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We're planning to run a simple competition at an event. It's a skill based competition (not a lottery), where the best score at the end of the event will receive an android tablet. No purchase is required to enter. It's just meant to be fun. The target audience of the event is very broad, and we expect a lot of children to attend. The event will be in held in Finland and we're a Finnish company.

To run the competition, we obviously need a way to contact the prize winners. It's a two day event, so we are planning to keep an encrypted Excel sheet on a local computer with the player's name, contact information, and score. The only purpose of the sheet is to contact the winner and ship the prize to them - we will securely delete all the data after the event.

(We will get our real lawyer to check our terms and conditions are watertight beforehand, but I don't want to seek their advice if what we're trying to do is clearly illegal.)

In summary, the question is : is it legal to collect contact information on minors to facilitate a "for fun" competition with all data used strictly only for that purpose?

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Basically, you need informed consent from the participants to collect this personal data.

For children under 16 years, you also need informed consent consent from the parent or guardian.

The relevant legislation is GDPR Article 8 and Recital 38. (Or will be after May 25th. 2018)

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  • In the end, we asked everyone their age before allowing entry with contact info. In addition, to let the younger kids play too, we created an anonymous entry method : we got the kids to pick a random science object, which we paired with randomly generated numbers. We shouted out the winner on our social media and website, and the kids could then get their parent to contact us to claim the prize with their "secret number". This let everyone participate in the fun, and many privacy conscious adults used it too! – Matt Bond May 26 '18 at 20:21

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