ONLINE GAMING AND CHILDREN’S RIGHTS:

Recommendations for

The Online Gaming Industry
on Assessing Impact on Children

Acknowledgments
This document was developed by Milka Pietikäinen, independent consultant and Director of Threefold
Sustainability Services, and Erik Nyman from the UNICEF Child Rights and Business Unit with Daniel KardefeltWinther from UNICEF Office of Research-Innocenti. This document also benefitted from the inputs of a wide
range of stakeholders in the public and private sectors, civil society and academia. UNICEF would like toacknowledge in particular the valuable contributions from Josianne Galea Baron from the UNICEF Child Rights
and Business Unit, Sarah Jacobstein from the US Fund for UNICEF, Lulu Li from Swedish Committee for
UNICEF, Andrew Mawson from UNICEF Division of Private Fundraising and Partnerships (PFP), and Emma Day
from UNICEF’s Regional Office for East Asia and the Pacific, as well as the input received from the industry,
notably Christin Hertzberg of Modern Times Group, MTG AB, Dieter Carstensen of the LEGO Group, and theEuropean Games Developer Federation (EGDF).

Design and layout: Big Yellow Taxi, Inc.
Cover Photo Credits: (top to bottom, left to right) © UNICEF/UN014979/Estey;© UNICEF/UN046033/Gilbertson VII Photo; © UNICEF/UNI304647/Ma;© UNICEF/UN0345667/LeMoyne; © UNICEF/UNI220247/Pancic
Copyright and Disclaimer:
All rights to this document remain with the United Nations Children’s Fund (UNICEF).
No part of this document may be replicated or redistributed without the prior written
permission of UNICEF.
A reference to a non-UNICEF website does not imply endorsement by UNICEF of theaccuracy of the information contained therein or of the views expressed.
© United Nations Children’s Fund (UNICEF), April 2020

ONLINE GAMING AND CHILDREN’S RIGHTS:

Recommendations for

The Online Gaming Industry
on Assessing Impact on Children

TABLE OF CONTENTS

Table of Contents
Acknowledgments.. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

2

2.5 Protection from grooming andsexual abuse. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 18

Foreword......................................................................

3

General recommendations. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 18

Preface...........................................................................

4

Preventing grooming and sharing of childsexual exploitation and abuse materials. . . . . . . . . . . . . . . . 18

5

Collaborating with law enforcement and otherstakeholders. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 19

How to use these recommendations. . . . . . . . . . . . . . . . . . . . . . 5

2.6 Commercial models and influence.. . . . . . . . . . . . . . . . . . . 19

Introduction...............................................................

1. Fundamental principles.................................

7

General recommendations. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 20
In-game purchases. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 21

8Advertising. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 21

2.1 Healthy game play (gaming time). . . . . . . . . . . . . . . . . . . . . . . . 8

Use of player data. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 22

2. Recommendations for the industry.. . . . .

Giving guidance to parents and children.. . . . . . . . . . . . . . . . . 9
Healthy game play by design. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 9
Considerations for professional esports teams
and event organizers .. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 10
2.2 Inclusion and representation. . . . . . . . . . . . . . . . . . . . . . . . . . . . . 10
General recommendations. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 11
Company policies. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 11

Privacy policies. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 23
Considerations for esports teams, events,
streaming platforms and sponsor of esports
and streamers.. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 23

3. Taking a more holistic and structured
24
approach............................................................

3.1 Policies. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 24
Key considerations:. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 24

Considerations for professional esports teams
and event organizers .. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 12

3.2 Governance. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 25

2.3 Toxic environments. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 13

Key considerations:. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 25

General recommendations. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 13

3.3 Due diligence and remediation processes. . . . . . 25

Community Guidelines and Codes of Conduct . . . 13
Managing inappropriate behavior. . . . . . . . . . . . . . . . . . . . . . . . . . . 14
Considerations for streaming service
providers and esports teams. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 15

3.4 Reporting and transparency. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 25

Annex A - International frameworks
relevant to child rights

26

Annex B - Additional references

27.. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

2.4 Age limits and verification. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 15
General recommendations. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 16
Age rating and limits. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 16
Age verification and parental consent.. . . . . . . . . . . . . . . . . . . 17
Considerations for streaming services andesports. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 17

2

RECOMMENDATIONS FOR THE ONLINE GAMING INDUSTRY ON ASSESSING IMPACT ON CHILDREN................

FOREWORD

Foreword
Online gaming is a growing business sector, whichmeans those involved in the gaming business are
creating digital environments that draw the attentionof children around the world, in a way few others can.
Online games give children the chance to learn to;collaborate with others, connect with friends aroundthe world, learn new things, and simply have fun.
However, as is the case with many activities thatchildren engage in online, children can also experienceharm while playing games. As such, online gaming
companies have the responsibility to shape theirplatforms in ways that both maximize the positive andminimize the negative impacts on children.
This report has been finalized during the initial phasesof the COVID 19 pandemic and the implementation
around the world of physical distancing measures.
These measures have contributed to an explosion in
online gaming (among all age groups), demonstratingthat gaming is a central element in 21st century leisureand entertainment.
UNICEF engages with the world of business acrossmultiple sectors to address awareness and action
on impact on children. Many industrial sectors (andregulators) are recognizing the responsibilities that are

inherent in the social power and reach of business,
which the pandemic has thrown into sharp relief.
The children’s rights considerations that online
gaming companies should examine are found inissues such as establishing healthy game time,ensuring inclusion and representation, avoiding toxic
environments, considerations around age-limits andverification, combatting grooming and sexual abuse,and managing commercial influence.
The recommendations made in this document aredesigned to guide and support gaming companies
through a process of incorporating child rights
considerations throughout their business activities.
The recommendations are based on an exploration ofexisting promising practices within the industry, andhave been developed in consultation and dialogue
with many industry stakeholders.
Both the value of online gaming and the potential risks
and hazards associated with it are under the spotlight.
These recommendations are intended to guide theonline gaming industry to assess and understand its
impact on children’s rights with the goal of providing
the best possible experience for all children looking toenjoy gaming online.

Wivina BelmontePrincipal Advisor Partnerships,
UNICEF Division of Private Fundraisingand Partnerships (PFP)3

RECOMMENDATIONS FOR THE ONLINE GAMING INDUSTRY ON ASSESSING IMPACT ON CHILDREN© UNICEF/UNI209795/KARIMOVAPREFACE

Preface
To explore both positive and potentially negative
aspects of children’s online gaming, in August 2019
UNICEF Innocenti and UNICEF Child Rights andBusiness unit published a Discussion Paper on Child
Rights and Online Gaming, as part of a series ofsimilar papers tackling child rights issues within thedigital sector. While preparing this paper and after
its publication, UNICEF engaged extensively with theonline gaming industry in order to better understandand confirm the risks and opportunities for child rights;
to identify best practices and leaders; and ultimately
to be able to offer the online gaming sector a rightsbased framework to understand and manage its
impacts on children.
Many companies expressed their wish to receive
more practical level recommendations for further
improving their approach to child rights that they
could consider in their everyday business practices.
The authors came across promising practices by
several companies, ranging from parental controls to
age ratings, and community moderation and reporting
tools. Many of these examples have inspired therecommendations here, which have the aim ofpromoting the more widespread and consistent
adoption of promising practice.

4

The UNICEF Discussion Paper on Child Rights
and Online Gaming applies a child rights
framework to online gaming, introducing topics
of discussion to encourage debate and joint
work among different stakeholders. It is aimed
specifically at online gaming companies andcovers the same wide set of issues includedin this recommendations document, as wellas presenting an overview of emerging bestpractices in the sector and an introduction tothe online gaming ecosystem.

RECOMMENDATIONS FOR THE ONLINE GAMING INDUSTRY ON ASSESSING IMPACT ON CHILDRENINTRODUCTION

Introduction
As a digital industry creating interactive experiences,
the online gaming sector1 shares many of the challenges
and opportunities of other internet services, but it
also has specificities, particularly relating to somerevenue models. This document makes reference toexisting, more detailed guidance on child rights issues
relevant for the digital sector where it is both available
and also applicable to online gaming companies. The
recommendations here intend to focus on issues of
either unique concern for online gaming companies or tothose shared issues of highest relevance for the sector.
The online gaming industry consists of companies of all
sizes, from large established multinationals to very small
start-ups. Its ecosystem spans developers, publishers,
distributors, streaming services, esports organizers
and teams, and others. It is also influenced heavily bydevelopers of operating systems for gaming devices.
In order that the recommendations in this document
are practical and accessible to companies of different
sizes with different levels of resources, and are also
adaptable to whatever the role of the company is in
the wider gaming ecosystem, they are presented in
the format of questions. The intent is that all gaming
companies can consider these questions in their
specific context and role. As contexts vary, not every
question will be applicable to all companies.
Each section starts with an overview of theissue, also making reference to relevant articlesof the Convention on the Rights of the Child (‘theConvention’). Recommendations first introduce generalrecommendations, followed by further considerationsgrouped by topic. Each sub-section offers an introduction
on the context on why a particular topic merits special
consideration from the point of view of child rights.
The recommendations are organized according to themain sections of the UNICEF Discussion Paper on Child
Rights and Gaming, reflecting the most relevant childrights issues for the sector it identified. Sections 2 and 3
provides overarching guidance on how companies may
implement a more formal and consistent approach toconsider child rights related risks and opportunities in their
1business activities. All of these recommendations areunderpinned by international human rights frameworks andother instruments that call for businesses to consider theirrole in respecting child rights. These are outlined in Annex
A. Annex B contains additional references and sources.
This document purposefully does not highlight specificbest practices from individual companies as to do so would
have required more detailed assessment of such initiatives.

