UK AADC ICO Guidance - Conformance documentation
Maintain records showing how each AADC standard has been addressed
Where this comes from
Provision: ICO Guidance - Conformance documentation
Instrument: UK Age Appropriate Design Code
Citation: Information Commissioner's Office, Age Appropriate Design: a code of practice for online services, Conformance guidance
Text version: ICO Age Appropriate Design Code (statutory code under Data Protection Act 2018 s 123), issued 2 Sept 2020
Who it applies to
It applies when all of these are true:
- Service is likely to be accessed by children under 18
…unless:
- Services not likely to be accessed by children do not need to maintain AADC conformance records. (ICO AADC Scope)
Scope in the source's own terms
- Service is likely to be accessed by children
- Service operates under GDPR (EU scope; block moved from UK-GDPR authorship)
What engineering work it implies
Sample acceptance criteria Landfall generates for this obligation:
- Register maps each standard/requirement to the design decisions that address it
- Each entry links its supporting risk assessments and records the residual risk accepted
- Register is versioned; changes are dated and attributable to an author
- Register names an owner and a review cadence (at least annual)
- Register is producible for the regulator on request
Evidence an auditor expects
- Audit reportDocument reviewRetain 6 years
AADC conformance self-assessment
Documented assessment showing how each of the 15 AADC standards has been addressed
- Process recordLog analysis
Conformance record update history
Version-controlled record of conformance assessments with change history
Questions people ask
- Does UK AADC ICO Guidance - Conformance documentation apply to my service?
- It applies when Service is likely to be accessed by children under 18. It does not apply where Services not likely to be accessed by children do not need to maintain AADC conformance records. (ICO AADC Scope).
- From when does this apply?
- UK AADC ICO Guidance - Conformance documentation applies from 2 September 2021. Its current status is: in force.
- What evidence does an auditor expect?
- AADC conformance self-assessment; Conformance record update history.
Find out whether this one lands on you
Landfall's pre-scan answers the applicability question above for your product in minutes, then turns every obligation that applies into traceable engineering tickets with a citation chain your auditors can follow.
Not legal advice. Landfall maps regulatory obligations to engineering work for planning purposes. Its verdicts are not legal advice and create no attorney-client relationship — verify with qualified counsel before relying on them.