Australia has already shown it can act on children's online safety. The under-16 social media ban passed Parliament in November 2024 and took effect in December 2025. The Children's Online Privacy Code is in development. The appetite for action exists. Here's what can be done right now.

NSW Department of Education

1. Reverse the "must be public" requirement

The NSW DoE social media procedures currently state that school accounts "must not restrict access or be set as 'private' or 'closed.'" This policy was written when "public" meant "accessible to the school community." In 2026, "public" means "scraped by AI, indexed by search engines, harvested by facial recognition, and available to anyone on earth."

The fix is straightforward: update the procedures to allow (or require) school social media accounts to use private or restricted settings. This is a policy update, not legislation. The Department can do this immediately.

2. Update the Permission to Publish form

The current consent form is binary (all public publishing or none) and makes no mention of AI training, facial recognition, or data scraping. It needs:

This is a form update. It does not require legislation.

3. Issue clear guidance on AI-era social media risks

The Department should issue updated guidance to all NSW public schools addressing:

Schools are following current DoE guidance in good faith. That guidance is outdated. Updating it immediately changes the practice of every public school in NSW.

State and territory education departments (nationally)

4. Adopt consistent standards across all states

Every state and territory education department has its own social media policy for schools. None of them were written for the AI age. A coordinated national approach would ensure all Australian schoolchildren receive the same baseline protection, regardless of which state they live in.

The Education Council (the body that brings together state and territory education ministers) could agree to a set of minimum standards for school social media that include:

Federal Government

5. Accelerate the Children's Online Privacy Code

The OAIC's Children's Online Privacy Code is due by December 2026. It should explicitly address:

6. Close the consent gap in the Privacy Act

The current Privacy Act reform process should address the gap between what parents consented to ("publishing") and what actually happens ("permanent extraction into AI systems"). Consent given for one purpose (school communication) should not automatically extend to another (AI training, facial recognition).

The Privacy Act should also clarify that:

7. Require Meta to offer an opt-out for Australians

Meta offers European users an opt-out from AI training because GDPR requires it. Australians have no equivalent protection. Senator David Shoebridge summarised the situation directly: "Meta made it clear today that if Australia had these same laws, Australians' data would also have been protected."

Australia should legislate a right for all users, including schools and organisations, to opt out of having their public content used for AI training. Until then, the only defence is to not make the content public in the first place.

8. Enforce the Clearview AI order

The Australian Information Commissioner found Clearview AI breached the Privacy Act and ordered the company to stop collecting Australian data and delete what it had. There is no evidence of compliance. The OAIC should actively pursue enforcement, not let the matter rest.

What's already in motion

December 2025
Under-16 social media ban took effect
4.7 million accounts removed. But does not address schools posting children's photos.
March - June 2025
Children's Online Privacy Code consultation
OAIC exposure draft released for public comment.
December 2026
Children's Online Privacy Code due
Will set new standards for children's personal information online.
Ongoing
Privacy Act reform
Comprehensive reform underway. Likely to strengthen children's protections.
The biggest wins don't require new legislation

Updating the NSW DoE social media procedures, updating the Permission to Publish form, and issuing new guidance to schools are all administrative actions. They can happen immediately. They would protect every child in every NSW public school. And they would set a precedent for every other state and territory to follow.

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