These recommendations
are designed to help online
gaming companies of all kinds– game developers, publishers,
distributors, platforms, esports
companies and streaming services
HOW TO USE THESE RECOMMENDATIONS
These recommendations are designed to help online
gaming companies of all kinds – game developers,
publishers, distributors, platforms, esports companies
and streaming services – to assess their current
practices and identify areas where they can improve or
make a difference in relation to the rights of children.
Companies may choose to work through the full list ofquestions to test their overall approach and set priorities
based on where the biggest gaps or opportunities canbe found. Companies can also start by focusing on a
specific section or topic that they deem most urgent,
relevant or of most concern for their business.
Bigger companies may choose to assign specificfunctions/teams to consider questions that are most
relevant to them – designers, community managers, safety
managers, public policy, etc. Those functions/teams canconsider how the recommendations could be implemented
in practice, what processes would be impacted and what
resources would be needed to carry them out.

Throughout this paper, we refer to ‘online gaming industry’ to describe the industry that creates and delivers video games through digital means. “Gaming” refers to playing ofvideo games. As such how of the term ‘gaming’ is used in this document is distinct from its application with regards to gambling.

5

RECOMMENDATIONS FOR THE ONLINE GAMING INDUSTRY ON ASSESSING IMPACT ON CHILDREN© UNICEF/UNI170297/MAWA

INTRODUCTION

For all companies, but perhaps especially smaller andyounger companies, as well as educational institutions
that teach game development, these recommendations
outline issues to consider building into their practices
and design processes from the start – to be included in‘safety/privacy by design’ approaches.

with licensees (intellectual property holders) and with
distribution, gaming device, and developer platforms to
demand rights-respecting approaches from those theycollaborate with or accept on their platforms.

It is important to note that the areas covered do not
represent an exhaustive list of all issues and as suchthe recommendations should not be considered as apass or fail ‘compliance check-list’.
There may also be areas where local laws go beyond
what the recommendations presented here suggest.
Similarly, companies may judge that some existing laws
actually restrict them from being able to take action inother areas. Guidance for these types of situations isprovided in the UN Guiding Principles on Business andHuman Rights. 2
There is a great opportunity for the industry to
proactively seek to understand how it impacts children
and find solutions that not only protect them from harm
but also increase the positive outcomes for children
engaging with online games. When considering theserecommendations, companies should consider theirability to control and change their own practices,
but also their leverage to influence the issues more
widely or to encourage other actors in the industry
to do so. For example, there is considerable leverage
2

UNICEF and the International
Telecommunications Union (ITU) have jointly
created guidance and tools and learningmaterials for the broader ICT sector. These
Child Online Protection guidelines include
check-lists for different parts of the sector,
including content providers and developers,
on what policies to have in place; how todevelop processes to handle child sexual
abuse materials; how to create safer digital
environments; how to educate children, parents
and teachers; and how to promote children’s
civic engagement through digital tools.

https://www.ohchr.org/documents/publications/guidingprinciplesbusinesshr_en.pdf

6RECOMMENDATIONS FOR THE ONLINE GAMING INDUSTRY ON ASSESSING IMPACT ON CHILDRENFUNDAMENTAL PRINCIPLES

1. Fundamental principles
There are some fundamental principles that
underpin all of the recommendations in thisdocument.
1.

2.

Child rights, like all human rights, areuniversal and inalienable, indivisible,
interdependent and interrelated. Thismeans that while protecting some rights,
the approach must ensure not
to infringe on other rights.

Regardless of regulatory regimes, children havespecific rights until they reach age 18. They should
not be treated as adults when they reach the ageof digital consent, whatever that may be. 3 As such,these recommendations call on companies toaward special consideration and protection to all
persons under 18 years of age in accordance withinternational norms and standards.
The recommendations here do not only concern
companies who design and target online games
for children. Children of all ages play all games,
including those that are targeted at adults. 4 Given
the ineffectiveness of current age verification
processes, companies should acknowledge thatchildren may be playing their games and consider
the risks to children who may be present.

tailored as children and their abilities mature
rather than just implementing one blunt age
level where children can either participate ornot. It also means companies should find ways
to involve those who are in charge of children’scare, such as parents and other care-givers.
4.

Child rights, like all human rights, are universal
and inalienable, indivisible, interdependentand interrelated. This means that steps taken
to protect some rights must not infringe onother rights. An example of this tension isthe challenge of how to protect children fromharmful content with better age verification
systems while ensuring their right to privacy
is not infringed. A holistic approach to childrights means that companies should concern
themselves not only with risks and protection ofchildren, but also their empowerment throughaccess and free expression – and also their rightto play and enjoyment of culture that are very
relevant rights for the online gaming sector. 6

5.

The recommendations in this document are
guided by the principle of the best interests of thechild which states that a primary considerationin any decision that affects a child should be thechild’s best interest informed by, among otherthings although not exclusively, the child’s own
views and desires.7

These recommendations callon companies to award special
consideration and protection to
all persons under 18 years of age
in accordance with international
norms and standards.
3.

The rights of children must be considered in
the light of their evolving capacities. 5 Children
merit special considerations while they growand mature and become more able to exercise
their rights online and offline. This means
companies should seek solutions that can be3

Article 1 of the Convention on the Rights of the Child defines children as all persons under the age of 18 unless otherwise stated under national law.

4

For example: <https://www.internetmatters.org/hub/research/parenting-generation-game-report/> and<https://statensmedierad.se/download/18.7b0391dc15c38ffbccd9a238/1496243409783/Ungar+och+medier+2017.pdf> (p. 45)

5Article 5 of the Convention on the Rights of the Child “…provide, in a manner consistent with the evolving capacities of the child, appropriate direction andguidance in the exercise by the child of the rights recognized in the Convention.”

6

The UNICEF Discussion Paper on Child Rights and Online Gaming offers an overview of the CRC articles most relevant for the sector, it is available at:<https://www.unicef-irc.org/files/upload/documents/UNICEF_CRBDigitalWorldSeriesOnline_Gaming.pdf>

7Article 3 of the Convention on the Rights of the Child: “In all actions concerning children … the best interests ofthe child shall be a primary consideration.”

7

RECOMMENDATIONS FOR THE ONLINE GAMING INDUSTRY ON ASSESSING IMPACT ON CHILDRENRECOMMENDATIONS FOR THE INDUSTRY

2. Recommendations for the industry
2.1 HEALTHY GAME PLAY(GAMING TIME)
A child’s right to leisure, play and culture (article 31)
relates strongly to the online gaming sector. How
much of their leisure time children spend in the digitalworld is an increasingly debated topic, raising concerns
among some about the health (article 24) implications ofexcessive use or over-training in competitive scenarios.

Any initiatives encouraging
discussion between parents
and children on gaming andencouragement of parents to get
acquainted with their children’s
gaming hobby, can contributeto better outcomes for all across
many areas presented in theserecommendations.

The Convention calls for children to have a rightto express their views on matters affecting them(article 12), and these views to be given due weight inaccordance to the age and maturity of the child. Any
initiatives encouraging discussion between parents
and children on gaming and encouragement of parents
to get acquainted with their children’s gaming hobby,
can contribute to better outcomes for all across many
areas presented in these recommendations.
These questions can be answered from the perspective ofgame developer, publishers, distributors and platforms (insome cases the questions can be answered in terms of
the requirements a publisher, distributor or platform mayplace on the games they market, sell and profit from).

