UK AADC Standard 4 — Transparency (ICO Age Appropriate Design Code, statutory guidance under DPA 2018 s 123)
Provide clear, age-appropriate privacy information and bite-sized data-use explanations
Where this comes from
Provision: Standard 4 — Transparency (ICO Age Appropriate Design Code, statutory guidance under DPA 2018 s 123)
Instrument: UK Age Appropriate Design Code
Citation: Data Protection Act 2018 s 123/s 127; ICO Age Appropriate Design Code, Standard 4 — Transparency
Text version: ICO Age Appropriate Design Code (statutory code of practice under Data Protection Act 2018 s 123; in force from 2 September 2020 with a transition period to 2 September 2021 - date not independently verified on the ICO pages), fifteen standards as displayed on ico.org.uk on 2026-09-23. The Data (Use and Access) Act 2025 has amended UK GDPR and the ICO has signalled a revised code: check for a reissued code before relying on this text.
Who it applies to
It applies when all of these are true:
- Service is likely to be accessed by children under 18
…unless:
- For the youngest age ranges the code relies more on parental involvement for privacy information, so information a young child cannot follow may be directed to parents; the code's condition is the child's age, not feasibility, and simplification must never... (ICO AADC Standard 4 - age-range recommendations)
Scope in the source's own terms
- Service has child users who need privacy information
- 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:
- Default profile visibility: private (not public)
- Default data sharing: off (opt-in, not opt-out)
- Default location tracking: off
- Default contact discoverability: off
- User can change any default via settings
Evidence an auditor expects
- User-interface evidenceUser testing
Age-appropriate privacy notices and explanations
Screenshots/recordings of privacy information presented to different age groups
- Test resultsUser testingRecommended
Comprehension testing with children
User research showing children understand privacy information at their reading level
Questions people ask
- Does UK AADC Standard 4 — Transparency (ICO Age Appropriate Design Code, statutory… apply to my service?
- It applies when Service is likely to be accessed by children under 18. It does not apply where For the youngest age ranges the code relies more on parental involvement for privacy information, so information a young child cannot follow may be directed to parents; the code's condition is the child's age, not feasibility, and simplification must never... (ICO AADC Standard 4 - age-range recommendations).
- From when does this apply?
- UK AADC Standard 4 — Transparency (ICO Age Appropriate Design Code, statutory… applies from 2 September 2021. Its current status is: in force.
- What evidence does an auditor expect?
- Age-appropriate privacy notices and explanations; Comprehension testing with children.
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.