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Age appropriate design: a code of practice for online services

The Information Commissioner's Office ('ICO') announced, on 12 August 2020 that the Age Appropriate Design Code ('the Code') has completed the parliamentary process and has been issued. In addition, the ICO noted that the Code will come into force on 2 September 2020 and online services will be granted a transition period of 12 months to conform to the same. This is the result of a process which commenced on 12 April 2019 with the launch of the consultation on the draft Code.

In particular, the Code contains 15 standards of age appropriate design for online services, including the best interests of the child, Data Protection Impact Assessments ('DPIAs'), age-appropriate application, transparency, connected toys and devices, and profiling. In addition, the ICO published resources ('the Resources') to help relevant online services and stakeholders comply with the Code, including a DPIA template. Moreover, the Department of Digital, Culture, Media & Sport ('DCMS') has published an explanatory memorandum ('the Memorandum') to the Code.


In particular, the Code contains 15 standards of age-appropriate design for online services, including the best interests of the child, Data Protection Impact Assessments ('DPIAs'), age-appropriate application, transparency, connected toys and devices, and profiling. In addition, the ICO published resources ('the Resources') to help relevant online services and stakeholders comply with the Code, including a DPIA template. Moreover, the Department of Digital, Culture, Media & Sport ('DCMS') has published an explanatory memorandum ('the Memorandum') to the Code.


“A generation from now we will all be astonished that there was ever a time when there wasn’t specific regulation to protect kids online. It will be as normal as putting on a seatbelt.

“This code makes clear that kids are not like adults online, and their data needs greater protections. We want children to be online, learning and playing and experiencing the world, but with the right protections in place.


In particular, the Code contains 15 standards of age-appropriate design for online services, including the best interests of the child, Data Protection Impact Assessments ('DPIAs'), age-appropriate application, transparency, connected toys and devices, and profiling. In addition, the ICO published resources ('the Resources') to help relevant online services and stakeholders comply with the Code, including a DPIA template. Moreover, the Department of Digital, Culture, Media & Sport ('DCMS') has published an explanatory memorandum ('the Memorandum') to the Code.


“We do understand that companies, particularly small businesses, will need support to comply with the code and that’s why we have taken the decision to give businesses a year to prepare, and why we’re offering help and support.” Elizabeth Denham, the Information Commissioner.


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