Retaining players with engaging content is ofcourse a primary target for any game designer andpublisher – customers who enjoy the experience
will return and buy new products and are more
likely to spend money in the game. Finding the rightbalance between providing engaging experiencesand generating revenue will be a key considerationfor online gaming companies. To find this balance,companies will rely heavily on feedback fromtheir community and are often able to adjust theirapproaches accordingly. Given that this is an area
where children merit special consideration as they
are still learning to moderate their behaviors, it
is important for companies to ensure that they
are consulting with children in an age-appropriatemanner and seek to understand what is in the child’sbest interest. More information for businesses on
consulting with children can be found in UNICEF’s“Engaging stakeholders on Children’s Rights” tool. 88This tool offers guidance to companies on
engaging stakeholders on children’s rights aspart of enhancing their standards and practices
at both the corporate and site levels. Engaging
stakeholders on children’s rights can inform thedevelopment of company policies, and humanrights due diligence processes (assessing
actual and potential human rights impacts,
integrating and acting upon the findings,
tracking responses and communicating how
impacts are addressed), and the developmentof grievance and remediation mechanisms.
Stakeholder engagement can also feed into a
company’s broader sustainability strategy andlong-term goals.

https://www.unicef.org/csr/css/Stakeholder_Engagement_on_Childrens_Rights_021014.pdf

8RECOMMENDATIONS FOR THE ONLINE GAMING INDUSTRY ON ASSESSING IMPACT ON CHILDRENRECOMMENDATIONS FOR THE INDUSTRYGIVING GUIDANCE TO PARENTS AND CHILDREN
Parents have primary responsibility for balancing
the activities of their children, with children given
progressively more autonomy as they mature.
Gaming companies can encourage parents toengage with their children’s gaming hobby andbuild their understanding of how appropriate thegame content is for their child, of how games
work, and set game time limits together with theirchild. This can help parents to also view theirchild’s gaming hobby more positively and makechildren more likely to tell their parents about any
negative experiences they may encounter.
2.1.1.

2.1.2.

2.1.3.

2.1.4.

2.1.5.

9

Do you provide guidance (or reference existingguidance from others in the ecosystem) for
parents and caregivers to, together with theirchildren, set fair rules and boundaries forhealthy gameplay? Have you considered what
healthy gameplay would look like for yourgames in particular?
Does your guidance (or existing guidance you
may refer to) encourage parents to involve
their children in discussions around games
and the appropriate rules for game time? Does
this guidance encourage parents to take into
account the level of development and maturityof individual children (such as teaching children
to manage their gaming time themselves or toagree on how many sessions / levels to play,rather than setting strict time limits)?
Do you have parental control solutions in place,or are your games compatible with platform-level
parental control solutions, that are appropriate todifferent age groups of children and allow parents
to manage play time together with their child?
Do the parental control solutions you provide,or do the platform-level parental controls yourgames are compatible with, allow for a scalingor tailored approach to take into account theevolving needs and capabilities of children as
they grow and mature?9
Do you, or any organizations you are a member of,carry out any customer research or consultation

with parents and children to ensure their feedback
on your services, including how well your parental
control solutions may address challenges aroundhealthy game time and how your games may
encourage excessive use among children?
2.1.6.

Outside of parental controls, do you provide
ways for players, including children, to set time/ session limits? Do you actively promote these?

HEALTHY GAME PLAY BY DESIGN
There are a number of ways companies canencourage healthy game play and refrain frompromoting excessive play in game design. As
with commercial influence (see section 2.6),
children may be more susceptible than adults
to techniques seeking to direct behavior andtherefore merit special considerations.
2.1.7.

When you design games, do you consider
techniques to support users to develop healthy
playing habits and learn how to manage
gaming time?

2.1.8.

Do you use rewards or other “nudge
techniques” to encourage players to keepplaying or come back to the game at frequentintervals? Are these periods and intervals
reasonable? Are the techniques you employ
easy for children to recognize and also resist?

2.1.9.

Are your games designed in a way that keeps
the length of sessions reasonable?

2.1.10. Are your games designed in a way that does
not disadvantage the player for taking time off
not to play it?
2.1.11. Does your game design encourage players totake breaks (e.g. with alerts or rewards)?
2.1.12. Do you build opportunities for idle time inyour games?
2.1.13. Do your games include any virtual reality elements?
If/when VR is involved, do you take into accountany specific risks or considerations for children andtheir development, given little research has been
done on VR’s impacts on children?

“While parental controls may be appropriate for young children who are less able to direct and moderate their behaviour online, such controls are more difficult to justify foradolescents wishing to explore issues like sexuality, politics and religion. […] Importantly, parental controls may also hamper children’s ability to seek outside help or advice
with problems at home.” (UNICEF Discussion Paper on Privacy, Protection of Personal Information and Reputation p. 17, available at:<https://www.unicef.org/csr/css/UNICEF_CRB_Digital_World_Series_PRIVACY.pdf>)

9

RECOMMENDATIONS FOR THE ONLINE GAMING INDUSTRY ON ASSESSING IMPACT ON CHILDRENRECOMMENDATIONS FOR THE INDUSTRYCONSIDERATIONS FOR PROFESSIONALESPORTS TEAMS AND EVENT ORGANIZERS
If your esports team, league or event accepts players
and participants below the age of 18, there are somespecial requirements that should be put in place toensure these children understand their rights, and that
their educational, physical and mental needs are met.
2.1.14. Have you introduced any special considerations
regarding esports players who are children(below 18) in terms of how many hours per day
they can practice or stream?
2.1.15. Do your internal policies and contracts with any
players under the age of 18 include specificconsiderations to ensure educational needs,
physical and mental wellbeing, access to family
support and safeguarding of minors from abuse?10

2.1.16. Are there any time limits or any other limits /restrictions imposed on tournaments, both online
and physical events involving minors below theage of 18, either as players or spectators?
2.1.17. How do you consider issues relating to thekinds of content that minors (under 18) may
see when watching events (physical audienceand online audience) in event planning?

2.2 INCLUSION AND
REPRESENTATIONChildren’s right to non-discrimination (article 2)outlines that children should not be distinguished,excluded, restricted or given preference on any
ground, including race, sex, language or religion.
While there is common perception that playing online
games is an activity solely enjoyed by boys, this is notreality. Nevertheless, much remains to be done to makethe world and representation of online games inclusive
and welcoming from the perspective of gender. Womenand minorities represent a fraction of game developers,11
which could help explain why most lead charactersremain white males, and women and girls continue tostruggle to find content that appeals to them.12

Japan Committee for UNICEF has publishedChildren’s Rights in Sports Principles,
which outline 10 expectations for sports
organizations, sponsors, adult athletes andparents and caregivers regarding rights ofunder-age athletes. Many topics covered arealso relevant for the esports sector, including
protecting children from exploitation, ensuring
adults who interact with them are trained andunderstand their specific needs, that children
are provided balance in their activities andother elements for a healthy lifestyle, and thatany specific considerations for children areembedded in any sponsorship deals.

Addressing diversity and making gaming experiencesmore reflective of wider society also represents asignificant economic opportunity for gaming companies.13
It is important for gaming companies to pay attention
to who is in the room when games are developed anddecisions are made, to ensure that different viewpoints
and experiences are represented and also heard. This
will allow companies not only to fully appreciate thedifferent forms discrimination can take but will support
the creation of content and experiences that will appeal
to a more diverse and wider user base.
Non-discrimination also encompasses issues regarding
exposure to unsafe, unfriendly or even threatening
environments that women and girls unfortunately still

10 The ILO Conventions 138 and 182 on minimum age and child labour call attention to any practices that may harm the physical or mental wellbeing of children or that
impede their access to basic education.
11 According to European game developer associations, women represent between 10-30% of game developers in Europe depending on the country, with figures in mostcountries between 10-20%.
12 Lynch, Teresa & Tompkins, Jessica & Driel, Irene & Fritz, Niki. (2016). Sexy, Strong, and Secondary: A Content Analysis of Female Characters in Video Games across 31
Years: Female Game Characters across 31 Years. Journal of Communication. 66. 10.1111/jcom.12237.
13 Change the Game: Driving Inclusivity and Belonging in Games, available at: <https://static.googleusercontent.com/media/play.google.com/en//about/changethegame/assets/static/pdf/white-paper-2019.pdf>

10RECOMMENDATIONS FOR THE ONLINE GAMING INDUSTRY ON ASSESSING IMPACT ON CHILDRENRECOMMENDATIONS FOR THE INDUSTRY

disproportionately encounter, and which will discourage
their participation both in online gaming communities
and the growing field of esports. (How to tackle toxic
environments is discussed more specifically in section 2.3)
These questions can be answered from the perspective ofgame developer, publishers, distributors and platforms (insome cases the questions can be answered in terms of
the requirements a publisher, distributor or platform mayplace on the games they market, sell and profit from).

Addressing diversity also represents asignificant economic opportunity for gaming
companies. It is important for gaming
companies to pay attention to who is in theroom when games are developed and decisions
are made ... this will allow companies to create
content and experiences that will appeal to amore diverse and wider user base.

GENERAL RECOMMENDATIONSChildren will seek to identify with characters toenhance their enjoyment of the gaming experience.
To draw positive experiences and learning fromgames, it is important that they can find diverse
characters in diverse roles and that games aremarketed in a way that is inclusive. It is criticalthat, at every step, companies remain aware of
the messages representation in games can send tochildren and young people: what it tells them about
what they should look like, what they can do, andthe roles they can play.
2.2.1.

Are you making conscious efforts to introduce
diverse characters (including lead characters)
and to avoid stereotypical representations orgender roles for game characters?

