The UK’s independent authority set up to uphold information rights in the public interest, promoting openness by public bodies and data privacy for individuals.

Deputy Commissioner Steve Wood gives an update on the code and impact assessment for relevant online services and stakeholders

Our Age Appropriate Design Code is nearing the end of the Parliamentary scrutiny process. From August, it will be used as a practical guide for relevant online services to protect children’s privacy.

It’s a huge step towards protecting children online, especially given the increased reliance on online services at home during COVID-19, but there is still work to be done. Anyone who has been following its development will know the code’s 15 standards are rooted in existing law, and that the code itself is not a new law. It has been created as a tool to steer businesses to comply with current information rights legislation and was introduced by the Data Protection Act 2018.

We know that many businesses will still need support during the 12 month transition period. That’s the timeframe set out for businesses to make adjustments to products and services before the code comes fully into force in August 2021. So, we’re developing a package of support which will provide practical resources to help organisations in assessing the changes they need to make and taking steps towards them. We’re also exploring how services such as our regulatory sandbox can support organisations innovating in this space.

Our plans about where to focus our support will be informed by the impact assessment of the code we published on 17 July. Using evidence from our wide-ranging consultation; engagement with stakeholders including the tech industry, campaigners, trade bodies and organisations; and publicly available research and data, the assessment builds on what we know considering both the benefits to children, parents, businesses and wider society as well as the implementation costs.

Parliament set the scope of the code so it would be broad, covering not just online services designed for children but also those services that are likely to be accessed by children. And, as we state in our impact assessment, this makes quantified analysis of the costs and benefits challenging, with costs varying considerably even between small and medium enterprises (SMEs).

We’ve consulted representative bodies about the nature of support their member organisations would find useful but we’re looking for further input to help us shape our package of support to make sure we identify the most relevant and impactful advice and support. We are open to receiving more quantitative evidence from organisations on the benefits and costs of the code as the transition period progresses to provide us with further insight.

If you are a representative body, a business or an organisation affected by the code and you have suggestions on the type of support that would be helpful or you wish to provide further evidence on the costs and benefits of the code please email us at

The ICO has committed to reviewing the Age Appropriate Design Code in August 2022, one year after the transition period, to understand how the code is working and whether the costs and benefits are in line with expectations. The review will allow us to assess whether the support package is sufficient and to tailor any additional resources we decide to develop.