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This briefing will compare the draft "Fundamentals for a
child oriented approach to data processing" (the
"
Fundamentals") recently released by the
Data Protection Commission of Ireland (the
"
DPC") with the Age Appropriate Design
Code (the "
AADC") produced by the
Information Commissioner's Office in the UK (the
"
ICO"). The AADC was adopted in
September 2020 and organisations have until 2 September 2021 to
comply. See our briefing on the Fundamentals
here.
The Fundamentals apply to both online and offline services that
are directed at / intended to be accessed by children. The