UK AADC Standard 12 — Profiling (ICO Age Appropriate Design Code, statutory guidance under DPA 2018 s 123)
Disable profiling by default; only permit with harm-protection measures in place
Where this comes from
Provision: Standard 12 — Profiling (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 12 — Profiling
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:
- The code's examples of profiling that may be on by default: accessibility features for a disabled child, and editorially controlled news feeds. 'Educational benefit' is not among them. (ICO AADC Standard 12 - compelling reason for profiling on by default)
- Profiling required by a legal or regulatory requirement (such as safeguarding), for preventing child sexual exploitation and abuse, or for age assurance under Standard 3 does not need a privacy setting. (ICO AADC Standard 12 - profiling without a setting)
What engineering work it implies
Sample acceptance criteria Landfall generates for this obligation:
- User model has `profilingEnabled` boolean field (default: false)
- Recommendation engine checks profilingEnabled before processing user
- Behavioral tracking skips users with profilingEnabled=false
- Ad targeting excludes users with profilingEnabled=false
- Admin dashboard shows count of users with profiling disabled
Questions people ask
- Does UK AADC Standard 12 — Profiling (ICO Age Appropriate Design Code, statutory g… 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 The code's examples of profiling that may be on by default: accessibility features for a disabled child, and editorially controlled news feeds. 'Educational benefit' is not among them. (ICO AADC Standard 12 - compelling reason for profiling on by default).
- From when does this apply?
- UK AADC Standard 12 — Profiling (ICO Age Appropriate Design Code, statutory g… 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.