![]() Developers should consider whether their approach to the design, monetisation and promotion of games would benefit from any changes in light of the latest guidance. The new guidance is a reminder for video game developers of the particular considerations that apply when developing not only games that are specifically designed for and marketed to children but all games which might appeal to children. The ICO is offering developers an opportunity to volunteer for an audit to assess their privacy practices and compliance with the guidance, which has been well received in other sectors in the past (e.g. Leanne Doherty of the ICO has acknowledged that “ Gaming plays a central part in so many young people’s lives, and the community and interaction around games can be a child’s first steps into the digital world…The Children’s Code makes clear that children are not like adults online, and their data needs greater protection.” The above reflects the desire for the ICO to prevent children from being pressured to supply too much personal data and to prevent game developers from using children’s personal data in a detrimental manner. The FTC sued to block the acquisition in December 2022, choosing to bring the case before its internal administrative law judge. Instead, ensure nudge techniques are designed to benefit children – for example, by encouraging high privacy settings. time-limited offers, “one-time-only” offers and communications via social media which might encourage young children to set up a social media account).
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