Where policy and practice collide: Comparing United States, South African and European Union approaches to protecting children online

That children have a right to protection when they go online is an internationally well-established principle, upheld in laws that seek to safeguard children from online abuse and exploitation. However, children's own transgressive behaviour can test the boundaries of this protection regime, creating new dilemmas for lawmakers the world over. This article examines the policy response from both the Global North and South to young people's online behaviour that may challenge adult conceptions of what is acceptable, within existing legal and policy frameworks. It asks whether the 'childhood innocence' implied in much protection discourse is a helpful basis for promoting children's rights in the digital age. Based on a comparative analysis of the emerging policy trends in Europe, South Africa and the United States, the article assesses the implications for policymakers and child welfare specialists as they attempt to redraw the balance between children's online safety while supporting their agency as digital citizens.