Growing up in the Online World: 5Rights response
5Rights’ response to the national consultation Growing Up in the Online World, outlining key recommendations for protecting children’s rights in the digital environment.
The UK Government’s Growing Up in an Online World consultation is an opportunity to reset how we think about children’s lives online. The question is no longer whether children should be online — they already are. Instead, we should be asking what kind of digital environment we want them to grow up in, and how we ensure it respects their rights, protects them from harm and supports them to thrive.
Right now, too much responsibility sits with children and families to navigate systems shaped by commercial incentives and design choices they had no role in creating. That is neither a fair nor sustainable basis for protecting children’s rights.
In our response to the consultation, we make four key points.
First, digital design is the problem, and the solution. Children’s experiences online are shaped less by individual apps than by the systems behind them – recommendation algorithms, profiling, autoplay, infinite scroll, engagement loops and AI-driven content. These are not neutral features. They actively shape what children see and how they behave. A rights-respecting approach therefore has to start earlier, by preventing harm at source rather than reacting after it occurs.
Second, age-appropriate design must go further than age-gating. The Government is right to focus on this area, but age-gating alone is not enough, and policy should not stop at age 16. We need a more comprehensive approach that reflects children’s different developmental stages. This includes prohibiting personalised, data-driven systems for under-13s, and introducing a pre-certification regime for services used by 13–18-year-olds, requiring clear standards on safety, privacy, transparency and design. Responsibility should sit with those who design and operate services, not with children or their parents.
Third, safety must be built in by design. Children should not be expected to navigate poorly designed environments. Safety should be embedded from the outset through rights-based design, minimising data collection, reducing profiling, avoiding engagement-driven manipulation and ensuring transparency and accountability by default. The Safety by Design Code of Practice provides a framework for doing this in practice.
Fourth, age assurance must be part of a broader system, not a standalone fix. It should be risk-based, privacy-preserving and judged on real-world effectiveness. This means preventing underage access without excluding legitimate users, minimising data use, ensuring accessibility and fairness, and providing transparency and routes for redress when systems fail. The Government must learn and build on age assurance duties as part of the Online Safety Act and make them safer and more robust for all users.
Existing frameworks such as the Online Safety Act and the Age Appropriate Design Code already set important expectations. The challenge is not a lack of rules, but inconsistent enforcement. A rights-based system requires clear standards, effective regulation and meaningful consequences when services fail children — otherwise protections remain principles on paper rather than realities in practice.
