Internet Matters response to Age Appropriate Design Code call for evidence

This Code will provide guidance on the privacy standards that the ICO will expect organisations to adopt where they are offering online services and apps that children are likely to access and which will process their data.

We are delighted to provide our response to the ICO consultation on the age-appropriate design code. We have based our response on what parents have told us. For example, our Cybersafe research from 2016 indicates that parental concerns around online safety peak when children are within the 10-13 age range is lower with younger children, and tends to drop off in the later teenage years.

For younger children, there is an increasing choice of products designed for pre-school and KS1 and this, combined with the reality that most younger children are not navigating the internet by themselves, but with parental engagement and oversight. Therefore our recommendation is that ICO focus on where they can have the most impact.

This is important since the services children start to use aged 10+ are typically the same services that have been designed for use by adults, including social networking, email, use of apps and instant messaging. In this context, the gap to be fixed here is the space between toddlers and older teens, with a real focus on designing with safety for the cohort that are growing their independence online between the ages of 10-13.

Parents’ main online concerns for their children are those which could damage the child’s emotional well-being or put them in physical danger, principally: sexual content, inappropriate content they find themselves, violent content and strangers/grooming. However, as children’s Internet use becomes more social, new risks emerge and levels of parental concern increase.

Our research suggests that the ages of 10 to 13 represent a critical moment at which parents feel most concerned about their children’s internet use and would most welcome a strong intervention on age appropriate design.