ICO publishes final online Age Appropriate Design Code

DPIAs, high level privacy settings and switching profiling “off” by default are aspects required by this code, subject to Parliamentary approval. By Ben Slinn of Baker & McKenzie.

On 21 January 2020 the ICO published its Age Appropriate Design Code of practice for online services following a public consultation in April 2019(1). The ICO is required to prepare this statutory Code under Section 123 of the Data Protection Act 2018. In terms of next steps, the Code needs to be approved by Parliament, and following such approval there will be a 12-month transition period before the Code takes effect. The ICO expects the transition period to end in autumn 2021.

The Code is likely to have a significant impact on the design of online services and related data protection compliance. The ICO launched a consultation on 26 February 2020 (open until 27 March 2020) on a package of support it intends to publish to assist organisations with conforming to the Code(2).

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