Age appropriate design is an aspect of
general compliance with the UK GDPR.


On 2 September 2020 the Information Commissioner’s Office (‘the ICO’) ‘Age appropriate design: a code or practice for online services’, dubbed by the ICO as ‘the Children’s Code’ came into force, with a twelve months’ transition period requiring organisations to be in conformity with its provisions by 2 September 2021.

VerifyMyAge instructed James Hines QC & Ben Summers of 3 Raymond Buildings to provide an opinion on the effect of the Code and to express their view on the risk of enforcement action in response to breaches of the Code’s provisions. This document contains a brief summary of their opinion on the effect of the code.


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