The Children’s Code – what you need to know about the Age Appropriate Design Code

26th August 2021Children's

As Elizabeth Denham, the Information Commissioner, said a year ago when she first introduced the Code:

“Taking care of children online should be as normal as putting their seat belts on in a car.”

The Children’s Code is a code of practice that organisations must follow if they provide services such as apps, online games, online services, or social media or website sites, if they are likely to be accessed by children.

The desired outcome is that children will enjoy a much safer and more positive experience online.

In September 2020, she gave organisations 12 months to prepare – those 12 months has expired, and on 2 September 2021, the new Code will be enforced.

Enforcement action by the ICO includes audits, orders to cease, and fines of up to 4% of global turnover.

Are you ready?

  • Have you put children first?
  • Have you given children high privacy settings by default?
  • Do you give children an age-appropriate service even if they change their default settings?
  • Do you provide age-appropriate communications?
  • Do you provide tools that help children when they need it?
  • Do you know how old your users are? If not, have you provided a high privacy service to all users by default?

If you want some general advice about whether this applies to your organisation and how to go about implementing it if you haven’t already – you are welcome to book a complimentary zoom consultation with one of our data protection specialists here at Griffin House Consultancy.

Do you want to reassure your customers and gain recognition from regulators?

To help organisations comply and to demonstrate that compliance, the ICO has just approved a Certification scheme focusing entirely on proving your commitment to safeguarding children online via your compliance with the Children’s Code.

The ICO issued a press release on 19 August 2021 stating that this ‘new certification will raise the bar of data protection in children’s privacy and age assurance . .’

How do I get started?

Firstly, you should familiarise yourself with all of the specifics of the Children’s Code.  The Information Commissioners website has a hub of information regarding all aspects of the Age Appropriate Design Code.

Then take your practical steps:

  1. Pre-Audit assessment. This is where you (perhaps with the help of a consultant), comb through all relevant policies and procedures and produce an analysis report stating where you are compliant and whether there are any gaps.
  2. Update your policies, procedures, and practices accordingly
  3. Get certified – protect your organisation, protect children, enhance your credibility, and thrive in a world of increasingly privacy-conscious consumers.

If you would like your website, online service or digital offering audited against the code in order to achieve certification, we recommend you look at the Age Appropriate Design Certification Scheme (AADCS), you can also email [email protected]. It is a fully accredited and reputable scheme and the AADCS website contains a wealth of information about the Code too.

If you contact them say hi from us and please tell us how you got on by emailing us at [email protected].

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