The ICO exists to empower you through information.

Identify additional measures you could take to reduce or eliminate risks identified as medium or high risk in step 5.

To assess the level of risk, you must consider both the likelihood and the severity of any impact on children. High risk could result from either a high probability of some harm, or a lower possibility of serious harm. You should bear in mind that some children will be less resilient than others, so you should always take a precautionary approach to assessing the potential severity of harm.

Risk Options to reduce or eliminate risk Effect on risk Residual Measure approved
    Eliminated/ reduced/ accepted Low/ medium/ high Yes/no
Use of (game play) data that contravenes health standards and guidelines (for example issues by the Chief Medical Officer or Public Health England). Risk that data-enabled service personalisation leads to excessive engagement, that risks children’s right to access health services.

Game-play sessions are designed to be short (90 secs), the game can be paused or exited without losing place in the game, release of new themes is spaced out.

We keep up to date with government advice on the welfare of children in the context of digital services through updates from our representative body.
reduced low yes
Personalised targeting of service features that generate revenue (for example in-game perks or purchases) that are set without adequate transparency and safeguards, risking children’s right to protection from economic exploitation. All in-app purchases or subscriptions require parental authorisation. There is a contact function for parents to contact us for accidental purchases. reduced low yes
Parental controls for monitoring children's activities are used without adequate transparency for children, risking children’s rights to protection from other forms of exploitation. A parental overlay enables adults to set up the system. Additional parental controls are provided by platform level. accepted medium yes
Personalised advertising of fraudulent or age-inappropriate products that risks children’s right to protection from economic exploitation. All ads are age-appropriate. We use an ad provider specialising in children’s ads.  There is no targeted or contextual advertising. Ads are clearly distinguished from game-play and do not request or require direct action from the children. eliminated low yes
Failure to uphold community standards exposes children to harms that have a chilling effect (for example leaving online communities – family circle - as the result of abuse) risks children’s right to freedom of association. Sharing features in family circle allow limited content to be shared, such as game scores and emoticons that do not share user personal data with others. No opportunity for negative messages to be created and shared through family circle eliminated low yes
Online tools for children (and parents, for younger children) to exercise their data rights that are untransparent, not specific to the rights they support, or not provided, risking children’s right to knowledge of their rights. Data rights explained in adult and children’s privacy notices. An email address is available for individuals to contact us with any questions about their rights and to exercise their rights. There is also a contact button within the app itself to help children contact us to exercise their rights. reduced low yes