2.2.2. Is there a conscious effort to ensure games
and social features are designed in a way thatwill be appealing to both girls and boys?
2.2.3. Are you encouraging your developers orcommunity to design games that appeal todiverse audiences? Do you have formal policies
for this, for example is this a requirement to beconsidered in your game design process, or to
be included on your platform?
11

2.2.4. When you are taking decisions on characters,
storyline, social features, monetization andmarketing, is a diverse group of people
consulted to make those decisions? Are you
making sure their views are also heard andtaken into account when decisions are made?
2.2.5. Across the range of games you have developed
or provide access to, have you done an inventoryof your game characters based on diversity?
2.2.6.

Can characters in your game be customised soplayers can choose what their character looks like(e.g. choose gender, skin colour – as relevant)?

2.2.7.

In your marketing and promotional materials do
you consider new ways to appeal to potentially
new and diverse audiences, rather than solely
targeting a narrow segment of your market?

2.2.8.

Are you involved in any industry or other initiatives
focused on taking steps to create environmentsthat are positive, inclusive and safe for all playergroups, whether players are adults or children?

2.2.9.

Do you have any initiatives around encouraging
girls or children from minority groups to enter
the industry (e.g. these could be collaboration
with schools, with universities, or traineeships,
scholarships, or after-school clubs and activities)?

2.2.10. Are you taking steps to avoid that character
design does not sexualize children when they
are characters in the game?

COMPANY POLICIESIt is important that children find role models ingame characters but also in people who work in
the industry. Having a diverse workforce will help
companies to better understand the requirements
and challenges faced by their diverse customer base.
Developing a diverse workforce requires measuring
diversity to help to identify gaps and understanding
how to create an inclusive workplace where people
feel their needs are understood and their differenceis valued. In addition, how companies treat theirstaff, particularly those who are parents, has a big
impact on the rights of their employees’ children.
2.2.11. Do you have an equal opportunity andnon-discrimination policy in place? Is this
supported by mechanisms for employees toreport any concerns?

RECOMMENDATIONS FOR THE ONLINE GAMING INDUSTRY ON ASSESSING IMPACT ON CHILDRENRECOMMENDATIONS FOR THE INDUSTRY© UNICEF/UN0202943/PANCIC

2.2.13. Are efforts made to ensure recruitment,
promotions and inclusive workplace policies
are free of bias and help to improve diversityof the workforce (e.g. do you require
shortlists for each recruitment to include bothmale and female candidates)?
2.2.14. Do you run any networks for employees tocome together to share experiences – e.g.
women, the LGBT community, minorities - andfor them to report any issues to management?

CONSIDERATIONS FOR PROFESSIONALESPORTS TEAMS AND EVENT ORGANIZERS

2.2.12. Do you measure the gender balance of (a) youroverall workforce, (b) your senior management(c) different job roles (in particular more
technical roles or key roles for diversity, such as
developers)? Do you measure other appropriate
diversity metrics depending on your jurisdiction?

Esports players are some of the most visible
representatives of the online gaming community, andas such who they are speaks volumes about whogames are made for. Esports players are also rolemodels and idols for many young people. For the
moment, a lot of the focus of esports tournaments is
on games that lend themselves well for competitiveand entertaining play, such as combat, but thatare also traditionally more targeted to and enjoyedby men. Making sure events are inclusive in their
participation and marketed as such will bring in newaudiences and result in better tournaments.
2.2.15. Do you have diversity indicators for the esports
players in your leagues / teams / tournaments?
2.2.16. Do you have in place processes for people toreport, and for you to investigate any harassment
or discriminatory behaviour during tournaments?
2.2.17. Do you actively take steps to increase diversity
in esports?
2.2.18. Do you organize, sponsor or support any
female esports leagues, teams or players?

UNICEF provides guidance on impact
assessments on Children’s Rights andBusiness Principles on how companies can
put in place policies and processes to createfamily-friendly workplaces (Principle 3). These
would cover considerations such as parental
leaves, maternity protections, flexible
working, and fair wages, which can all
support working parents, workplace diversity
and have a significant impact on the lives of
the children of your employees.
122.2.19. Have you considered esports events aroundgames that would more traditionally target andengage women?
2.2.20. Do your promotional materials for events
include pictures of women, minorities andgenerally diverse audiences to show an
inclusive and welcoming message?
2.2.21. In promoting you players and teams, do you
ensure you also promote female players?
2.2.22. Are the teams that organise esports
tournaments diverse?

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2.3 TOXIC ENVIRONMENTS
As young people spend more and more of their freetime online, digital playgrounds play an increasingly
important part in the social lives and interaction ofchildren – as well as the cultural content they consume.
Research in the United States has shown that online
gameplay is second only to social media as themost common digital venue for adolescents to meet
new friends.14 Similarly, popular esports players andstreamers wield increasing influence – and thus carryincreasing responsibility - as teen idols and role models.
Participation in online gaming may facilitate children’s
enjoyment of their right to freedom of expression(article 13) and to freely come together and meet eachother (article 15), enabling children to be creative andform cross-cultural bonds with others, sharing andlearning together.

Toxic or disruptive behaviour - including
inappropriate, sexist or racist content exists in the online gaming world as it doesin many online environments.

However, toxic or disruptive behaviour - including
inappropriate, sexist or racist content - exists in the online
gaming world as it does in many online environments,
and children are exposed to, targeted by and participate
in it. This exposure to unsafe or hostile environments
will discourage participation and will impact children’s
rights to non-discrimination (article 2) both as potential
victims of discrimination but also by creating risk of themmodelling inappropriate language and behaviour they see
and hear. (Inclusion and representation are discussed
more specifically in chapter 2.2)
Given social features in online games can significantly
boost revenues,15 many gaming companies seek to build
positive and healthy online gaming communities that
attract users. That said, there is room for more robust
and consistent communication and implementation of
Codes of Conduct within online games and platforms andfor finding ways to incentivize and model good behaviour.

These questions can be answered from the perspective ofgame developer, publishers, distributors and platforms (Insome cases the questions can be answered in terms of
the requirements a publisher, distributor or platform mayplace on the games they market, sell and profit from).

GENERAL RECOMMENDATIONS
2.3.1.

Do you offer a version of your game(s) /service without social features or are thesefeatures opt-in? Is this particularly for children
or offered as an option for all users?

2.3.2. Can your users have private profiles whichallow them to manage potential ‘friend’ lists
and easily delete, block or mute people?
2.3.3. Do you work with or promote any helplines
available for children to use to seek support,
counselling or report bullying they may
encounter? Is this information easy to find?
2.3.4. Do you participate in any collaborative crossindustry or multi-stakeholder initiatives to fighttoxic behaviour or cyber-bullying?

COMMUNITY GUIDELINES AND CODESOF CONDUCTYour commitment to promote positive behavior
will be invaluable for children to learn andcopy positive behaviors. A key part of this is
to proactively and consistently promote andcommunicate your Community Guidelines in waysthat are attractive to users of all ages.
2.3.5. Do you have Community Guidelines or Codesof Conduct which clearly outline what kind of
behaviours are not welcome in your gameor service?
2.3.6. Do you explain why you have Community
Guidelines and what kind of community you
want to create and why?
2.3.7.

Are your Community Guidelines worded insimple language that your community would
respond to and that would also be easily
understandable for children? Are they shortenough so that everyone, including children,
have the patience to read them?

14 Lenhart, Amanda, et al., ‘Teens, Technology & Friendships’, Pew Research Center, Washington, D.C., August 2015, p. 2, available at<www.pewinternet.org/2015/08/06/teens-technology-and-friendships>.
15 Research of 10 mobile games by TwoHat found that chat features can increase user lifetime value (LTV) by 20x. The research is available at<https://venturebeat.com/2018/12/13/how-a-top-10-mobile-game-uses-chat-and-moderation-to-drive-20x-ltv/>

