Childnet’s response to the Government's consultation on Age Appropriate Design

Posted on 26 September 2018

Recently, Childnet submitted a response to the Information Commissioner’s (ICO) call for evidence in its development of the Age Appropriate Design Code.

What is the Age Appropriate Design Code?

The Code is a requirement of the Data Protection Act 2018, which supports the UK’s implementation of the EU General Data Protection Regulation (the GDPR). For lots of us, GDPR meant receiving lots of emails towards the end of May 2018, asking us to give permission for online retailers, charities and networks to continue our data on their systems.

It’s an important piece of legislation that requires that all the websites we use adhere to agreed standards around collecting, using and sharing the personal data we provide when we use them. That’s anything from our email addresses and shopping habits to what we tend to read on social media, or our location.

When it’s developed and becomes law, the Code will provide guidance on the design standards that providers of online ‘Information Society Services’ (ISS), which process personal data and are likely to be accessed by children, to meet.

Why is the Code important?

What’s interesting about the Code is that it provides an opportunity to put Children’s Rights at the heart of what websites and online services do to protect children, and make sure they can get the best out of the digital world. The Code is looking at data and privacy, from how Terms and Conditions are presented online, to geolocation services. But it also goes much further, according to the ICO, for instance, “strategies used by sites and apps to personalise a child’s experience to encourage them to stay online longer, such as auto play videos and the timing of social media notifications.”

Being guided by the UN Convention on the Rights of the Child means that Code will apply not only to the sites that young children use all the time, but anything that under 18s are likely to access. This means that in future, companies, social media platforms, streaming sites, voice-activated service providers and other digital tech companies will have to think about what’s in the best interests of children as they design their online offer.

What did Childnet do to prepare its response?

To prepare for our response, Childnet staff took part in discussions with lots of other charities, University researchers and industry representatives, to learn about the scope and potential of the code. It was fascinating to learn from one researcher that our data is worth about $5 a year to internet companies. It doesn’t sound like much, but when so many of us use the same few platforms to shop, chat or find out what’s going on, it adds up!

We also consulted with young people who take part in Childnet’s programmes through our Digital Leaders platform and our deSHAME youth board. Their responses included lots of recommendations for social media companies about how they present how data is used by them; one person said, “Be clear. These days, companies have everything, and it can be easily leaked or sold for profit like the Cambridge Analytica scandal”, while another suggested that young people would understand what terms and conditions they’re agreeing to if companies, “Make a short video on it before you agree to it”. Since most young people – and adults! – never read terms and conditions, how can we understand what we’re agreeing to, when it comes to how our data is collected, used, and sold on?

What’s next for the planned Code?

The ICO will consider the responses of all the organisations that took part in the consultation, and is also working directly with young people and parents to get their views. When finalised and through Parliamentary processes, the Age Appropriate Design Code will, says the ICO, “let those who design the online services that children use know what we expect from them.”

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