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Step 5: Identify and assess risks

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Guidance: You must consider the potential impact on children and any harm or damage your data processing may cause – whether physical, emotional, developmental or material.

When completing this section, if may be helpful for you to refer to  Standard 5 of the code – Detrimental use of data and the Children’s code harms framework.

Describe source of risk and nature of potential impact on individuals.

Include as a minimum an assessment of particular risks to children as listed in the DPIA standard in the Children’s Code. You may need to consider separately for different age groups.

Likelihood of harm

Remote, possible or probable

Severity of harm

Minimal, significant or severe

Overall risk

Low, medium or high
  1. Use of (game play) data that contravenes health standards and guidelines (for example issues by the Chief Medical Officer or Public Health England). Risk that data-enabled service personalisation leads to excessive engagement, that risks children’s right to access health services.
 possible significant medium
  1. Personalised targeting of service features that generate revenue (for example in-game perks or purchases) that are set without adequate transparency and safeguards, risking children’s right to protection from economic exploitation.
 possible significant medium
  1. Parental controls for monitoring children's activities are used without adequate transparency for children, risking children’s rights to protection from other forms of exploitation.
 possible significant medium
  1. Personalised advertising of fraudulent or age-inappropriate products that risks children’s right to protection from economic exploitation.
 possible significant medium
  1. Failure to uphold community standards exposes children to harms that have a chilling effect (for example leaving online communities – family circle - as the result of abuse) risks children’s right to freedom of association.
 remote minimal low
  1. Online tools for children (and parents, for younger children) to exercise their data rights that are untransparent, not specific to the rights they support, or not provided, risking children’s right to knowledge of their rights.
  possible  significant medium