Artifact GuideUKChildren's Code

UK GDPR Children's Code

Children's Code decisions under the UK GDPR should be written in operational language: who is in scope, what must happen, what evidence proves it, and when escalation is needed.

This guide converts requirements into implementation-ready ownership, evidence, and review decisions. It is practical guidance, supporting implementation planning and should be validated against jurisdiction-specific legal, contractual, and policy requirements before implementation.

Author
Sorena AI
Published
May 9, 2026
Updated
May 9, 2026
Questions
3

Structured answer sets in this page tree.

Primary sources
5

Cited legal and guidance references.

Publication metadata
Sorena AI
Published May 9, 2026
Updated May 9, 2026
Overview

The Children's Code is the ICO's statutory Age Appropriate Design Code for online services likely to be accessed by children. If your service, app, game, website, or connected device may be used by children, the code sets design and governance standards you need to build into the product and keep under review.

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3 of 3 questions
Question 1

What should teams do about Children's Code under the UK GDPR?

Teams should treat Children's Code under the UK GDPR as a source-linked operating decision for online services likely to be accessed by children: confirm whether the issue affects controller/processor roles, lawful basis, transparency, DPIA, data-subject rights, breach notification, IDTA/Addendum transfers, children data, or ICO enforcement exposure, assign the team that can change the process, and keep evidence showing the action and review trigger.

The safest first step is to confirm whether the product or service is likely to be accessed by children, then identify the controller/processor role, purpose, lawful basis, special-category status, right, breach, transfer, or child-data trigger before assigning the UK GDPR action.

  • Write the Children's Code decision in one sentence before drafting controls.
  • Attach the external source URL and a short source quote to the evidence record.
  • Route unclear cases to legal, privacy, security, or compliance review before launch.
Citations
Question 2

What evidence should teams keep for Children's Code under the UK GDPR?

Useful evidence is not just a privacy notice. Keep the source, lawful-basis note, DPIA, rights log, breach assessment, transfer mechanism, processor terms, and approval trail together.

  • Source URL and quote used for the decision.
  • Scope notes, screenshots, data-flow or system references, and role mapping.
  • Implementation ticket, approval record, exception notes, and review date.
Citations
Question 3

Which mistakes create risk when handling Children's Code under the UK GDPR?

The common failure pattern is copying an EU GDPR answer without checking UK GDPR wording, DPA 2018 limits, ICO guidance, UK transfer tools, PECR overlap, and post-Brexit divergence.

  • Using an old threshold, deadline, source page, or contract template without checking current source text.
  • Treating a source-linked exception as a general exemption for every product or data flow.
  • Publishing notices, controls, or answers that do not match the actual product behavior.
Citations
Primary sources

References and citations

gov.uk
Referenced sections
  • GOV.UK publication record confirming the Age Appropriate Design Code was laid before Parliament.
"The Age Appropriate Design Code was laid before Parliament on 10 June 2020"
ico.org.uk
Referenced sections
  • ICO Article 30 template supporting records of processing evidence for Children's Code decisions.
"Headings highlighted green are required areas of documentation under Article 30 of the GDPR"
ico.org.uk
Referenced sections
  • ICO code supporting evidence practices when Children's Code work involves data sharing decisions.
"As the UK Information Commissioner, I know that data is one of modern society's greatest assets"
ico.org.uk
Referenced sections
  • ICO design guidance showing when teams should consider the Children's Code standards and children's best interests during product design.
"You must consider the standards and children's best interests at key moments in the design process"
ico.org.uk
Referenced sections
  • ICO statutory Children's Code source supporting age-appropriate design duties for online services likely to be accessed by children.
"best interests of the child are the primary consideration when designing and developing online services"
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