With six months to go until the transition period ends and the Age Appropriate Design Code (also being called the "Children's Code") comes into force, will your organisation meet the 15 Standards in time?
Does the Code apply to me? If you are based in the UK and providing commercial online/connected services or products that are likely to be accessed by under-18s, then Yes!
What first steps should we take if we're just starting to look at this now?
- Assess which of your products/services are "likely" to be accessed by under-18s, so you know what is covered by the Code;
- Consider whether your Privacy Notice is fit for purpose, bearing in mind the likely ages of the children accessing your site and their level of comprehension;
- Review whether there are any gaps in your DPIA coverage and get a plan in place to remedy this position within the time available, so that you can identify the risks and ensure relevant mitigations are put in place.
The ICO website has a very helpful guide explaining all the relevant Standards and providing guidance on how to meet them.
No time to delay...
We often see that organisational change takes much longer than anticipated and timelines tend to slip more than once! So, whatever stage your organisation is at now, don't delay implementation!
In the coming decade, I believe children’s codes will be adopted by a great number of jurisdictions and we will look back and find it astonishing that there was ever a time that children did not have these mandated protections.