13

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2.3.8. How are your Community Guidelines
communicated to users? Are they easily
accessible and frequently visible (e.g. do users
need to acknowledge them when they first signup, purchase or before they can first chat)?
2.3.9. Do you incentivize players in any way to makesure they acknowledge your Community
Guidelines (e.g. by giving in-game currency forcompleting a training)?
2.3.10. Do you use creative methods to present yourCommunity Guidelines in a format that children
can easily understand and engage with (e.g. asvideos, cartoons or icons)?
2.3.11. Do you remind users of your Community
Guidelines regularly?
2.3.12. Do you try to find out how users perceive theCommunity Guidelines and how well thesebeing followed?
2.3.13. Are all your employees trained in yourCommunity Guidelines?
2.3.14. Do you employ dedicated Community
Managers responsible for building healthy andnon-toxic player communities based on yourCommunity Guidelines?
© UNICEF/UNI209842/KARIMOVAMANAGING INAPPROPRIATE BEHAVIOR
Having in place monitoring to address toxic
behaviour in real time; reasonable response times
for flagging and communicating outcomes; andincentivizing positive behaviour all contribute toshow that you can be trusted to keep everyone safe.
2.3.15. Do you have mechanisms in place for users
to safely and confidentially flag inappropriate
behaviour and breaches of Community
Guidelines? Are these easy to find and to use(including for children)?
2.3.16. Do you monitor your processes for responding
to flagging, making sure response times andresources to manage reports are reasonable?
2.3.17. Do you have anything in place to ensure thatflagging mechanisms are not misused to bully?
2.3.18. Do you provide prompt responses to reports fromplayers, including outcomes of investigations;the ability to appeal decisions; and action against
players who do not respect the rules?
2.3.19. Beyond flagging, do you have other monitoringmechanisms in place to actively manage
disruptive and inappropriate behavior during
in-game communication and on streaming
services (e.g. robust chat moderation thatinvolves automatic and human moderators)?
2.3.20. Are your Community Managers trained to deal
with situations where children are involved anddiffuse situations where children are the ones
being disruptive in your community?
2.3.21. Does your text chat filtering tool allow users
and/or parents to choose and set different
levels of filtering (e.g., ranging from removing
e.g. sexually explicit language and hate speech
to also removing profanity?)
2.3.22. Do your chat filtering tools adapt the levelof filtering depending on the age rating of a
specific game or age limits of your service?
2.3.23. Have you introduced ways to incentivize good
behaviour or earn rewards for positive actions
among members of your community (e.g.
rewards for not having been flagged by others)?
2.3.24. Are you experimenting with any in-game, realtime educational content to promote and push
on positive community behaviour?

14

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2.3.25. What consequences do you have in placebeyond banning users when they are disruptive(e.g. requirement to take e-learning course /watch a video of your Community Guidelines)?

CONSIDERATIONS FOR STREAMINGSERVICE PROVIDERS AND ESPORTS TEAMS
Like all stars of popular culture and sports, howgaming streamers and esports players behave
and speak can influence the young people who
admire them. As role models in promoting positive
behaviour, their role and responsibilities should
not be underestimated and on the contrary,should be harnessed. While streamers may not bedirectly employed or have contractual agreementswith streaming platforms, the platforms should
consider their leverage to enforce their Community
Guidelines to those who broadcast in their channels.
2.3.26. Are streamers required to acknowledge
your Community Guidelines to ensure they
understand what kind of behaviour is not
welcomed in your platform before they
can stream?
2.3.27. Do you engage with and encourage popularstreamers on your platform to openly speakout against racism, homophobia, sexism, hatespeech and other forms of bullying?
2.3.28. If streamers on your platform engage in toxic
behaviour that is against your Community
Guidelines, do you have clear responses
to tackle such situations and are thesecommunicated to the community?
2.3.29. Do players at your esports events have toofficially acknowledge the Codes of Conductof the event (and of the game they are playing)
before participating?
2.3.30. Are esports events used to promote healthy
and positive gaming communities, either
by the organisers, developers or players(or all together)?
2.3.31. At esports events, are Community Guidelines/ Codes of Conduct published in the event
program? Are they promoted at the event itself?
2.3.32. Do you use your events to promote positiveand supportive communities and behaviour?

15

2.4 AGE LIMITS AND
VERIFICATION
While businesses have a responsibility to respectchildren’s rights, the Convention calls for parental
guidance consistent with the child’s evolving
capacities (article 5) and outlines parents’ primary
responsibility (article 18) for the upbringing anddevelopment of the child. This means not only
parental responsibility of supervision but also theneed for parents to consider the views of the child on
issues impacting them. This is an area where parents
can greatly benefit from the insight and support ofthe companies who have created or sell the games
their children play.
The online gaming industry has built many
international and national self-regulatory initiatives
on age rating to help in this process. Age ratings andlimits are designed to help alert children and parents
to content that may be inappropriate for gamers of
their age group. In addition to the audiovisual content
of games, age ratings can also warn of commercial
features such as the possibility of in-game purchases
or encouragement of gambling. Given children may
be more susceptible to commercial influences, itwould seem appropriate that age ratings consider theappropriateness of different commercial content tospecific age groups. Information including clear anddetailed explanations of the commercial practices usedwithin games should be provided by publishers.

Companies can invest in child-friendly
versions of their games without datacollection, which both protect children’s
rights to play and access and continue tocomply with privacy regulations.

As such, age ratings can help parents form anunderstanding of the suitability of a particular gamefor their child – whether the child is playing or
watching others play the game – and help parents
in their role of making informed decisions for their
particular child. Transparency and completenessof the criteria against which a game is rated will
improve this understanding.

RECOMMENDATIONS FOR THE ONLINE GAMING INDUSTRY ON ASSESSING IMPACT ON CHILDRENRECOMMENDATIONS FOR THE INDUSTRYRegardless of the age rating of the game, online
gaming companies tend to exclude children below theage of digital consent if they are identified and parental
consent is not achieved. This means that privacy
regulations intended to protect children may in fact
be incentivizing children to lie about their age to beable to access the games they want to play. To protect
children’s rights to play and access while continuing tocomply with privacy regulations, companies can createa version of their games without data collection forchildren under the age of digital consent.

In general, there is ample room for innovation onage verification methods that are robust, respect
the evolving capacities of children, and are privacyrespecting. Many commonly used age verification
methods are inefficient and easily circumvented bychildren without the knowledge of their parents.
When companies do not know who their customers
are, or whether their customers are children, it isharder to provide them with additional protections.
These questions can be answered from theperspective of game developers, publishers,
distributors and platforms (In some cases thequestions can be answered in terms of therequirements a publisher, distributor or platform
may place on the games they market, sell andfrom which they profit).

2.4.3. Do you, or the platform(s) where your game isavailable, provide parental control mechanismsthat are easy to install and disable, that allow
parents to disable or enable game features
such as spending and social features, andprovide varying levels of control or filtering toaccommodate children’s evolving capacities?

AGE RATING AND LIMITS
Existing regional and national game age rating
systems take into consideration the cultural
sensitivities of the countries and regions in which
they are used. However, numerous different age
ratings and the fact that these are not easily
available or aligned across Terms of Service or
privacy policies, individual games, distribution
platforms where games are bought and accessed,
and local legal guidance can be a source ofconfusion and frustration for parents and children.
2.4.4. Have you obtained an age rating from yourlocal authorized rating agency for each market
you operate in?
2.4.5.

Are your age ratings aligned to relevantinternational ratings and local legal requirements?

2.4.6.

If you operate a digital storefront for the download
or purchase of games, do you ensure age ratings
are displayed in a prominent and clear way for allof the services / games you offer? Do you offer
information from different age ratings sources?

2.4.7.

Do you explain clearly at the point of purchase or
first access to a game what age ratings mean andconsider (i.e. are you transparent on why a gamereceived a particular rating, what criteria wasused, and relative weight of the different criteria
in determining the age limit for your game/
service)? Do you offer a clear explanation of thegame itself, and the features contained there-in?

GENERAL RECOMMENDATIONSRegardless of the age limit of your games or Termsof Service, unless robust age verification systems
are in place, it should always be assumed thatchildren will be present in the user base and steps
taken to protect them.
2.4.1.

When designing, operating and profitingfrom games does your company consider
how players under age 18 may be affectedwith what they are exposed to (not limited tocontent, but also to community interactions,data collection, in-game purchases, and otherconsumer protection related practices) andhow they could be protected?

2.4.2. Do your default settings take into account thatchildren might access your services/games?

16

2.4.8. Is your company involved in any activities
to try and drive greater alignment andconsistency regarding age ratings across thedifferent platforms where games are available?
2.4.9. Do you offer the possibility for your users –including parents and children – to provide andshare with others their views on the suitable
age limits for your game or service?

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2.4.10. Do the age rating systems you use consider
the different monetization techniques andsocial features of the game? Or do you as acompany consider omitting certain monetization
techniques or social features from your games
that are targeted to persons under 18?

AGE VERIFICATION AND PARENTAL CONSENT
To account for different maturity levels and evolving
capacities of individual children, creating processes
where parents and care-givers can be involved via
parental consent mechanisms should be considered,
so that children can be permitted access toadditional features and content as they mature andtheir right to play and access is carefully considered
as well as their right to privacy. However, thismeans that companies need to be able to identify
a player as a child to be able to award this higher
degree of protection and support.
2.4.11. Does your company have minimum standards
and requirements for the effectiveness of age
verification mechanisms? (e.g. at the very least,
avoiding potentially influencing players to lie
about their age by asking leading questions,such as “you need to be 16 to play this game,are you 16?”?)2.4.12. Do you think your current age gating andparental consent processes are adequate toprotect children? How could you improve?
2.4.13. Do you require age-verification and parental
consent for in-game monetization?
2.4.14. Do your current age verification methods
respect data privacy and security?
2.4.15. What kind of data do you require to verify
age? Is this data only used for age verificationand deleted when the verification has been
completed? Is your method also accessible tomore vulnerable children, who may not havedocumentation or data you require?
2.4.16. Do you have a process in place to handle andeventually remove any under-age players fromyour game or service who may be identified orreported to you?
2.4.17. Do you have processes in place to request
parental consent from children identified to be17

under the digital age of consent, rather than
excluding them, if the content of the game orservice is otherwise appropriate for children?
2.4.18. Do you have any content directed at adultsonly? How is this content flagged and isaccess to this protected (e.g. a PIN)?
2.4.19. If a game is accessed via a third party suchas a social media site is there an age checkagainst the game’s age limit and profile age?
2.4.20. Are you involved in research and developmentof new age-verification methods that are morerobust but do not infringe children’s rights to
privacy or collect unnecessary personal data?

