The ICO's Age Appropriate Design Code

On 2 September, the UK's Information Commissioner announced that the Age Appropriate Design Code (AADC) is now in force. The AADC takes the provisions of the GDPR and applies them to the specific needs of children in the online world. Affected organisations now have a 12 month implementation period (until September 2021) in which they must act to ensure they achieve compliance.

The AADC has a reach that stretches further than many organisations may realise because it applies to services likely to be used by under 18s, not just those targeting them. This brings online retailers, news sites, social media platforms and even financial services providers within scope. The AADC also sets out detailed expectations for children of different ages, dividing children into age brackets with specific vulnerabilities and needs that should be addressed. The ADDC provides an important reminder that, even where the consent of a parent is provided, children still have a right to be informed about issues affecting their privacy, including where their online activities can be monitored by a parent.

The AADC contains 15 interconnecting provisions that set out the requirements online services must meet to make their services suitable for under 18s. Topics range from the familiar GDPR principles of data minimisation to more specific concerns around age verification and connected toys. The AADC now sits alongside UK data protection legislation to provide structure and detailed guidance to service operators' data privacy compliance efforts, as well as standards for the regulator to consider when determining the legality of processing activities.

In this webinar from 9 September, Vin Bange, Jo Joyce, and Tamara Mackay-Temesy discuss what the AADC means for online businesses and look at some of the compliance challenges they will need to resolve during the 12 month implementation period. The team also discuss how legal design processes and techniques may be used to meet the requirements of the AADC.