Photo of Fiona Bundy-Clarke (UK)

On 15 April 2019, the ICO opened a public consultation on a draft code of practice titled Age Appropriate Design (the “Code”).  The Code will remain open for public consultation until 31 May 2019.

The consultation document is described as a “code of practice for online services likely to be accessed by children.”  However, its potential impact is in fact wider, and is perhaps better described as applying to all online services that are not demonstrably unlikely to be accessed by children, which it controversially defines as individuals under 18.  For this reason, the Code in its current form will have implications for almost all providers and users of online services.