The final version of the ICO’s Age Appropriate Design Code was published earlier this year. It needs to be approved by Parliament, and there will then be a 12 month period before it comes into force. The ICO expects the Code to be in force by autumn 2021.

Although this may sound like a long time away, to comply with the Code existing services will need to be reviewed and where necessary updated, and changes to design processes for new services will likely be required. It is therefore important to start thinking now about how the Code may apply.

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Ben advises clients in a wide range of industry sectors, focusing in particular on data protection compliance, including healthcare, financial services, adtech, video games, consumer and business-to-business organisations. Ben regularly assists clients with global data protection compliance projects and assessments as well as specific data protection challenges such as international transfers and data security breaches. Ben is also regularly involved in drafting and negotiating data protection clauses in agreements for various clients in a wide range of industry sectors. Ben also regularly advises clients on electronic direct marketing and cookies.

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