The ICO’s Age Appropriate Design Code: Parental Controls and Online Tools

This post discusses Standards 10 and 14 of the draft Age Appropriate Design: A Code of Practice for Online Services published by the UK’s Information Commissioner’s Office’s (ICO).

Standard 10 of the Code would require notice to children when an online service allows parental monitoring or tracking.  This would include a “clear and obvious sign” when monitoring is in progress (e.g., a lit-up icon).  (Section 13 of the Code, which addresses connected toys and devices, would similarly require clear notice to children and parents when data is being collected, for example, a light that switches on when audio is being recorded.)

Section 14 would require providers to provide prominent and accessible tools (e.g. a “download all my data” and “delete all my data” tools) to help children exercise their data protection rights and report concerns.  The Code states that providers “have an obligation not just to allow children to exercise their rights but to help them to do so.”  The ICO recommends highlighting the tools during the setup process and making them accessible via a clear and easily identifiable icon placed prominently on the screen.