To account for different maturity
levels and evolving capacities
of individual children, creatingprocesses where parents andcare-givers can be involved via
parental consent mechanisms
should be considered...
CONSIDERATIONS FOR STREAMINGSERVICES AND ESPORTS
2.4.21. Do you have age limits for your esports
tournaments/leagues/streaming services forparticipants and spectators?
2.4.22. Are age limits aligned to the age ratings of thegame being played or streamed?
2.4.23. Do you have a consistent policy on how theseage limits are determined (e.g. are they basedon the age limit of the games that is being
played? On local laws? On whether there isprize money or other considerations)?
2.4.24. At esports events, do you have a formal
process, that is consistently applied across yourevents, to verify at the event venue the age of
those who are participating (spectators)?
2.4.25. Are you clearly flagging mature content on yourstreaming service? Have you introduced any
additional controls to ensure this content can beaccessed only by adults?

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2.5 PROTECTION FROMGROOMING AND SEXUALABUSEThe Convention calls for protection of children fromsexual abuse (article 34). Where children are likely togather, there will be those who wish to cause them harm.
While comprehensive research and statistics are stilllacking, there is evidence that gaming platforms andcommunities have been misused by adults to find andconnect to children and to groom them in order tosexually exploit them both online and following meeting
offline. Social features in online games, platforms andstreaming services can also be used to share illegal childsexual exploitation and abuse content. Conversely, they
may also be used by children to tell others about real life
abuse they are experiencing.
Providers of online services including online games andplatforms can make a significant contribution to fighting
child sexual exploitation and abuse online (and offline)
by putting in place mechanisms to prevent grooming
and sharing of known child sexual abuse content,
and also by identifying and referring suspected illegal
activity to law enforcement authorities.

PREVENTING GROOMING AND SHARING
OF CHILD SEXUAL EXPLOITATION AND
ABUSE MATERIALS
There are many steps online gaming companies
can take to both protect children from unwanted
contact in games and platforms as well as makeit difficult for criminals to misuse their services.
Increasingly sophisticated technical solutions areon offer to manage unwanted content and behavior
in online communities – whether to prevent known
child sexual exploitation and abuse material frombeing uploaded or to recognize grooming attempts.
Companies should also consider how they empowerusers to have greater control of who can contact
them and share content with them with opt-in rather
than opt-out from different social features.
2.5.4. Do you have mechanisms (technical or human)in place to proactively identify potentially illegal
content or activity against children (grooming)
whether in in-game communication, chats orother messaging services?
2.5.5. Do you have mechanisms for users to reportsuspected grooming activity to you?
2.5.6.

Are your Community Managers trained specificallyto recognize and deal with grooming activity?

These questions can be answered from the perspective ofgame developer, publishers, distributors and platforms (insome cases the questions can be answered in terms of
the requirements a publisher, distributor or platform mayplace on the games they market, sell and profit from).

2.5.7.

Do you use any image hashlists, PhotoDNA,
CSAI Match or URL blacklists, or other filteringsolutions to review and block known childsexual exploitation and abuse material before it
is uploaded to your services?

GENERAL RECOMMENDATIONS

2.5.8. Do you dedicate resources – human andfinancial – specifically to innovate on more
safety features for your products and services?

2.5.1.

Do your Terms of Service and Codes ofConduct clearly prohibit the sharing of illegal,child sexual exploitation and abuse content?

2.5.2. Before implementing social features in yourgame, platform or service, have you considered
how these could be misused to groom children
or share illegal content? Based on this, do you
provide information to all users (including parents
and children) on how to protect themselves fromthis misuse or content, and where to report it?
2.5.3.

18

Do you provide guidance, or refer to guidanceby others, on how parents can support theirchildren to tell them about any inappropriate or
unusual contact?

2.5.9. Do you allow users to create private profiles?
Are profiles private as a default?
2.5.10. Do you have mechanisms in place for users toeasily delete or block unwanted people?
2.5.11. If you enable private messaging between users,
are users able to control who is allowed tomessage them? (e.g. by restricting this ability
to people on their friend list or allowing users
to screen and accept/deny messages as they
arrive from anyone not on their friend list)?
2.5.12. Do you ensure that no private information (such as
email or phone numbers) is visible to other users?

RECOMMENDATIONS FOR THE ONLINE GAMING INDUSTRY ON ASSESSING IMPACT ON CHILDREN© UNICEF/UN0299607/HERWIG

RECOMMENDATIONS FOR THE INDUSTRY

2.5.13. Do your parental control systems, or theplatform-level parental controls your games
are compatible with, allow some or all socialfeatures to be disabled?

COLLABORATING WITH LAW ENFORCEMENTAND OTHER STAKEHOLDERS
Incidents of grooming and child sexual
exploitation and abuse are extremely sensitive
and time critical, and what your company canand should do in these situations may be clearly
defined in law. For this reason, it is important tounderstand the local requirements and define andcommunicate clear, written internal processes
on how these situations should be handled, bywhom, and who should be informed.
2.5.14. Do you have formal, written internal
processes to block and remove content(and eventually preserve the content forinvestigative purposes) when it is foundor reported to you, and report this to theauthorities or to the National Center ofMissing and Exploited Children (NCMEC) or
similar child protection organizations?
2.5.15. Are your Community Managers trained in theseprocesses and able to handle and report situations
where users may share information aboutsituations that may be putting them in danger?
2.5.16. Is your company participating in any cross-industry
initiatives to create awareness among users or
to collaborate with law enforcement to fight childsexual exploitation and abuse materials online?

2.6 COMMERCIAL MODELSAND INFLUENCEThe Convention calls for children to be protected fromall types of exploitation (article 36), including commercial
exploitation. From a child rights perspective, theincreasingly popular ‘free-to-play’ business model, whererevenue is derived largely from in-game microtransactions,can have benefits in that a greater number of children
can access high-quality games and participate in thesecommunities because the original content is free.
However, as online gaming companies identify newmonetization strategies for free-to-play games, these
may represent challenges from the perspective of childrights. Children may be more susceptible to commercial
practices seeking to direct their behavior and manipulateemotions and are less likely to be able to distinguishpaid content or commercial influence than adults. Formsof economic exploitation relevant to online gaming may
include monetization techniques that may be aggressive,
inappropriate or manipulative and that can be difficult forchildren to recognize or avoid. Examples can be foundin ‘nudge techniques’ that lead users to give certain
responses; stealth advertising; product placements;
sponsorship of streamers or use of other influencers;
and advertising that cannot be turned off or that isoffered as an alternative to purchases to gain in-gameadvantage or currency.
Particularly concerning are monetization practices that
may infringe on children’s right to privacy or may involve
selling or sharing their personal information to third
parties.16 Given the challenges with age verification (see16 This section refers to data collected, retained and shared for commercial purposes. It does not refer to situations where companies may be legally obligated to collect, retainor share data for e.g. law enforcement purposes. A more complete view to the complexities of corporate collection and use of children’s data, please visit UNICEF Discussion
Paper on Privacy, Protection of Personal Information and Reputation, available at <https://www.unicef.org/csr/css/UNICEF_CRB_Digital_World_Series_PRIVACY.pdf>

19

RECOMMENDATIONS FOR THE ONLINE GAMING INDUSTRY ON ASSESSING IMPACT ON CHILDRENRECOMMENDATIONS FOR THE INDUSTRY

section 2.4), it can be assumed that the data of many
children is being unknowingly processed in this way.
Protection of privacy and personal information (article 16)
states that children have “the right to protection frominterference with their privacy, family, home andcorrespondence, and to protection from unlawful attacks
on their honor and reputation.”Children may not be as equipped as adults torecognize commercial influence and can be
more susceptible to commercial messages andtechniques seeking to direct behaviour ormanipulate emotions. Children are also lesslikely to recognize paid content than adults.

