Policy Briefing — UK Age Appropriate Design Code finalised with 12-month transition
The ICO’s final Age Appropriate Design Code sets 15 standards for online services likely accessed by children, with a one-year transition to embed data minimisation, profiling limits, and high-privacy defaults before 2 September 2021 enforcement.
Executive briefing: The statutory code under the UK Data Protection Act 2018 requires online services to apply the best interests of the child, geolocation and profiling switches off by default, and transparent notices written for age groups. Organisations have 12 months from the 12 August 2020 publication to implement the 15 design standards before ICO enforcement begins on 2 September 2021.Code sections 2, 3; pp. 20–23
Operational steps
- Service inventory. Map products likely to be accessed by children and document risk ratings, DPIAs, and age assurance approaches.
- Design controls. Disable geolocation and profiling by default for child users, and ensure nudge techniques do not lower privacy.
- Evidence packs. Prepare transparency pages and governance records demonstrating board oversight and escalation routes for children’s data risks.
Sources
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