Upwork's platform is for adults only and the company states it does not knowingly collect data from anyone under 18. If a child's data is found, Upwork says it will delete it.
This analysis describes what Upwork's agreement states, permits, or reserves. It does not constitute a legal determination about enforceability. Regulatory applicability and practical outcomes may vary by jurisdiction, enforcement context, and individual circumstances. Read our methodology
This provision reflects Upwork's operational compliance stance regarding children's data collection restrictions under laws like the Children's Online Privacy Protection Act (COPPA). It establishes the company's stated policy regarding age-gating and data retention procedures for underage users.
Interpretive note: The exact verbatim text could not be confirmed from the truncated document. The adequacy of Upwork's age verification mechanism is not described in the policy and is a practical compliance question distinct from the policy assertion.
Upwork's privacy policy previously disclosed that it complied with the U.S. Data Privacy Framework and certified adherence to its Principles regarding how it processes personal data from EU, UK, and Swiss residents. The updated policy removes nearly all of this language, including the explicit commitment to Data Privacy Framework Principles and the statement that those Principles would govern in case of conflict with other policy terms. Users in the EU, UK, and Switzerland no longer have a clear, policy-level statement of the legal framework protecting their data when transferred to the U.S., which may reduce transparency about data protection safeguards. You may contact Upwork to request copies of the data transfer mechanism documents it uses.
View change record →The updated policy now explicitly states that Upwork complies with the U.S. Data Privacy Framework and has certified to the U.S. Department of Commerce that it adheres to DPF principles when processing personal data from EU, UK, and Swiss residents. The policy establishes that if any conflict exists between Upwork's privacy policy and DPF principles, the DPF principles will govern. This creates an explicit legal hierarchy for data protection standards applicable to residents of those jurisdictions. Users from affected regions can visit https://www.dataprivacyframework.gov/ to view Upwork's certification and learn more about the DPF program.
View change record →If you are under 18 or are a parent of a minor who may have created an Upwork account, you should know that Upwork's services are not intended for minors and any such accounts should be reported to Upwork for deletion. Parents can contact privacy@upwork.com to request deletion of a minor's data.
How other platforms handle this
Customer will not, and will not permit any other person (including any End User) to: ... (c) include any personal information of children under 13 or the applicable age of digital consent as Customer Data or allow minors to use the Mistral AI Products without legally adequate consent from their pare...
The Services are not directed to children under 13. If you learn that your child under 13 has created an account on Duolingo, please contact us at privacy@duolingo.com. We do not knowingly collect personally identifiable information from children under the age of 13. Parents or guardians can create ...
To access or use the Service, you must have the requisite power and authority to enter into these Terms. Our Service is not directed to children, and any access or use of the Service by anyone under the age of 13 is not allowed.
Monitoring
Upwork has changed this document before.
Receive same-day alerts, structured change summaries, and monitoring for up to 10 platforms.
"Our services are not directed to individuals who are under the age of 18. We do not knowingly collect personal information from children under 18. If we become aware that a child under 18 has provided us with personal information, we will take steps to delete such information.— Excerpt from Upwork's Upwork Privacy Policy
REGULATORY LANDSCAPE: The Children's Online Privacy Protection Act (COPPA) in the US applies to operators of websites directed to children under 13 and requires verifiable parental consent before collecting personal information from children. Upwork's 18-plus age restriction means COPPA's 13-year threshold is not the relevant standard; rather, Upwork asserts a higher age limit. The EU's GDPR Article 8 sets the age of digital consent at 16 in most member states (with member state discretion to lower to 13), and platforms must take reasonable steps to verify user age for consent purposes. The UK Age Appropriate Design Code (Children's Code) imposes obligations on platforms likely to be accessed by users under 18. GOVERNANCE EXPOSURE: Low for a platform that is not directed at minors. However, the reliance on self-certification of age (rather than active verification) means that minors who misrepresent their age could access the platform, creating residual COPPA and GDPR Article 8 exposure. This is a standard industry practice for B2B-oriented platforms. JURISDICTION FLAGS: The UK Children's Code may impose obligations on Upwork if users under 18 are found to access the platform in meaningful numbers, even if the platform is not directed at them. EU member states with age 13 digital consent thresholds may have different implications for 13-15 year old users. CONTRACT AND VENDOR IMPLICATIONS: Enterprise clients using Upwork to engage freelancers should ensure their own procurement policies require contractor age verification, as Upwork's policy places reliance on user self-certification. COMPLIANCE CONSIDERATIONS: Compliance teams should confirm that Upwork's onboarding flow includes a clear age declaration mechanism and that the process for deleting minors' data upon discovery is documented and tested.
Full compliance analysis
Regulatory citations, enforcement risk, and due diligence action items.
Free: track 1 platform + weekly digest. Watcher: 10 platforms + same-day alerts. No credit card required.
Professional Governance Intelligence
Need to monitor specific governance provisions?
Professional includes provision-level monitoring, governance timelines, regulatory mapping, and audit-ready analysis.
Built from archived source documents, structured governance mappings, and historical version tracking.
This provision reflects Upwork's operational compliance stance regarding children's data collection restrictions under laws like the Children's Online Privacy Protection Act (COPPA). It establishes the company's stated policy regarding age-gating and data retention procedures for underage users.
If you are under 18 or are a parent of a minor who may have created an Upwork account, you should know that Upwork's services are not intended for minors and any such accounts should be reported to Upwork for deletion. Parents can contact privacy@upwork.com to request deletion of a minor's data.
ConductAtlas has identified this type of provision across 4 platforms. See the full comparison.
No. ConductAtlas is an independent monitoring service. We are not affiliated with, endorsed by, or sponsored by Upwork.