Ahead of the game

How Hatch Kids takes UK’s “Children’s Code” regulations in consideration

Since last week, a new Age Appropriate Design Code, known as the “Children’s Code”, was issued in the UK for all apps and other digital media accessed by children. The code is a set of design standards that ensure well designed services that are safe for children to use. Companies have 12 months to comply with the new code – and the great news is that Hatch Kids is already compliant! 

When reading about the reasons behind issuing this code, the UK’s Information Commissioner’s Office ICO points out that the new regulations aren’t there to protect or shield children from the digital world, but instead to offer a set of standards that ensure that children can use digital media in a safe way. As they put it, to provide “a safe space for them to learn, explore and play” – something we tend to say ourselves at Hatch Kids! 

ICO further explains that 1 in 5 internet users in the UK are children, and some of the biggest data protection concerns are about children’s privacy topics. When the United Nations Convention on the Rights of the Child talks about children’s needs of safety, it needs to extend to safety also in data protection. The UK is taking the first step introducing child specific safeguards and code of practise. As ICO puts it, the code “requires information society services to put the best interests of the child first when they are designing and developing apps, games, connected toys and websites” for kids. Just like using a safety belt in a car to keep children safe, digital apps should be designed safe for kids.

Hatch Kids is a Finnish publisher of children’s game platform for learning, exploring and playing. Already in our first design phase we took a similar ethos of making sure Hatch Kids is built for kids from 2 to 8 years old. We wanted to make sure we could support their development in a healthy way, providing them a safe space to enjoy the best of digital games and toys available. This also meant that we wanted to keep the service straightforward and minimal – we stream games from the cloud to avoid downloading one heavy app on a device, and make it safe – we don’t offer chat options or other routes for non-family members to access the user data, and there isn’t a chance for encounters with unsuitable content such as 3rd party ads. Our parental controls and family profiles are already available, and being further developed as we speak. 

We’re happy to see the UK going ahead with similar principles that have inspired us when designing Hatch Kids. Children’s Code is mainly about designing for kids and it’s quite inspirational. Here are some of our thoughts on the 15 standards of age appropriate design:

  1. Best interests of the child – support the rights of children.
    At Hatch Kids, we have designed the service in consideration of the users age and developmental stages. When it comes to the UX, the user experience design, we have conducted user tests with various families and kids of different ages in order to understand how they use digital devices. Some of these learnings were introduced as updates to the UX to support gaming ergonomics. We source games that support wellbeing and health, curiosity and emotional development. We empower both the kids and parents with different tools and overview on progress, and allow space for both learning and free play. 

  1. Data protection impact assessments – assess and mitigate risks.
    We are GDPR compliant and do not collect profiling or biometric data. Hatch Kids is a safe space to play without advertisements, which means there is no risk to come access harmful materials. 

  1. Age appropriate application – age groups and suitable content.
    Hatch Kids is designed for 1-8 years. In ICO’s age ranges this means 0-5 year old pre-literate and early literacy and 6-9 year old core primary school years. We categorize our age ranges as toddlers, juniors and champions based on their age and level of challenge in games and learning. We follow Finland’s early childhood education curriculum in our age appropriate content recommendations.

  1. Transparency – how we communicate with you.
    ICO recommends that personal data information should be easy to access and read. Our privacy policy can be found here and our customer support can help with any questions through the app.
    When designing Hatch Kids for kids, we have taken in consideration that not all of our users know how to read, so most information is presented as graphics and audio prompts. Only parents are able to change important settings and sign up for the subscription through parental controls that are behind a mathematical puzzle lock.

  2. Detrimental use of data – supporting kids welfare and industry standards
    Our content as games and digital toys do not contain anything harmful and are kid friendly. Our service is based on a monthly subscription, marketed towards the parents which means there are no ads or in app purchases, paid product placements or other advertising related content. The subscription purchase options are behind the parental controls. We do not use personal data, psychological blackmailing or personalized rewards to incentivise gameplay. All games have a back button available all times which means children can leave the game at any time without losing their game progress. We are also compliant with Ofcom’s code practise for the protection of under 18s. 

  1. Policies and community standards – keeping to our own standards.
    We want to be worth your trust. We are also committed to keeping our word on our privacy policy through our distribution partners at Google Play and Apple Appstore which also require strict policies when it comes to apps for children. 

  1. Default settings – by default, you are safe.
    Your privacy is important by default. If in the future you want to sign up for any additional services such as customised learning reports, it’s an additional step offered in the parental controls. 

  1. Data minimisation – only minimum amount of personal data.
    If we need some data from you, it’s only the least amount and for the minimum amount of time we might need it for such as age level recommended games. 

  1. Data sharing – we don’t share data.
    We do not share personal data with third parties. You as a parent are the only one able to access the child profile’s data. 

  1. Geolocation – no need to know your exact location.
    Hatch Kids does not access GPS or your exact geolocation, but we use your IP address for general location data. This we do not share with anyone else. Our own service does a check on the device if it’s using WIFI or cellular connection in order to stream the game content from our cloud servers. Our customer support system checks on network provider and country level location in order to provide localised and better customer service. 

  1. Parental controls – tools for the guardians.
    Hatch Kids settings are behind a parental lock, a tricky math question that adults should be able to solve. This is the place to subscribe for the service, ask questions from the customer support team, change your email address or delete your account. 

  1. Profiling – based on age appropriate and suitable content recommendations.
    Parents are able to create specific profiles for their kids based on age range. Our profiling practices are benign, for example we recommend games based on previously played games or games that fit the age range suggested curriculum. The profiling is never shared with third parties.

  1. Nudge techniques – fair design for children.
    Our design isn’t meant to encourage kids to provide unnecessary personal data. When possible, we try to nudge towards the positive decisions such as high privacy and parental controls and promoting health and taking breaks.

  1. Connected toys and devices – we do not provide additional devices.

  1. Online tools – access your data.
    You can find further instructions on requesting your data here.

We’re excited to see ICO’s code going ahead and inspired to do even better when it comes to our design work and communication transparency.

You can read more about the new Children’s code on ICO’s website:


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