IAB UK responds to ICO’s proposed Age Appropriate Design Code

Read our response to the ICO's Age Appropriate Design Code consultation

IAB UK

IAB UK, the trade body for digital advertising, has responded to the Information Commissioner’s Age Appropriate Design Code consultation, outlining its concerns about the ability of the current proposal to achieve its goals and warning of significant collateral damage to ad funded internet content and services.

The IAB and its members want to ensure that children have a safe, informed and positive ad-funded experience online. Its response – which is available to view in full below – puts forward a comprehensive view on the proposed code and calls for further industry engagement and consultation in order to address the risks of significant unintended consequences that the code presents in its current form. The main issues IAB UK has urged the ICO to address are:

  • The code’s scope and ambiguity risks leaving it open to interpretation. The approach proposed – that it will apply to any site or service that is “likely” to be accessed by children – is too broad, covering all online content irrespective of whether it is aimed at children or not.

  • If sites and services have to age-gate their services to prove under-18s don’t use them, the effectiveness of the code in achieving its objectives will be hindered. What’s more, access to ad-funded internet services will be impacted – potentially creating a less open, more hierarchical web experience for users. The ICO needs to evaluate the impact on internet users – children and adults – and service providers that rely on advertising revenue to provide their content at little or no cost. 

  • Finally, the six-week time period provided by the ICO has been far too short for the industry to submit a full and considered response to the code, given the significance of the proposed changes. This is an important process that should not be rushed. IAB UK suggests that the ICO embarks on developing a ‘co-designed’ workable solution, created with the input of online service providers, in order to create a more risk-based, proportionate and achievable approach that helps ensure the code meets its objectives.

IAB UK are keen to work with the ICO on these issues to provide a workable and risk-based solution that effectively safeguards children online and complements the robust protections provided by existing regulatory and legislative frameworks, while also limiting the detrimental impact on the ad-funded internet services we all benefit from.

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