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ARTICLE · 23 MARCH 2023

ICO's Top Tips For Game Designers

Shepherd and Wedderburn
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To assist developers, the ICO separates its suggestions into those that game developers "should" follow and those that they "could" follow.

United KingdomPrivacy
Joseph Fitzgibbon
Joseph Fitzgibbon
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The Information Commissioner's Office (ICO) recently published new guidance to game developers and designers to assist them in complying with the Children's Code. The guidance, described as "Top tips for game designers", follows several audits of the gaming industry carried out by the ICO, and is intended to build upon the standards imposed within the Children's Code.

What is the Guidance?

To assist developers, the ICO separates its suggestions into those that game developers "should" follow and those that they "could" follow.

The guidance suggests that developers "should":

  1. Risk Assess: Developers are encouraged to put in place processes to help them identify and minimise data protection risks within games. Early in the process this may involve consulting with external stakeholders, including children, to carry out risk assessments. Where games are to involve randomised rewards, such as loot boxes, these rewards should be risk assessed against the

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