Dealing with gamers Data children’s data since the launch of of those games designed for an older the Children’s Code and it sits firmly customer base, most will still have alongside other child and consumer some appeal to older children. protection measures in the UK. Gaming providers with online services The restriction of the application of which do not, or cannot, adopt a zero the Children’s Code to information data approach, will need to work society services is particularly out what age range to pitch to. This important for the game industry, impacts not only the policies and because it will apply to some but privacy notices but also the design not all forms of gaming. Information and functionality of whole platforms, society services are those normally sites, apps and games. provided for remuneration at a The Children’s Code does not require distance by electronic means at the a one-size fits all approach and the individual request of the recipient amount and nature of work required of the services. This means that the to process the data of young scope of the Children’s Code extends children differs significantly from to online and connected gaming but what’s needed to engage with older not generally offline gaming using teenagers. Structuring sites so that consoles at home and downloaded different age groups have a different games where no internet connection experience is an option, but this is required to play. may require significant profiling and For many businesses, the efforts additional data processing, which required to meet the Children’s causes its own privacy challenges. Code’s requirements will be minimal, If a one-size fits all approach is but for others it will be a significant preferred, the needs of younger users challenge – particularly for those will have to take precedence. Some which offer services that aren’t operators may take the chance of designed for children but are still non-compliance rather than aiming likely to be accessed by them. to meet the needs of the youngest Online gaming products are often users, but this is a high-risk strategy. designed to appeal to under-18s and, 99