Age Appropriate Design Code: How the Yoti app is complying with the ICO

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Following the end of its 12-month transitional period, it is now a legal requirement for businesses to comply with the ICO’s Age Appropriate Design Code (the Code).

It will affect any business operating online whose services are likely to be used by children in the UK, specifically in industries such as social media, video or music streaming, gaming or education. 


Providing safer environments for children in the digital economy with 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 data privacy awareness, making language simpler and treating them fairly, whilst minimising data collection. By conforming to the Code, businesses are deemed to be acting in the best interest of the children using their online services. Encouraging this default safety setting, children can safely access digital services whilst minimising the collection and use of their data. 


How we’re taking action in line with the Age Appropriate Design Code

As a company, our work is guided by an ethical framework, developed in line with the GDPR and key principles such as Privacy by Design. As such, we found a strong alignment with the Age Appropriate Design Code but we wanted to focus on two of the fifteen standards:

Best interests of the child: When you design and develop online services a child is likely to access, the best interests of the child should be a primary consideration.”​​

Transparency: The privacy information you provide to users, and other published terms, policies and community standards, must be concise, prominent and in clear language suited to the age of the child. Provide additional specific ‘bite-sized’ explanations about how you use personal data at the point that use is activated.”

So we started off with user research. We specifically wanted to see how well a group of teenagers understood our app, age estimation process, services, terms and privacy policy. 

This helped us pinpoint concepts that were difficult to understand, as well as how easy it was for our users to find information about how their data is used. Our findings encouraged us to change aspects of our app content, our communications and our privacy information.


Changing the content in our app based on the Age Appropriate Design Code

We are committed to making our app as easy to use as possible for people of all ages. We used the results from our user research to optimise important content to be certain that it would be widely understood.

We're committed to protecting your privacy screen

We made sure our titles provided greater context and included subtitles to make screens scannable. We explained in greater detail any words that might not be easily understood by younger people, like ‘encrypted’. In other cases, we avoided using words that could be considered too broad in a given context. For example, we no longer use the word ‘biometrics’ on our age-gating primer screen and instead swapped it out for the phrase ‘a scan of your face’. We also made sure to clarify why we needed certain information from our users.

We also improved usability by removing collapsed content so text was easier to read, and added a contact form on our data privacy screen, which we hope will reassure and encourage younger users to ask any questions they may have about how their personal data is being handled.


Communicating with our younger users by improving readability

Where comprehension is involved, it’s incredibly important that our younger users understand our services as best they can. To do that, we need to make sure our wording is easy to read. We used a number of readability tools to help the editing process. Hemingway helped us to pinpoint the key areas of improvement.

Before edits

faq pre-edit at a readability of grade 9

After edits

Once we made the edits, we ran our new and improved content through Story Toolz to see how much easier our content was to read using seven different readability indices. We made sure that in as many circumstances as possible we were improving the way our services could be understood by young people.



If we want children to understand how they can use the app, it’s important that our FAQs are approachable and accessible. We hope that by doing this, we become as transparent as possible in line with the Age Appropriate Design Code’s fourth standard

On average, we improved the readability of our FAQs by two school years by using less words and using simpler alternatives to complex terms. We hope that children will feel more comfortable navigating our app when they have questions about how to use it.


Customer Service Emails

We made our email templates even easier to read, all of which now have a readability grade of 5 or below. That’s a reading age of 10 years old.


Making our privacy information easier to understand

Bite-size summaries

We’ve added bite-sized summaries to sections of our key privacy and terms documents. We initially thought about calling these blue boxes, but quickly realised this wouldn’t be accessible to people with visual impairments. Instead, we decided to include an information icon and refer to the summaries as information boxes.

app terms and conditions screen


We have added a section on definitions that explains frequently used key terms in our privacy information, such as “third parties” and “biometrics”.


Privacy notice for children and young adults

We’ve written a simplified privacy policy for children and young adults. Rather than add a definitions section, we decided to find alternative words altogether and write a summary with the key information about how we do privacy at Yoti. 

This is not a substitute for our detailed privacy policy but it allows users to understand privacy in a more simplistic way. We’re also designing a new structure for our privacy pages to make them easier to navigate. There’s a fixed sub menu that shows an overview of all sub-pages and we clearly signpost to key pages based on whether you’re an end user, corporate client or young adult.


Our products evolve with child safety requirements

The efforts don’t stop there. We hope to continually improve our services for children over the coming months and years. Since reviewing our existing app onboarding and other flows, we are planning to make some changes which will be included in our next few releases. So watch this space.

While we continue to act in the interest of our users, we encourage all businesses that are affected by the Code to act with us and create safer spaces for children. If you would like to find out how we can help you and your business to comply with the Age Appropriate Design Code, get in touch with us today.