What Does Age Verification for 18+ Content Mean for Data Protection in the UK? 

The UK is introducing mandatory age verification for accessing 18+ online content, including pornography, gambling and other age-restricted services. This change is designed to protect children, but it raises important questions for the data protection community. Are these measures safeguarding users or creating new risks? And how do organisations strike a balance between compliance and privacy? 

What Is Age Verification and Why Is It Being Introduced? 

Age verification is the process of confirming that a user is over a certain age threshold, usually 18, before granting access to restricted online content. The UK Government has committed to rolling this out in response to long-standing concerns about children accessing harmful material online. 

Under the Online Safety Act 2023, platforms hosting 18+ content are now required to introduce robust age checks. This could involve ID scans, credit card verification, or even biometric facial recognition technology. 

Is This a Win for Online Safety or a Risk to Privacy? 

The move aims to protect vulnerable users, particularly children. But to verify age, websites must process more personal data and often very sensitive data. This creates tension between protection and privacy. 

Positive Intentions

• Protecting Children: Preventing underage users from accessing harmful content is widely supported by parents, educators and regulators. 
• Holding Platforms Accountable: The burden is shifting to providers, encouraging better content moderation and accountability. 
• Legal Clarity: New obligations provide a clearer legal framework for platforms, including pornographic and gambling websites. 

Potential Risks

• Data Minimisation Concerns: Does proving someone is 18 really require full identity data, or could a tokenised, privacy-preserving method be used? 
• Scope Creep: Once age data is collected, what stops platforms from storing or using it for other purposes? 
• Increased Attack Surface: The more sensitive data stored, the higher the risk of breaches. Facial recognition and ID scans are high-value targets. 
• Lack of Transparency: Users may not understand how their ID or biometric data is used, stored, or shared. 

What Technologies Are Being Used? 

Age verification is no longer just about ticking a box. Technology providers are introducing advanced tools to meet the UK’s requirements, including: 

• Biometric Facial Estimation: AI determines your likely age based on a selfie 
• Document Verification: Scanning a passport or driver’s licence 
• Credit Card Verification: Confirming age based on payment card data 
• Third-Party Age Assurance Providers: Trusted intermediaries that verify age without sharing the full identity 

All of these involve processing personal data. Some even involve special category data, which demands greater safeguards under UK GDPR. 

Data Protection Considerations for Organisations 

If your organisation is involved in publishing or enabling access to age-restricted content, there are immediate steps to take. 

1. Conduct a Data Protection Impact Assessment (DPIA)
Any use of biometric or ID verification requires a DPIA. These technologies pose high risks to individual rights and freedoms and are likely to trigger Article 35 obligations under the UK GDPR. 

2. Follow the Principles of Data Minimisation
Collect only what is necessary. If proof of age can be confirmed without identity, that’s preferable. Avoid systems that retain ID data longer than needed. 

3. Use Trusted Verification Providers
Work with accredited Age Check Certification Scheme (ACCS) providers or other UK-recognised vendors who are independently audited and transparent. 

4. Be Transparent with Users
Make it clear what data is being collected, how it is processed, and whether it is shared. This includes publishing clear privacy notices and cookie policies. 

FAQs: Age Verification & Data Protection 

Is age verification required by law in the UK?
Yes. The Online Safety Act 2023 requires platforms hosting 18+ content to implement proportionate and effective age checks. 

Do age verification systems fall under UK GDPR?
Yes. Any system that processes personal data—including biometric data or ID scans—must comply with UK GDPR requirements. 

What’s the safest way to verify age?
Using third-party age assurance providers that issue verification tokens without exposing full identity data is currently considered best practice. 

Can users opt out?
If access to the content is restricted by law, users cannot opt out of the age verification process. However, transparency and consent in how data is processed still apply. 

Who enforces this?
Ofcom is the lead regulator under the Online Safety Act. The ICO oversees compliance with data protection laws related to these technologies. 

The Balance Between Safety and Privacy 

For many, this change is a positive step towards safeguarding young people online. But it also signals a broader shift: privacy and safety are no longer separate priorities, they must coexist. 

The risk is that platforms, in their rush to comply, adopt intrusive systems without fully understanding the data protection consequences. Age verification should not become identity verification by default. 

The challenge now is to build trust through transparency, minimise data wherever possible, and ensure that age checks are done securely, proportionately, and fairly. 

What Should Data Protection Officers Be Doing Now? 

• Monitor developments and Ofcom guidance under the Online Safety Act 
• Review any services or platforms your organisation operates that may fall under age-restriction obligations 
• Speak to IT and procurement teams to vet any third-party age verification providers 
• Consider providing staff training on biometric data, DPIAs and user transparency 

Our View at Data Protection People 

We believe data protection and child safety can go hand in hand, but only if implemented carefully. Mandating age verification should not open the door to excessive data harvesting or surveillance. 

At Data Protection People, we support clients through this changing landscape, helping them stay compliant without compromising their users’ privacy. Our consultants can help you assess risks, write DPIAs, review third-party tools and update privacy documentation. 

If your organisation is implementing or reviewing age verification systems, we’re here to support you. 

Need Help Navigating Age Verification Compliance? 

We offer consultancy and audits that help organisations align with both the Online Safety Act and UK GDPR.