Seven essential instruments for POPIA compliance in research involving children and adolescents in South Africa

Abstract

Compliance with South Africa’s Protection of Personal Information Act (POPIA) is a foremost governance challenge
for research involving high-risk and vulnerable groups such as children and adolescents. It remains unclear what constitutes adequate safeguards to protect the personal information of the child under this new law. To meaningfully
adhere to the principal aims of POPIA, researchers must understand and address the implications of this legislation
on research governance practices. Navigating the additional POPIA compliance requirements within established research projects additionally raises questions about how research can use POPIA to build on existing research governance mechanisms without extreme additional burden on research teams.

We invite readers to explore a series of best practices in safeguarding the personal information of children, adolescents, and young people (0–24 years old) – a key age group that represents nearly half of South Africa’s population in 2021. We will discuss possible actions which can be taken to ensure POPIA effectively builds on existing data protection mechanisms for research projects at all stages of the research cycle. These actions promote compliance to POPIA throughout the data life cycle. Our objective is to stimulate a broader conversation on how to improve the protection of children’s and adolescents’ sensitive personal information in South Africa and inform considerations that need to be addressed by the POPIA esearch Code of Conduct.

We join the POPIA discussion as a research group generating evidence that influences social and health policy and programming for young people in sub-Saharan Africa. Our contribution draws on our work adhering to multiple transnational governance frameworks imposed by national legislation such as data protection regulations, funders, and academic institutions. This has involved the use of several research governance mechanisms. In this Commentary, we summarise seven essential instruments to assist research projects involving children and adolescents to achieve POPIA compliance.