UK AADC Standard 9 — Data sharing (ICO Age Appropriate Design Code, statutory guidance under DPA 2018 s 123)
Prohibit disclosure of children's data without a compelling best-interests reason
Where this comes from
Provision: Standard 9 — Data sharing (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 9 — Data sharing
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
…unless:
- The code's examples of a compelling reason to share: safeguarding purposes, preventing child sexual exploitation and abuse online, or preventing or detecting crimes against children such as online grooming. (ICO AADC Standard 9 - compelling reason)
- Disclosure required by law, a court order or a competent authority is a purpose of its own; the code's best-interests test still frames how it is done. (Disclosure required by law (UK GDPR Art 6(1)(c); not independently read))
Scope in the source's own terms
- Service shares or discloses children's data
- 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:
- Data sharing is OFF by default for all users
- Third-party integrations cannot access user data without explicit toggle
- Admin approval workflow for any bulk data export
- Data sharing settings visible in user privacy dashboard
- API blocks external data requests unless sharing is enabled
Evidence an auditor expects
- Policy documentDocument review
Data sharing policy for children's data
Policy documenting all third parties receiving children's data and lawful basis
- Contractual documentDocument review
Data processing agreements with recipients
DPAs with all third parties receiving children's data
Questions people ask
- Does UK AADC Standard 9 — Data sharing (ICO Age Appropriate Design Code, statutory… apply to my service?
- It applies when Service is likely to be accessed by children under 18; Service collects behavioral data. It does not apply where The code's examples of a compelling reason to share: safeguarding purposes, preventing child sexual exploitation and abuse online, or preventing or detecting crimes against children such as online grooming. (ICO AADC Standard 9 - compelling reason).
- From when does this apply?
- UK AADC Standard 9 — Data sharing (ICO Age Appropriate Design Code, statutory… applies from 2 September 2021. Its current status is: in force.
- What evidence does an auditor expect?
- Data sharing policy for children's data; Data processing agreements with recipients.
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.