Facebook and Instagram could be required to rethink familiar engagement features for users under 18 under a draft privacy code published by the United Kingdom’s Information Commissioner’s Office. The proposal does not explicitly order social networks to remove Like buttons, but its restrictions on persuasive design have prompted questions about whether Likes, streaks and similar rewards would need to change.
The Age Appropriate Design Code was released for public consultation on April 15, 2019. It is intended for online services that are likely to be accessed by children, not only products created specifically for them. That broad scope could include social networks, games, streaming services, websites, connected toys and apps operated by companies outside the United Kingdom when they serve UK users.
Privacy built into the service
The draft contains 16 standards organized around the best interests of the child. Among other measures, it calls for privacy-protective settings by default, collection and retention of only the data a service actually needs, clear explanations suited to a child’s age, and limits on sharing. Geolocation should normally be switched off, while profiling requires special care.
One section addresses nudge techniques: design choices that steer a person toward a particular decision. The ICO says services should not use such techniques to encourage children to provide unnecessary personal information, weaken their privacy settings or extend their use. A brightly highlighted public-sharing option paired with an obscure privacy choice is one obvious example of the kind of imbalance the proposal seeks to prevent.
Would Likes have to disappear?
Every Like creates information about what a person engages with, and visible reaction counts can encourage users to return, post more or seek approval. That led some coverage to suggest Facebook and Instagram might have to disable Likes for minors. Snapchat streaks, which reward people for exchanging snaps on consecutive days, were cited as another feature that could be examined under the same principle.
However, the draft does not name the Facebook Like button or impose a simple ban. It establishes technology-neutral standards rather than prescribing a single interface. A service might respond by changing defaults, reducing public metrics, limiting data use, redesigning prompts or demonstrating that a feature is appropriate for a child’s age and interests. The headline possibility of removing Likes is therefore an interpretation, not a rule already written by the ICO.
Age also presents a practical problem. A platform cannot apply different protections unless it has a reasonable way to identify younger users, but collecting more identity data can itself create privacy risks. The draft asks providers to apply its standards to all users unless they have age-assurance measures robust enough to distinguish between adults and children.
The consultation remains open until May 31. The ICO will consider comments from companies, experts, parents and the public before producing a final code. Because the standards are tied to existing data-protection duties, serious failures could expose organizations to enforcement under the GDPR, including fines calculated as a percentage of global revenue.
For social platforms, the proposal signals a wider change in regulatory thinking. Features once treated solely as tools for growth and participation may also be judged by the data they collect and the pressure they place on young users. Whether Likes survive unchanged will depend on how the final code is written and how companies explain their designs.
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