UK AADC Standard 9 - Data sharing
Prohibit disclosure of children's data without a compelling best-interests reason
Where this comes from
Provision: Standard 9 - Data sharing
Instrument: UK Age Appropriate Design Code
Citation: Information Commissioner's Office, Age Appropriate Design: a code of practice for online services, Standard 9
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
- Service collects behavioral data
…unless:
- Disclosure required by law enforcement, court order, or child safeguarding authorities. (Legal disclosure obligations)
- Disclosure to protect the vital interests of the child (e.g., emergency services, safeguarding referrals). (ICO AADC Standard 9)
Scope in the source's own terms
- Service shares or discloses children's data
- 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:
- Data sharing is OFF by default for all users
- Third-party integrations cannot access user data without explicit toggle
- Admin approval workflow for any bulk data export
- Data sharing settings visible in user privacy dashboard
- API blocks external data requests unless sharing is enabled
Evidence an auditor expects
- Policy documentDocument review
Data sharing policy for children's data
Policy documenting all third parties receiving children's data and lawful basis
- Contractual documentDocument review
Data processing agreements with recipients
DPAs with all third parties receiving children's data
Questions people ask
- Does UK AADC Standard 9 - Data sharing 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 Disclosure required by law enforcement, court order, or child safeguarding authorities. (Legal disclosure obligations).
- From when does this apply?
- UK AADC Standard 9 - Data sharing applies from 2 September 2021. Its current status is: in force.
- What evidence does an auditor expect?
- Data sharing policy for children's data; Data processing agreements with recipients.
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.