UK AADC Standard 8 - Data minimisation
Collect only minimum data needed for features child actively uses; offer granular choices
Where this comes from
Provision: Standard 8 - Data minimisation
Instrument: UK Age Appropriate Design Code
Citation: Information Commissioner's Office, Age Appropriate Design: a code of practice for online services, Standard 8
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:
- Content personalization is not strictly necessary for service delivery
- Service is likely to be accessed by children under 18
- Service collects behavioral data
- Behavioral data collection is not strictly necessary for service delivery
…unless:
- Profiling is permitted where it is in the best interests of the child (e.g., educational recommendations, safety filtering). (ICO AADC Guidance, Standard 8.3)
- Profiling for fraud prevention or safety purposes may be permitted without explicit consent. (ICO AADC Guidance, Standard 8.5)
What engineering work it implies
Sample acceptance criteria Landfall generates for this obligation:
- Consent modal/page appears BEFORE data collection begins
- Consent options are granular (user can accept some, reject others)
- 'Reject All' is as prominent as 'Accept All'
- No pre-checked boxes - all start unchecked
- When relying on consent, store the necessary scoped consent reference, purposes and choices, timestamp and notice version; avoid collecting extra identity data solely for the record
Questions people ask
- Does UK AADC Standard 8 - Data minimisation apply to my service?
- It applies when Content personalization is not strictly necessary for service delivery; Service is likely to be accessed by children under 18; Service collects behavioral data; Behavioral data collection is not strictly necessary for service delivery. It does not apply where Profiling is permitted where it is in the best interests of the child (e.g., educational recommendations, safety filtering). (ICO AADC Guidance, Standard 8.3).
- From when does this apply?
- UK AADC Standard 8 - Data minimisation applies from 2 September 2021. Its current status is: in force.
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.