CONSULTATION RESPONSE: AGE APPROPRIATE DESIGN CODE
The Information Commissioners Office has asked for evidence and views on the Age Appropriate Design Code. This code will provide guidance on how online companies should design their services if they’re likely to be accessed by children.
Through our work delivering peer-led training programmes at The Diana Award, we have empowered tens of thousands of young people with the skills, confidence and knowledge to change the culture and attitudes around bullying on and offline. We equip them with the necessary tools to promote online safety and digital resilience to their peers and to tackle the online issues that matter most to them.
For a number of years we’ve worked closely with tech companies to amplify the voices of young people in debates around online safety. We work closely with a number of social media platforms, telcos and online gaming companies to ensure that young people are central to shaping their safety policies and developing new interventions.
Increasingly our work focuses on how young people live their lives online and how they can balance the positive opportunities afforded by the digital world with an appreciation and understanding of the risks. Online privacy is a complex area for children and young people to navigate and whilst education programmes have a crucial role to play, there are undoubtedly improvements that need to be made. Privacy and safety by design must be embedded into online services and products that children and young people are likely to access.
“The child is a user who enjoys, experiences, consumes, interprets and plays. Secondly, the child is an expresser who draws, depicts, presents and writes. Furthermore, the child is a participant who operates and influences. And what is important, the child is the person in need of media protection.” National Anti-Bullying Youth Board Member, 14
There have been shifts towards privacy by design for young people with a number of social media sites in recent years. For instance Facebook sets default privacy settings as standard for users between the ages of 13-18.
Positive progress has been made within the wider sector to develop guidance for ISS providers and make recommendations on many of these aspects of design. For instance, The Diana Award is a member of the UK Council for Child Internet Safety (UKCCIS) which has published a number of good practice recommendations for industry .
However ISS providers can and should go further in design features to safeguard underage users. Members of our National Anti-Bullying Youth Board made the following recommendations for design features to assist in the safeguarding of children:
“Add a ’report abuse’ button to everything, meaning offensive comments can be flagged to moderators easily
Having higher privacy settings when you first join apps e.g. Snap Maps turned off
Automatically set accounts to private when you first join
Don't allow people that are not friends to direct message the person
Employ specially trained child and adolescent moderators to monitor use of social media more closely
Add links to supportive agencies/helplines within their geographical location
Strict privacy settings [for younger users] should be set by default”
National Anti-Bullying Youth Board Members, 14 and 15
We have outlined a number of further recommendations and points to consider when it comes to deciding on the scope and meaning of the terms listed in the Code. To read our full submission, click here.