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
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.
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
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.