Following the introduction earlier this year of the Online Safety Bill, designed to ensure the safety of the UK’s internet users, a recent Dispatches documentary aired on Channel 4, has uncovered a world of considerations not just for the tech giants, but for parents, educators, government and regulators alike. The team here at Nticipate works within a solid framework of legislation to ensure our clients remain compliant and go about their business in a structured and regulated process. But what happens when regulation struggles to identify the perpetrators of data misuse? This documentary highlights the frightening realities of the digital universe.

The Online Safety Bill has been introduced with the intention to ensure that the UK’s internet users can “have a new, safer digital experience, one that protects children from harmful content, limits people’s exposure to illegal content, while still protecting freedom of speech.’ However, the rapid growth of immersive digital experiences, such as augmented and virtual reality, is beginning to highlight where the gaps remain in the race to protect those – specifically children – when interacting in this online universe.

As an independent regulatory body, it is interesting to see how the Information Commissioner’s Office (“ICO”) has a set out in its Children’s Code, standards of practice that provide ‘built-in’ protection for children when gaming, exploring or using educational Apps and online services. One of the objectives of the code is to minimise the personal data collected, used, retained and shared. It also addresses issues associated with parental control and profiling. However, as the C4 documentary demonstrated, these codes and bills are only effective when stringently monitored, enforced with meaningful penalties for those who do not comply and supported by a network of responsible parties.

The ICO sets out 15 clear standards for providers of information society services (including all Apps, programs, games, websites communities/chat rooms, and connected toys or devices) to meet in order to ensure compliance of GDPR and data protection within the design process (you can read more about the Children’s Code here It is designed to safeguard and protect children whilst they are active ‘within’ the digital world.

Importantly, children are unlikely to understand the risks associated with the processing of their personal data. They will not necessarily understand the connection between their online actions and the subsequent content they are exposed to, be that simple marketing of additional digital assets or something much darker.

Is this where we need to emphasise to parents and educators that the role of responsibility is a shared one? Tech giants will all argue that they are putting measures in place to protect children, tools to prevent harassment and abuse. And, in theory they are. There are options for children to block other users, report abuse and choose just who they see and who can see them. But realistically, how a child is allowed to participate in digital worlds will fall to the parent. Parental controls are there for a reason, for a rational, educated mind to ensure the protection at App/game/website level are in place to safeguard their child.

Regulation can do so much, but some simple measures can be very effective in the protection of children and online data misuse; it’s a culture of safety and responsibility that needs much more open discussion at home, within classrooms and most certainly as an ongoing governmental concern. Let’s all play our role in shaping the safety of future generations and the digital world they will grow up in. It’s a fast-paced growth industry that shows no signs of slowing. Education is key. Understanding the game is everything.


Useful links:



Government Policy paper



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