UK AADC Standard 5 — Detrimental use of data (ICO Age Appropriate Design Code, statutory guidance under DPA 2018 s 123)
Prohibit use of children's data in ways detrimental to their wellbeing
Where this comes from
Provision: Standard 5 — Detrimental use of data (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 5 — Detrimental use of data; read with UK GDPR Art 5(1)(a) and Recitals 2, 38, 75 (referenced in ICO guidance, not independently verified against the GDPR text in this unit)
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
What engineering work it implies
Sample acceptance criteria Landfall generates for this obligation:
- Implementation or documented process meets the reviewed acceptance criteria; identify the tested version and deployment status separately
- Configure defaults from the assessed source and purpose; do not enable data collection or processing merely because this task exists
- Validate behavior for the assessed actors and use cases, including applicable guest or administrator paths
- UI clearly communicates what the feature does to users
- API returns appropriate error codes when feature blocks an action
Questions people ask
- Does UK AADC Standard 5 — Detrimental use of data (ICO Age Appropriate Design Code… apply to my service?
- It applies when Service is likely to be accessed by children under 18; Service collects behavioral data.
- From when does this apply?
- UK AADC Standard 5 — Detrimental use of data (ICO Age Appropriate Design Code… 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.