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Published 19.11.21

General comment No. 25 - Chapter XI: Education, leisure and cultural activities B

B. Right to culture, leisure and play

  1. The digital environment promotes children’s right to culture, leisure and play, which is essential for their well-being and development. Children of all ages reported that they experienced pleasure, interest and relaxation through engaging with a wide range of digital products and services of their choice, but that they were concerned that adults might not understand the importance of digital play and how it could be shared with friends.

  2. Digital forms of culture, recreation and play should support and benefit children and reflect and promote children’s differing identities, in particular their cultural identities, languages and heritage. They can facilitate children’s social skills, learning, expression, creative activities, such as music and art, and sense of belonging and a shared culture. Participation in cultural life online contributes to creativity, identity, social cohesiveness and cultural diversity. States parties should ensure that children have the opportunity to use their free time to experiment with information and communications technologies, express themselves and participate in cultural life online.

  3. States parties should regulate and provide guidance for professionals, parents and caregivers and collaborate with digital service providers, as appropriate, to ensure that digital technologies and services intended for, accessed by or having an impact on children in their leisure time are designed, distributed and used in ways that enhance children’s opportunities for culture, recreation and play. That can include encouraging innovation in digital play and related activities that support children’s autonomy, personal development and enjoyment.

  4. States parties should ensure that the promotion of opportunities for culture, leisure and play in the digital environment is balanced with the provision of attractive alternatives in the physical locations where children live. Especially in their early years, children acquire language, coordination, social skills and emotional intelligence largely through play that involves physical movement and direct face-to-face interaction with other people. For older children, play and recreation that involve physical activities, team sports and other outdoor recreational activities can provide health benefits, as well as functional and social skills.

  5. Leisure time spent in the digital environment may expose children to risks of harm, for example, through opaque or misleading advertising or highly persuasive or gambling-like design features. By introducing or using data protection, privacy-by-design and safety-by-design approaches and other regulatory measures, States parties should ensure that businesses do not target children using those or other techniques designed to prioritize commercial interests over those of the child.

  6. Where States parties or businesses provide guidance, age ratings, labelling or certification regarding certain forms of digital play and recreation, they should be formulated so as not to curtail children’s access to the digital environment as a whole or interfere with their opportunities for leisure or their other rights.

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