Key legal considerations consent boxes cannot be used. under current UK and EEA law Publishers will need to consider how to achieve consent, particularly in Transparency games targeted at children who must It’s essential to be upfront with be above a particular age (13 in the players about what personal data UK and ranging from 13-16 across the is being collected, including data EEA) to give valid digital consent. In shared by the players themselves, order to ensure that the consent of and what it’s being used for, younger players is valid, it will also including whether it’s being shared be essential that publishers prepare with third parties or transferred out wording and consent requests in of the UK (or out of the EEA where age-appropriate language. applicable). UK data protection fee This is usually done in a privacy and cookies policy (see below). Most UK-based publishers will need to register annually with the Lawful basis and valid Information Commissioner’s Office player consent (ICO) and pay a registration fee of Each processing operation must be between GBP40-2,900. Failure to do underpinned by a permitted lawful so may result in fines. Currently only basis. Where publishers are relying on the UK has the obligation to pay a player consent to justify processing, fee, but EU countries may introduce there are strict requirements. similar requirements, so this is worth Under both the EU General Data checking. Protection Regulation (GDPR) and Transferring personal data the UK GDPR, consent must be outside the UK/EEA freely given, specific, informed, and an unambiguous indication of A publisher will need to take one of a the individual’s wishes. This means number of possible compliance steps (among other things) that pre-ticked to ensure personal data is protected 96