Consent may be implied in some cases

When you directly collect personal information to provide a service, an individual’s consent may be implied.⁶⁰ Implied consent is consent that is not given explicitly, but which can be inferred based on the individual’s actions and the facts of a particular situation. You may imply consent for the use of personal information if you collected it directly and to provide a service. For example, if a parent gives you their personal information directly so that you can provide a service, you may imply their consent to use the information for this purpose.

In other cases, consent must be explicit and not merely implied. This includes any consent required for:

• an indirect collection
• a collection other than to provide a service
• a use of personal information, if the information had been collected indirectly, or was collected for a purpose other than providing a service
• a disclosure

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