UK AADC Standard 2 — Data protection impact assessments: the conformance record (Steps 4 and 7) (ICO Age Appropriate Design C…
Maintain records showing how each AADC standard has been addressed
Where this comes from
Provision: Standard 2 — Data protection impact assessments: the conformance record (Steps 4 and 7) (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 2 — Data protection impact assessments, Step 4 (explain how you conform to each standard) and Step 7 (sign off, record and integrate outcomes); UK GDPR Art 5(2) accountability (not independently read)
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
Scope in the source's own terms
- Service is likely to be accessed by children
- 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:
- Register maps each standard/requirement to the design decisions that address it
- Each entry links its supporting risk assessments and records the residual risk accepted
- Register is versioned; changes are dated and attributable to an author
- Register names an owner and a review cadence (at least annual)
- Register is producible for the regulator on request
Evidence an auditor expects
- Audit reportDocument reviewRetain 6 years
AADC conformance self-assessment
Documented assessment showing how each of the 15 AADC standards has been addressed
- Process recordLog analysis
Conformance record update history
Version-controlled record of conformance assessments with change history
Questions people ask
- Does UK AADC Standard 2 — Data protection impact assessments: the conformance reco… apply to my service?
- It applies when Service is likely to be accessed by children under 18.
- From when does this apply?
- UK AADC Standard 2 — Data protection impact assessments: the conformance reco… applies from 2 September 2021. Its current status is: in force.
- What evidence does an auditor expect?
- AADC conformance self-assessment; Conformance record update history.
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.