The ICO has issued a number of recommendations to game developers to protect children and to ensure compliance with the Children’s Code.

Key highlights are:

  • developers must be able to identify if their users are under 18 years old and discourage false declarations of age.
    • creation of games that are not detrimental to a child’s well-being by including prompts to encourage a user to take breaks
    • privacy settings should be set to high by default
    • ensuring that behavioural profiling for marketing is switched off by default.
    • nudge techniques for children to reduce their privacy (i.e. creating a social media account for rewards) should be discouraged.

This latest piece of guidance from the ICO is another example of the increased focus by legislators and regulators on the protection of children in online spaces, including the incoming Online Safety Bill. We expect the ICO to continue to be proactive in this space, conducting audits and taking enforcement action over any breaches.

 See the ICO’s full statement here.