Another area receiving increased attention, particularly
from regulatory authorities, is gambling and casino
type features in online games. A key concern isthat children may find it more difficult to resist suchfeatures, or they may not understand that real money
is being spent. Lootboxes17 have been in focus, inparticular if they contain content that can help players
advance in a game or be sold elsewhere for realcurrency. In-game currencies themselves have been
compared to casino tokens18 , because although theycannot be “cashed out” in the game,19 they take theuser one step away from thinking of the real monetary
value of their spending.
There is still little information in the public domain
regarding the significance of different revenue streams
for specific gaming companies or how certain commercial
practices, in particular relating to data collection, relate tomonetization efforts. Increased transparency from online
gaming companies on their commercial motivations could
help dispel misconceptions and would support customers
in making more informed choices.
These questions can be answered from the perspective ofgame developer, publishers, distributors and platforms (insome cases the questions can be answered in terms of
the requirements a publisher, distributor or platform mayplace on the games they market, sell and profit from).

GENERAL RECOMMENDATIONSChildren may not be as equipped as adults torecognize commercial influence and can be
more susceptible to commercial messages
and techniques seeking to direct behaviour ormanipulate emotions. Children are also less likely
to recognize paid content than adults. It is hence
important to consider what monetization techniques
might be perceived as unfair or misleading tochildren and ensuring that any commercial content,
product placement, and promotion and advertising
are clearly marked as such. These considerations
are also valid for gaming platforms that may
receive a share of in-game purchase revenues ofgames published on their platform and can havesignificant say on what monetization techniques are
acceptable on their platform.
2.6.1.

Does your company use in-game monetization
including in-game microtransactions and/or advertising? Do you explain to outside
audiences how significantly each of thesecontributes to your overall revenues?

2.6.2. Have you considered in designing andoperating in-game monetization techniques(including in-game purchases and advertising)
how children of different ages (up to 18) may
perceive or be affected by these methods?
2.6.3.

Has your company developed any policies
or guidelines which set out what in-gamemonetization techniques are not acceptable foryour company? Do these policies and guidelines
consider what may not be acceptable for children(e.g. ‘nudge techniques’ or game charactersseemingly insisting users purchase some items)?
Are these policies shared with any third parties
you may be collaborating with?

2.6.4. Do you provide clear and accessible disclosureand guidance to parents and children about
your in-game monetization techniques?
2.6.5.

Do you offer options for players (including parents orchildren themselves) to restrict in-game purchases
and advertising (e.g. parental controls to restrict orblock purchases or requiring consent from parents)?

17 Lootboxes are ’mystery boxes’ that can contain different virtual items – in-game currency, cosmetic features but also e.g. tools that can help players gain advantage in thegame. Users pay to open a box or spin a wheel and receive one or more randomized virtual items. Most large gaming platforms have required game publishers to publish theodds or relative rarity of winning from lootboxes since 2019 and this practice is spreading.
18 See, for example, Swedish Media Council: Ungar & medier (Youth & Media) (2017), available at<https://statensmedierad.se/download/18.7b0391dc15c38ffbccd9a238/1496243409783/Ungar+och+medier+2017.pdf>
19 There is, however, a secondary market for the sale and purchase of in-game currency and items for real money, which may be happening in breach of a gaming company’s Terms of Service.

20

RECOMMENDATIONS FOR THE ONLINE GAMING INDUSTRY ON ASSESSING IMPACT ON CHILDRENRECOMMENDATIONS FOR THE INDUSTRY

2.6.6. For children who identify themselves as below
the digital age of consent, do you offer a
version of your game / service without datacollection, rather than exclude them from thegame, if it is otherwise appropriate for them?
2.6.7.

When children are identified, do you offer a
version of your game / service that may be
more appropriate for them (e.g. without socialfeatures, advertising, in-game purchases, orwith offline versions)? Does disabling thesefeatures for children greatly affect gameplay?

IN-GAME PURCHASESChildren may not appreciate the real monetary
value of in-game purchases in the same way
as adults and may be more likely to accidently
over-spend without the consent of their parents.
Companies can support children in understanding
the value of in game currencies and put in placemechanisms to recognize and remedy accidental
or uninformed purchases.
2.6.8.

Do you apply daily and monthly spending limits
to your games, or are your games compatible
with platform-level parental controls or otherfeatures, that enable players to control spending?

2.6.14. Do you limit the amount of different in-gamecurrencies in a given game to avoid confusionand clearly explain the value and difference of
these currency(ies)?
2.6.15. Do you in your game design make sure that it iseasy for players to opt-out from your offers to
buy items or in-game currency (e.g. by ensuring
graphics for leaving a page or buttons to decline
an offer are the same size as to accept it)?
2.6.16. Do you in your game design use game charactersto mirror or boost the player’s emotions when theysucceed or fail to complete sessions or levels? Are
these techniques used to push monetization andare any special considerations taken for children?
2.6.17. If you offer the possibility for skin-trading,what mechanisms do you have in place forpreventing skin-gambling 20?

ADVERTISING
Advertising in games should take into accountthat children are likely to view them. Examples areadvertisements for other games meant for older
audiences or advertising of products that are notappropriate for children.

2.6.9. Do you have mechanisms in place to identify
and respond to abnormal spending patterns?
2.6.10. Do you have a policy in place to reimburse
purchases, e.g. those made by a child withoutparental consent? Is the policy easy to findand clearly communicated? Do you trackthe number of cases where children makepurchases without parental consent?
2.6.11. Does your game design restrict availability ofsome items to a specific time period or give
exclusive offers tied to certain timeframes?
2.6.12. For games that offer in-game microtransactions,can players earn the same of comparable items
from gameplay without making purchases? If
yes, are your games designed to encourage
players to purchase virtual items to save time?
2.6.13. Do your games use lootboxes or similarfeatures? Are you transparent about what canbe won and what the odds of winning are in a
way that is easily understandable?

UNICEF’s Discussion Paper on DigitalMarketing is primarily aimed at advertisers
targeting children in the digital space, and tocreators of digital platforms that are childdirected and that contain advertising. It mainly
focuses on raising awareness of relevant
issues from the perspective of child rights but
includes a final section with suggestions andopportunities for positive change.

20 Skin betting means using in-game virtual items as a form of currency to place bets on outcomes of professional sports matches, esports tournaments, and casino-stylegames such as roulette or blackjack, often in violation of the applicable Terms of Service.

21

RECOMMENDATIONS FOR THE ONLINE GAMING INDUSTRY ON ASSESSING IMPACT ON CHILDRENRECOMMENDATIONS FOR THE INDUSTRY

2.6.18. Do you have a policy on what products andservices cannot be advertised within yourgames / platform / events / streaming (suchas alcohol, tobacco, fire-arms, gambling
and betting, other adult content such as
pornographic content or unhealthy foods anddrinks)? Does this policy consider children andwhat may and may not be appropriate for them?
2.6.19. Is all advertising, including product placement
and endorsements, clearly marked as such?
2.6.20. Do you allow or use interstitial ads in between
game levels that cannot be turned off? Are
you considering the length of these ads, sothey are shorter than the gaming sessions?
2.6.21. Does your in-game advertising align to theintended audience of your game?

USE OF PLAYER DATA
Regulatory regimes increasingly define “anage of digital consent” for instances where thecollection and processing of personal information
requires consent by children themselves or theirparents. In current regulation, this age usuallyvaries between 13-18 but is consistently below
18. In line with international norms of children’s
rights, many of these regulations stipulate thatcollection, sharing or reselling of children’s data
should not be undertaken unless specific and valid
consent has been obtained.
However, defining an age limit for children to provide
informed consent to the processing of their personal
information is inherently difficult, partly due to thenecessary balancing between children’s rights toparticipation and freedom of expression (which may belimited if the age set is too high) and protection fromcommercial exploitation (if the age set is too low). At
a minimum, companies should comply with minimum
ages as set in law, but companies should consider
implementing higher standards if heightened protection
concerns arise.
The nature of data and its intended use are also key
factors – with data collected to improve the gaming
experience being likely less potentially harmful tochildren than data collected for targeted advertisingor onward data sale. A responsible company should
consider proactively informing users about what data22

it collects and how this will be used so that children or
their parents are able to provide fully informed consent
and understand implications of this. Regardless ofregulatory regimes, children have specific rights until
they reach age 18 and should not be treated as adults
as soon as they reach the age of digital consent.
Given the potential challenges of obtaining meaningful
and informed consent from children or parents,
companies that want to ensure respect for children’s
rights in this space should consider the best interestof the child as a primary consideration for what data
they collect and how this is used, even where consent
is obtained. This principle should also extend to theprocess of obtaining consent (e.g. refraining frombundling consent for essential and non-essential datacollection by providing granular options).

A responsible company should
consider proactively informing
users about what data it collects
and how this will be used so thatchildren or their parents are able toprovide fully informed consent andunderstand implications of this.

2.6.22. Do you use player data to inform how in-gamemonetization techniques are used and offered
to players? What types of data do you use (e.g.
game time, previous purchasing history, stage
in game, player skill, demographics)? Do you
use aggregated, anonymized and / or individual
player data?
2.6.23. Do you collect and use player data toincrease spending or to optimize monetization
opportunities? If yes, are you ensuring suchtactics are not used in the cases of players
who are children?
2.6.24. If your game or service collects data fromplayers, how do you ensure that the behaviour ofchildren below the digital age of consent playing
your games is not tracked? What limitations doyou put in place on the use of children’s data andhow do you implement those limitations?

