Openly breaking data protection law
These are the exact words from their cookie banner, including on their Get Help - AdvoCat page that utilises their cartoon character to appeal to child audiences and inform them about how to get help.
We also share information about your use of our site with our social media, advertising and analytics partners who may combine it with other information that you’ve provided to them or that they’ve collected from your use of their services.
Whilst they present a cookie banner, offering users to deny or allow such cookies, tracking has already loaded.
As the banner loads, so do requests to YouTube advising that you are using the site and Twitter of the exact page you are on.
Not the "best interests of the child"
The ICO makes it clear that child directed content must meet various standards, including "Best interests of the child"
A child seeking advocacy is in a vulnerable position and the interest in the service reveals they are likely in a care status.
It cannot be in the best interests of a child for a personalised advertising or social media content recommending engine to know that a child wants help with advocacy.
Because of the sensitive nature of this situation, the organisation should be respecting the privacy of the child.
The privacy of all other audiences viewing the website is important too, but likely not as important as those in need of advocacy.
Raising the complaint
23rd January 2023: complaint raised with Coram Voice and the ICO.
They replied the same day:
Thank you for your e-mail dated 23rd January 2023. I can confirm your request has been passed on to the relevant Manager. Your request will be reviewed, discussed and a response will be sent to you in due course.
In the meantime, if you require and further assistance please do not hesitate to contact me.
24th January 2023: A director replied too:
Thank you for your email below, which we received yesterday. We are reviewing the issues you raise.
And I replied with further details to help their investigation.
10th July 2023: Website still breaking the law and no reply yet. ICO updated with ongoing breach.