Information Commissioner’s Office consultation on its Age Appropriate Design Code

Call for Evidence

The Information Commissioner made a call for evidence and views on the Age Appropriate Design Code on 27 June 2018. The Code is a requirement of the Data Protection Act 2018. The Act supports and supplements the implementation of the EU General Data Protection Regulation (the GDPR).

The Code will provide guidance on the design standards that the Commissioner will expect providers of online ‘Information Society Services’ (ISS), which process personal data and are likely to be accessed by children, to meet. Once it has been published, the Commissioner will be required to take account of any provisions of the Code she considers to be relevant when exercising her regulatory functions. The courts and tribunals will also be required to take account of any provisions they consider to be relevant in proceedings brought before them. The Code may be submitted as evidence in court proceedings. The Commissioner seeks evidence and views on the development stages of childhood and age-appropriate design standards for ISS.

Summary of the Turing’s submission

This document provides the response of The Alan Turing Institute to the Information Commissioner’s Office (ICO) consultation on its draft code of practice for online services likely to be accessed by children. The Institute’s response combines the perspectives of various Turing researchers and those in its wider university network.

This response is split into two sections. The first makes comments on the overall code including why it is necessary and what we believe is missing from it, while the second addresses specific areas of the code.