Age Appropriate Design Code – A Consultation

I suspect that for many in schools the consultation launched by the ICO on the age appropriate design code has passed them by. Its title is not particularly illuminating and its not actually an education-based initiative. It is however very important and welcome.

What is the Age Appropriate Design Code

It is the latest development of the Data Protection Act 2018 and GDPR specifically related to the protection of children’s data online. It is being developed for information society services (ISS) which includes online products or services (including apps, programs, websites, games or community environments, and connected toys or devices with or without a screen) that process personal data and are likely to be accessed by children in the UK.

What is in the code?

The code sets out 16 standards that the providers of ISS should meet. The standards should not be considered in isolation but should be recognized as being interdependent. They include ensuring providers act in the best interest of the child through, ensuring transparency and data minimization and of particular importance is the requirement to uphold the providers own policies and age restrictions.

Why is this important?

This creates a new standard of data protection for children. It places responsibility firmly in the hands of the technology companies who are providing services that may be accessed by children. To place this into context most Social Media giants have T&Cs that state that users must be at least 13 years of age. This means that they are providing a service to children. To meet the code, they should ensure their service is designed for children and meets the standards, or they must change their T&Cs by raising the minimum age and most likely must introduce some form of age verification. This will change the way many companies will need to operate.

Why New Era Education welcomes the code.

New Era Education are committed to improving the Internet for children. We want them to enjoy the power and the benefits. We want them to share in the joy of playing games, watching videos, communicating and collaborating online. But we want them to do so safely, and for them to develop their digital literacy skills. DB Primary, our award-winning online safety platform, is specifically designed for children to use, supported by quality teaching, to learn about digital citizenship and to understand about privacy and how data is used online, including that given, acquired and inferred.

New Era Education are ISS providers to children (through their school) and will be subject to the code. We fully respect the code and the principles that underpin it. It presents us with no challenge and is a welcome addition to the increasing regulation that is placing the UK at the forefront of a better, safer Internet.

The Next Steps

Consultation closes on the 31^st May 2019. Following that the responses will be analyzed, and amendments made accordingly. It will then be presented to parliament before implementation. Currently the consultation is recommending a transition period to allow for adjustment of three months. The new legislation could be in place by January 2020. We welcome it.

For schools the code should present no significant issues. It would be worthwhile checking with service providers that they comply. New Era Education can confirm that we will comply for all the products and services accessed by children. 

For further information please see the 5Rights briefing here.