Privacy & Information Security Law Blog

On April 3, 2024, the UK Information Commissioner’s Office (“UK ICO”) published its 2024-2025 priorities for protecting children’s personal data online, titled the “Children’s Code Strategy” (the “Strategy”).  The Strategy builds on the UK ICO Children’s Code, introduced in 2021, and sets forth priority areas of improvement for social media and video-sharing platforms, and indicates how the UK ICO will continue to enforce and drive conformance with the Children’s Code.  The UK ICO, through the Strategy, will focus on the following with respect to social media and video-sharing platforms: (1) default privacy and geolocation settings (children’s profiles should be set as private by default and geolocation settings should be disabled by default); (2) profiling children for targeted advertising purposes (profiling generally should be disabled by default); (3) using children’s information in recommender systems (focusing on the potential harms to children posed by algorithmically generated content feeds, such as exposing children to harmful content; encouraging children to spend additional time on a platform; and encouraging children to provide platforms with additional personal information); and (4) using information of children under 13 years old (focusing on how services can obtain parental consent and use age assurance technologies).

To operationalize the Strategy, the UK ICO will publish a call for evidence in summer 2024 to invite input from a range of stakeholders, identify key social media and video sharing platforms, engage with stakeholders (including parents, children, and relevant children’s organizations) and use the agency’s regulatory enforcement powers to ensure compliance.