Age Appropriate Design Code: How stem4 supports and meets the standards of the Information Commissioner’s Code

It is now a legal requirement for organisations offering online services to comply with the ICO’s Age Appropriate Design Code (the Code).

It will affect any organisation delivering online services that are likely to be used by young people in the UK, though it is more focussed so far on companies working in social media, video or music streaming, gaming or education.

Making the online world safer and better for young people with the Age Appropriate Design Code

The Age Appropriate Design Code sets out 15 standards that aim to create a safe space for children to learn, explore and play online. It aims to empower children to be safe online by increasing their awareness of how their data is used, making language simpler and treating them fairly, whilst minimising data collection. By conforming to the Code, organisations are seen to be acting in the best interest of the young people who use their online services. The Code supports young people so that they can safely access digital services whilst minimising the collection and use of their data.

How stem4 makes sure you are supported as described in the Age Appropriate Design Code

As a young people’s mental health charity, our work is guided by a strategy to develop mental health support for young people, and those who care for them, by including young people in the design of the support at every stage.

Our resources foster the development of good mental health in young people through enhancing early understanding and awareness of good mental health in individuals, their families, schools and the community, promoting shared early detection and signposting towards prompt action and intervention.

This is primarily provided digitally through our innovative education programme, pioneering mental health apps, clinically-informed websites and mental health conferences that contribute to helping young people and those around them flourish.

stem4 has developed all of the support on what we know can improve mental health. stem4 also understands that it is important that any support offered is private, and that no data is collected that could identify a person. Respecting a young person’s right to privacy is core to everything that stem4 does. stem4 fully embraces ’Privacy by Design and By Default’.

stem4 strongly supports the Age Appropriate Design Code, because the Code can make it easier for young people to feel safer about getting mental health support online.

We are updating our Apps and resources to meet the Code’s standards.

Although there are 15 standards to protect the rights of young people online, we wanted to highlight a number of the standards to show how we embed the code in our work:

 

1. Best interests of the child: The best interests of the child should be a primary consideration when you design and develop online services likely to be accessed by a child

stem4 promotes the best interests of young people in two ways. Firstly, we use research insights on what helps young people be happier and healthier to design our resources. We then involve young people in the design process, and empower them to tell us if those insights need to be adapted to better support young people.

Secondly, stem4 works with experts as well as young people to ensure that our resources do not increase any risks that a young person may be facing with their mental health, and puts in place supports to reduce risks and prevent harms. This includes safeguarding, and no personal data is collected or shared that could lead to someone being identified or contacted. In this way, stem4 promotes what helps young people, but also tries to reduce any risks of harm.

2. Data protection impact assessments

All of our Apps undergo a Data Protection Impact Assessment to ensure that the Apps do not have a negative impact upon the rights and freedoms of children who are likely to use them. Should there be any risks, we put in place protections to reduce those risks, and ensure they are sensitive to the age of the young person who may use the Apps.

3. Age appropriate application

The stem4 Apps are recommended for a particular age-range, such as 12 years and older, and draw upon our understanding of how young people develop, what might be happening at that point in their life, what is important to them, and what knowledge and abilities they may have at that age. We do not check the age of the user, unless they wish to share that, as young people can vary in maturity, and our resources are developed with consideration of the youngest possible user, so that there is nothing that could be difficult for them.

4. Transparency

Our Apps give the user access to a Privacy Policy in two forms, one of which is in simpler language, to help the user easily understand what happens to their data.

5. Detrimental use of data

stem4 does not collect or share any personal data that could have a negative impact upon a young person.

6. Default settings

All the stem4 Apps are set to maximum privacy by default. In addition, users are encouraged to set up pass codes, so that no-one else can access their device or use of an App. If a young person is comfortable sharing some basic information about themselves (for example, their age, gender, ethnicity, and the country they live in) they can choose to share that, but that information does not allow anyone to identify them. There is also a ‘Skip’ button to make it easy for those who do not want to share this information to get full access to the support in the App quickly.

7. Data minimisation

We do not collect any personal information, and if a user wanted to share anything more about themselves, this is general, anonymous information that does not allow anyone to identify them personally.

8. Data sharing

We do not share any personal data with any third parties for advertising or other business activities, and any anonymised data on how young people use the Apps is only used by stem4 to improve the Apps, or inform health agencies who fund their free use by young people.

9. Geolocation

We do not track a user’s precise location, but may  ask what country a user is in when they start using an App, which allows us to give them information on local support if needed. We cannot check if what an individual user is sharing is correct.

We do make use of insights from Google Analytics 4. Google Analytics 4 collects data related to the device you are using, activities you undertake in the App, and your location, but does not log or store individual IP addresses, so we cannot know your exact location.

10. Profiling

stem4 does not profile the young people using the Apps, and the content within the Apps is only accessed if a young person wishes to see it. There are no algorithms that push content to a young person.

What stem4 will be doing next to ensure we continue to meet the standards of the Age Appropriate Design Code

stem4 has formed a Youth Advisory Group that we want to grow, so that a larger group of young people can be involved with co-design, and help us develop new resources, but also help us to improve our current resources.

We understand young people are passionate about mental health, and we will work to empower them, so that they can help us understand the needs of diverse groups of young people, and work with them to offer a greater choice of support.

We will work to understand better how young people want to be supported, and in what ways we can put into their hands the best support.

stem4 will undertake independent assessments (audits) of what we are doing in relation to the Age Appropriate Design Code, and ensure that all of our Apps and resources continue to protect and support the rights of young people.