The ICO exists to empower you through information.

Your result 

You are unlikely to be meeting minimum standards set in the  Children's code!

You need to identify and action any additional measures necessary to conform. Review the Children's code design guidance to see how you can improve.

Next steps 

You must undertake an assessment to establish whether children are likely to access your service in order to determine if you are meeting your data protection obligations and if you need to comply with the Children's Code. 


    • You may wish to refer to market research, current evidence on user behaviour, the user base of similar or existing services and service types and testing of access restriction measures.
You must provide privacy information that is suitable for all potential child users of your service to meet the age appropriate application standard in the Children's code.


  • Continue to find ways to present privacy information in a way that is likely to appeal to the age of the child who is accessing your online service.

This may include using diagrams, cartoons, graphics, video and audio content, and gamified or interactive content that will attract and interest children, rather than relying solely on written communications.

  • Conduct user research with children, parents and carers to test if your privacy information is understandable for children.

If this is not possible or you think it is unnecessary, use academic research to support your design decisions

Additional resources

Your answers 


Your answer 


Have you been able to establish the ages and or development needs of children using your service?


Action required! You need to establish the age of the people using your service to ensure you're meeting your data protection obligations. 

Have you designed privacy information for all children likely to access your service in a child friendly way?

We have not designed privacy information specifically for children likely to access our service or their carers.

Action required! If you don't know the ages or developmental needs of the children using your service, then it is important that privacy information is designed for all children likely to access your service and their carers. If you don't want to design for all potential child users then you need to establish the ages and or developments needs of the child.