Assume the children are there, and design as though they are.
The ICO’s Age Appropriate Design Code applies to any information society service likely to be accessed by children. A farming game attached to a family television programme is not a borderline case, and the correct posture is to assume a substantial child audience from the first design document rather than to discover one after launch.
What a real version would have to hold before it launched.
Eight obligations, every one of them marked due, because none of them exists — there is no game and therefore nothing has been assessed.
A register that shows only green is not a register. These are all outstanding and the page says so.
The standards that bite hardest on this design.
The ones that shaped mechanics
- Data minimisation
- No location, no birth date, no behavioural profileThe weather comes from one Oxfordshire station for everybody, which removes the location question entirely.
- High privacy by default
- Sharing off, discoverability off, at first runAnd for a child account, reel sharing cannot be turned on at all.
- Nudge techniques
- No streaks, no expiring offers, no win-back messagesWhich removes the three most effective retention mechanics in mobile gaming.
- Detrimental use of data
- No engagement optimisation against a child’s play patternThe design holds no play pattern to optimise against.
- Profiling
- Off, and not implementedThere is no segmentation, no personalisation and no targeted offer anywhere in the design.
The ones that shaped process
- DPIA
- Mandatory before launchAnd again before any significant change. It is the document that would kill most versions of this idea, and it should.
- Age assurance
- Proportionate to riskEstablished at the first age-gated feature rather than at the door, because a hard gate at the door collects more data, not less.
- Transparency
- Privacy information a child can readNot a link to an adult policy, which is the commonest failure.
- Governance
- A named person accountableThe same rule this site applies to the chapter ledger, for the same reason.
The exposure
- Maximum penalty
- £17.5 million, or 4% of global annual turnoverWhichever is higher. Set against an estate turning over tens of millions, that is not an abstraction.
- Enforcement history
- The ICO has taken action on children’s dataAnd has been explicit that games and social products are a priority area.
- The commercial reading
- The compliant design is also the cheaper designNo profiling stack, no segmentation, no personalisation engine and no retention team building streaks.
Why a DPIA before launch is the discipline rather than the paperwork.
A Data Protection Impact Assessment requires a description of the processing, an assessment of its necessity and proportionality, an assessment of the risks to the people affected, and the measures taken to address them. It is mandatory here, before launch, and again before any significant change.
The reason it matters is not that it is required. It is that a team which cannot write one has not understood its own product. If you cannot describe what you collect, why you need it and what happens if it leaks, you should not be shipping a service that children will use.
It is also the document that would stop the worst version of this game from being built. Almost every mechanic this design has refused — the streak, the expiring offer, the loot box, the behavioural profile, the win-back message — would have to be described, justified and risk-assessed in writing, against a child audience, by somebody who would then have to sign it.
What the design removed because of the code.
| Mechanic | Standard in the category | Here |
|---|---|---|
| Daily login streak | Almost universal | Absent. It is a nudge technique with a counter on it |
| Expiring first-purchase offer | Almost universal | Absent. No offer at all during onboarding |
| Win-back notification | Universal | Absent. No message is ever sent about not playing |
| Loot boxes | Common | Absent, and the economy page sets out the full reasoning |
| Behavioural segmentation | Universal | Absent. No profile is held, so none can be segmented |
| Precise geolocation | Common, for events | Never collected. Everybody plays one Oxfordshire weather feed |
| Free-text chat | Common | Absent. Every player interaction is a structured action |
| Friend-activity notifications | Universal | Off by default, and never a push |
This is not legal advice
It is a plain-English account of a published statutory code, written by somebody with no standing to advise anybody. Any real version of this would take proper advice, appoint a data protection officer and complete a DPIA before a line of code was written, and the outcome might be that the game should not be built at all.
Children, questioned.
Yes. The test is whether the service is likely to be accessed by children, not whether it is aimed at them. A farming game from a family television programme is not a borderline case.
Up to £17.5 million or four per cent of global annual turnover, whichever is higher. Against an estate of this size that is a material number rather than a theoretical one.
Before launch, and again before any significant change. Not as a formality afterwards, which is how most of them get done and why most of them are worthless.
And finally, the word itself.
Why the game is called Farming, and why nothing else could be.
