Our compliance with the Children’s Code
How Developing Experts ensures it complies with the Children’s Code:
Best interests of the child: The best interests of the child should be a primary consideration when you design and develop online services likely to be accessed by a child.
Developing Experts provides signposting links to employers, universities, and colleges. When a user clicks on a link away, a pop-up appears which advises them that they are visiting a third-party site and to check with an adult if needed. Only third-party sites which signpost training courses and employments are referenced.
Data protection impact assessments: Undertake a DPIA to assess and mitigate risks to the rights and freedoms of children who are likely to access your service, which arise from your data processing. Take into account differing ages, capacities and development needs and ensure that your DPIA builds in compliance with this code.
Developing Experts has undertaken an internal assessment to review its data collection procedures. Its review concluded that any third party site it signposts to from the Developing Experts site should be flagged to ensure that the risk of any third party site is mitigated. Third party sites are only to be signposted if they are deemed to add educational value to the user experience.
Developing Experts ensures no personal data is shared with third party partners.
Only anonymised data is shared with third party partners. This data relates to how the community of users generic interact with the careers and jobs posted on the site. For example, partners can see how many users from an area have viewed a particular career film or clicked on a careers profile or see how many users of a certain age are interested in construction or energy as a profession.
Age appropriate application: Take a risk-based approach to recognising the age of individual users and ensure you effectively apply the standards in this code to child users. Either establish age with a level of certainty that is appropriate to the risks to the rights and freedoms of children that arise from your data processing, or apply the standards in this code to all your users instead.
Developing Experts ensures that the Children’s Code is fully adhered to. Personal data gathered from children under 18 years of age is only shared with the teacher/school/parent or responsible adult who has created the account on the child’s behalf. The teacher/school/parent or responsible adult is able to track how the child is progressing with their learning.
Developing Experts encourages schools to set up parent accounts to enable children, parents and teachers to learn about the careers it is signposting through the curriculum to optimise the impact of Gatsby Benchmark 4.
Transparency: The privacy information you provide to users, and other published terms, policies and community standards, must be concise, prominent and in clear language suited to the age of the child. Provide additional specific ‘bite-sized’ explanations about how you use personal data at the point that use is activated.
Developing Experts Privacy Policy provides transparency about how it protects and uses data on the Developing Experts site.Detrimental use of data: Do not use children’s personal data in ways that have been shown to be detrimental to their wellbeing, or that go against industry codes of practice, other regulatory provisions or Government advice.
Children’s personal data is only shared with the teacher/school/parent or responsible adult. No personal data is shared with third party users linked to Developing Expert’s site.
Policies and community standards: Uphold your own published terms, policies and community standards (including but not limited to privacy policies, age restriction, behaviour rules and content policies).
Developing Experts carries our regular reviews to ensure all published terms, policies and community standards are adhered to. Developing Expert’s staff induction process ensures that all staff are made aware of and adhere to all published standards regarding the use of personal data.
Default settings: Settings must be ‘high privacy’ by default (unless you can demonstrate a compelling reason for a different default setting, taking account of the best interests of the child).
Developing Experts ensures that default settings are set to high privacy on all accounts for children under the age of 18 years.
Data minimisation: Collect and retain only the minimum amount of personal data you need to provide the elements of your service in which a child is actively and knowingly engaged. Give children separate choices over which elements they wish to activate.
Developing Experts only holds the data needed to enable the teacher/school/parent or responsible adult to assess a child’s progress. This includes how a child’s performance data in the class assessment tasks, their name, and school year. Users can personalize the career and job feeds they receive based on their personal interests, but this data is not shared to third party partners.
Data sharing: Do not disclose children’s data unless you can demonstrate a compelling reason to do so, taking account of the best interests of the child.
Developing Experts shares no personal data with third party partners.
Geolocation: Switch geolocation options off by default (unless you can demonstrate a compelling reason for geolocation to be switched on by default, taking account of the best interests of the child). Provide an obvious sign for children when location tracking is active. Options which make a child’s location visible to others must default back to ‘off’ at the end of each session.
Developing Experts does not use Geolocations on devices.
Parental controls: If you provide parental controls, give the child age-appropriate information about this. If your online service allows a parent or carer to monitor their child’s online activity or track their location, provide an obvious sign to the child when they are being monitored.
Developing Experts encourages schools and their parents to create accounts to support the learning and development of their child. The following message appears on the pupil dashboard.
‘Developing Experts encourages your school to set up 'parent accounts' . If your parent/guardian has been given access to an account they can see how you are performing.’
Profiling: Switch options which use profiling ‘off’ by default (unless you can demonstrate a compelling reason for profiling to be on by default, taking account of the best interests of the child). Only allow profiling if you have appropriate measures in place to protect the child from any harmful effects (in particular, being fed content that is detrimental to their health or well-being).
The Developing Experts platform does not allow personal profiling to take place. Users can personalize the career and job feeds they receive based on their personal interests, but this data is not shared with third party partners.
Nudge techniques: Do not use nudge techniques to lead or encourage children to provide unnecessary personal data or weaken or turn off their privacy protections.
Any data collected via the site is anonymized for users under 18 years. Developing Experts ensures nudge techniques are not used to gather data from minors.
Connected toys and devices: If you provide a connected toy or device, ensure you include effective tools to enable conformance to this code.
Developing Experts does not provide a service that connects to toys or devices.
Online tools: Provide prominent and accessible tools to help children exercise their data protection rights and report concerns.
Developing Experts ensures the personal data uploaded to the site is only uploaded by the teacher/school/parent or responsible adult who has created the account on the child’s behalf. This process ensures that the personal data held by Developing Experts is only gathered if the responsible adult who on the child’s behalf deems it to be necessary. Users can personalize the career and job feeds they receive based on their personal interests, but this data is not shared to third party partners.
Any data collected via the site is anonymized for users under 18 years.