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UK AADC · UK-AADC-STD-08-RETENTION

UK AADC Standard 8 — Data minimisation: retention (ICO Age Appropriate Design Code, statutory guidance under DPA 2018 s 123)

Delete children's data when no longer needed; automate retention schedules

HIGHRecommendationData processingRegulatory guidanceIn forceApplies from 2 September 2021

Where this comes from

Provision: Standard 8 — Data minimisation: retention (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; general storage-limitation principle referenced by ICO's Standard 8 guidance, itself derived from UK GDPR Art 5(1)(e) (not independently re-verified against the GDPR text in this unit)

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.

Read the official text ↗

Who it applies to

It applies when all of these are true:

  • Service is likely to be accessed by children under 18
  • Service collects behavioral data

…unless:

  • Retention required by a legal obligation is a purpose of its own under UK GDPR, so data may be kept for as long as that obligation requires. The former 'child safety purposes' row was not a recognised carve-out from storage limitation and is removed. (UK GDPR Art 5(1)(e) and Art 6(1)(c) (not in Standard 8; not independently read))

Scope in the source's own terms

  • Service stores personal data of 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:

  • Retention schedule exists per data category and is enforced automatically
  • Expired data is deleted or anonymized across primary and backup stores
  • Children's data retention is minimized and periodically reviewed
  • A record past its retention window is removed by the scheduled job
  • Deletion propagates to secondary stores/backups within the required window

Evidence an auditor expects

  • Policy documentDocument review

    Data retention schedule for children's data

    Documented retention periods for each data type collected from children

  • Technical controlTechnical audit

    Automated deletion implementation

    Technical evidence of automated data deletion processes

  • Process recordLog analysis

    Deletion logs

    Records showing data deletion in accordance with retention schedule

Questions people ask

Does UK AADC Standard 8 — Data minimisation: retention (ICO Age Appropriate Design… apply to my service?
It applies when Service is likely to be accessed by children under 18; Service collects behavioral data. It does not apply where Retention required by a legal obligation is a purpose of its own under UK GDPR, so data may be kept for as long as that obligation requires. The former 'child safety purposes' row was not a recognised carve-out from storage limitation and is removed. (UK GDPR Art 5(1)(e) and Art 6(1)(c) (not in Standard 8; not independently read)).
From when does this apply?
UK AADC Standard 8 — Data minimisation: retention (ICO Age Appropriate Design… applies from 2 September 2021. Its current status is: in force.
What evidence does an auditor expect?
Data retention schedule for children's data; Automated deletion implementation; Deletion logs.

Find out whether this one lands on you

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