UK AADC Standard 10 — Geolocation (ICO Age Appropriate Design Code, statutory guidance under DPA 2018 s 123)
Disable geolocation by default; show active-tracking indicator; hide location from public
Where this comes from
Provision: Standard 10 — Geolocation (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 10 — Geolocation
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
- Data categories collected includes Location / Address
…unless:
- Geolocation needed to provide the core service (the code's example: a map service that must know the user's location to display the map or give directions) needs no privacy setting; any geolocation beyond the core service does. (ICO AADC Standard 10 - core service)
Scope in the source's own terms
- Service has geolocation features accessible to children
- Service collects or uses location 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:
- Default profile visibility: private (not public)
- Default data sharing: off (opt-in, not opt-out)
- Default location tracking: off
- Default contact discoverability: off
- User can change any default via settings
Evidence an auditor expects
- Technical controlTechnical audit
Geolocation default-off configuration
Technical evidence showing location tracking disabled by default for child users
- User-interface evidenceUser testing
Active tracking indicator
Screenshots showing visible indicator when location tracking is active
- Technical controlTechnical audit
Location visibility restrictions
Configuration showing child location data is not visible to other users by default
Questions people ask
- Does UK AADC Standard 10 — Geolocation (ICO Age Appropriate Design Code, statutory… apply to my service?
- It applies when Service is likely to be accessed by children under 18; Data categories collected includes Location / Address. It does not apply where Geolocation needed to provide the core service (the code's example: a map service that must know the user's location to display the map or give directions) needs no privacy setting; any geolocation beyond the core service does. (ICO AADC Standard 10 - core service).
- From when does this apply?
- UK AADC Standard 10 — Geolocation (ICO Age Appropriate Design Code, statutory… applies from 2 September 2021. Its current status is: in force.
- What evidence does an auditor expect?
- Geolocation default-off configuration; Active tracking indicator; Location visibility restrictions.
Find out whether this one lands on you
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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.