Children's Code assessment

Last updated: 27 September 2026

MyCloseKin LTD's assessment of CloseKin Play against the ICO Age Appropriate Design Code. Owner: MyCloseKin LTD directors. Next review: September 2027, or sooner if the service changes.

Standard	Status	How Play meets it	To do
1. Best interests of the child	Applies	Play is designed for connection between a child and a trusted adult. No ads, no social features, no in-game purchases aimed at children. Cards are age-banded and reviewed for suitability.	Review card library annually.
2. Data protection impact assessment	Applies	This assessment, the data map and lawful-basis record together form our DPIA. Risk is low: minimal child data, device-only storage.	Formal DPIA sign-off before launch.
3. Age-appropriate application	Applies	All children receive the same high-privacy settings regardless of age. Age band is chosen by the parent only to pick suitable cards.	None.
4. Transparency	Applies	A child-friendly Kids' Privacy page plus a full Privacy Notice for adults, linked from setup and settings.	None.
5. Detrimental use of data	Applies	No streaks, timers, rewards for extended play or pressure to return. Journey progress only marks completed adventures.	None.
6. Policies and community standards	Applies	Terms and Terms for Parents are published and followed.	None.
7. Default settings	Applies	Highest privacy by default: no analytics, no sharing, no cloud copy of child data.	None.
8. Data minimisation	Applies	We collect only nickname, avatar, age band and progress. Conversation answers are never recorded.	None.
9. Data sharing	Applies	Child data is not shared with anyone. Paddle only receives the adult's payment details.	None.
10. Geolocation	Applies	No location data is collected.	None.
11. Parental controls	Applies	The parent creates, edits and deletes all profiles. Children are not monitored — no conversation content exists to monitor.	None.
12. Profiling	Applies	No profiling. Card selection uses only age band and cards already seen.	None.
13. Nudge techniques	Applies	No dark patterns. Upgrade prompts are shown to the adult account holder, not framed at children.	Keep upgrade screens adult-facing.
14. Connected toys and devices	Does not apply	Play is a web app with no connected toy or device.	None.
15. Online tools	Applies	Parents can delete all family data in Settings and request account deletion at any time.	Add self-serve account deletion.

Key principles in detail

Best interests: the service exists to help families talk. Nothing is monetised from children's attention or data.

Data minimisation: the most sensitive thing in the game — what a child says — is never captured.

Privacy by default: there are no optional settings that reduce privacy.

Transparency: privacy information is given in plain words for children and full detail for parents.

Age-appropriate design: cards are grouped by age band, with large text, simple choices and play always alongside a grown-up.

This assessment is an internal record prepared following ICO guidance and is not legal advice.