RECOMMENDATIONS FOR THE ONLINE GAMING INDUSTRY ON ASSESSING IMPACT ON CHILDRENRECOMMENDATIONS FOR THE INDUSTRY

2.6.25. Do you share the user data you collect with third
parties for example between platforms and gamedevelopers? Are the data protection policies ofthese third parties aligned to yours and are you
ensuring that the use of the data is limited to the
purposes it was originally provided for?

2.6.29. Do your privacy policies include specificsections explaining your policy on datacollection from children and how to contact thecompany in situations where data may havebeen inadvertently collected from children?

2.6.26. Are you transparent with users about what data
you collect from them, how you use and share it
and with whom? Is this information easy to find,complete and also easy for children to understand?

2.6.30. Are your privacy policies and Terms ofService easily accessible? Are these – or a
version of them – written in a way that iseasy to understand, both for children andtheir parents?

2.6.27. Are you ensuring that permissions are not‘bundled’ and that it is transparent and clear
what access and data collection users agree toat any given time?

2.6.31. What are your default privacy settings? Do
these take into account that children may playyour games by ensuring that least amount ofdata is collected and shared as a default?

2.6.28. Do users have to agree to data collection (incl.
cookies) before they can access your game orplatform, or is there a possibility to opt out? Is the
opt-out process easy to navigate and informative?

CONSIDERATIONS FOR ESPORTS TEAMS,EVENTS, STREAMING PLATFORMS ANDSPONSOR OF ESPORTS AND STREAMERSPRIVACY POLICIESPrivacy policies and Terms of Service mostcommonly take the point of view of the service
provider focusing on addressing their legal risks
and obligations. Written in legalistic language,
even older children – and adults – may struggle
to understand the extent and implications whenpermitting the collection of personal data.

2.6.32. Do you have in place any restrictions on what
type of advertising or sponsors are allowed
for your esports teams or events or on yourstreaming platform? Do these take into
account what may be appropriate for children(e.g. restrictions on type of companies thatcan sponsor of advertise such as alcohol,
tobacco, gambling, unhealthy drinks or foods)?
How are these communicated to advertisers?
2.6.33. As an esports team, do you have any specificpolicies when you have underage esports players
to protect them from commercial exploitation byyou, their sponsors or their parents?
2.6.34. As an esports team or event organizer, do you
have any policies in place relating to betting
and gambling in esports and how do you
ensure robust age-verification mechanisms
to prevent children from participating in any
betting or gambling activity?

UNICEF’s Industry toolkit for Children’s Online
Privacy and Freedom of Expression outlines
overarching principles, based on human rights
law, that should ground and shape decisions
about children online. It translates these fiveprinciples into check-lists of issues to consider
to better respect children’s privacy andfreedom of expression across the products andservices digital companies offer.
23

2.6.35. If you sponsor esports teams or events orindividual streamers, do your sponsorshipcontracts include requirements to betransparent that recipients are sponsored andby whom, including when they are paid toendorse products and services?

RECOMMENDATIONS FOR THE ONLINE GAMING INDUSTRY ON ASSESSING IMPACT ON CHILDRENTAKING A MORE HOLISTIC AND STRUCTURED APPROACH

3. Taking a more holistic andstructured approach
The online gaming community at its best is a
supportive and inclusive environment and many
people working in the industry are aware of andkeen to integrate these values into the services theywork to provide. This positive and welcoming culture
has also been evident in UNICEF’s engagementswith the sector. There are examples of online
gaming companies that have taken proactive
steps to make gaming a more positive and safer
experience for children. However, these initiatives
remain fragmented and few take a holistic approach
to children and children’s rights. Neither are goodpractices applied in a consistent manner acrossthe industry.

A number of business policies have relevance to –and could make specific reference to - child rights.
These include:

As gaming companies grow from small start-ups tomore mature businesses, more structured and formal
approaches are needed to ensure everyone in thecompany applies the same standards.

3.1.1.

Are your policies consistent across your games/ services (if not, what varies and why)?

3.1.2.

Do your policies make reference to issues
relating to children including creating safe
environments, educating parents and children,and collaborating with law enforcement?

3.1.3.

Has your company made any public
commitments on issues that are relevant tochild rights, such as commitments to relevantinternational standards (See section 3)?

3.1.4.

Once policies are in place, how do you ensurethat employees are aware of and understandthem? Are employees required to acknowledge/ sign policies?

3.1.5.

Do you evaluate or measure in any way what
impact your policies may have on children andtheir rights?

3.1.6.

Do you provide training to relevant employees
on your policies?

3.1.7.

Have you consulted children in the drafting ofyour policies to hear their views?

3.1.8.

Are your policies (or a version of them) written
in a way that children can understand?

This section highlights the elements that need to be
put in place within a holistic and structured company
approach to children’s rights. More detailed guidance isavailable in the materials that are highlighted throughout
this document.

3.1 POLICIESSetting company-wide – or game or business activity
specific – policies is an opportunity for companies
to define and communicate their responsibilities,
expectations and commitments to everyone
inside and outside the company. Even for smaller
companies, it is worthwhile taking time to discussand agree key principles that everyone commits
to. The questions outlined in this document are
the building blocks of good policy based on theinternational human rights and children’s rights
standards and principles outlined in Annex 1. andaligning the company approach and principles
to these standards makes them more credible,
consistent and defendable.

24•

Codes of Conduct•

Community standards•

Terms of Service•

Privacy policy•

Age limits•

Broadcasting policies

KEY CONSIDERATIONS:RECOMMENDATIONS FOR THE ONLINE GAMING INDUSTRY ON ASSESSING IMPACT ON CHILDRENTAKING A MORE HOLISTIC AND STRUCTURED APPROACH

3.2 GOVERNANCE
Governance is about defining and communicatingwhere (by whom or by which teams) decisions are
made on different policies and practices and who isultimately accountable for their implementation. It is
an important cornerstone of corporate responsibility.

KEY CONSIDERATIONS:
3.2.1.

Where or by whom are policies and processes
relating to child rights approved? Is this doneat the Board or leadership team level?

3.2.2. Is there a senior executive and/or a function
assigned with overall responsibility for issues
relating to children?
3.2.3.

Are you receiving any feedback or views ofchildren to guide your approach (in form of achild advisory councils or dedicated workshops)?

3.3 DUE DILIGENCE AND
REMEDIATION PROCESSES
Processes to implement policies related tochildren can range from carrying out detailed
reviews to identify and address any gaps, risks
and opportunities relating to child rights (‘duediligence’) to check lists to implement aspects ofthe policy into business decisions or processes.
Remediation is about having in place ways toidentify, report and address any failures tocomply to the policies you have set.
3.3.1.

Do due diligence processes which consider
child rights exist, e.g. considering child rights
issues before developing new products
and services, establishing new business
relationships, and in mergers and acquisitions?

3.3.2. Do you monitor how well your policies are
implemented and respected?

3.3.4. Do you have processes in place to carry out
investigations into potential violations?
3.3.5. Do you have any mechanisms in place toensure you also receive feedback from children
on your policies and services?

3.4 REPORTING AND
TRANSPARENCY
To show accountability and to demonstrate toyour stakeholders that you are living up to yourcommitments, it is essential to communicate
openly and honestly to external audiences on the
progress and improvement you are making overtime on implementing your policies. This creates
trust among your stakeholders, from customers
to investors.
3.4.1.

How do you communicate to external
stakeholders about your policies or issues
relating to children (e.g. is there information on
your website or in your social media channels)?

3.4.2. Do you publish an annual corporate
responsibility report or include non-financial
information in any annual reporting?
3.4.3. Have you set performance indicators relating
to your child rights policies (such as % of
employees acknowledging policies; % of
employees trained; total number of children
reached by your initiatives within a year; total
number of situations flagged by users; % ofincidents reported by users addressed within X
timeframe, etc.)?
3.4.4. Do you participate in any industry or
multi-stakeholder initiatives on corporate
responsibility which deal with topics relevant
to children?
3.4.5. What stakeholder groups do you discuss childrights related issues and progress with? Do
you engage with any child rights groups?

3.3.3. Are there ways for employees (or others) toreport any violations of your policies?

25

RECOMMENDATIONS FOR THE ONLINE GAMING INDUSTRY ON ASSESSING IMPACT ON CHILDRENANNEX A

Annex A - International frameworks
relevant to child rights
There are a number of international human rights
frameworks which form the basis upon which thebusiness responsibility to respect human rights and childrights is founded, and which this document draws from.

Declaration are Convention No. 138 on Minimum Ageand Convention No. 182 on Worst Forms of Child Labour.
These prohibit child labour and set restrictions of thetypes of work and working hours unsuitable for children.

The Universal Declaration of Human Rights was
adopted in 1948 and is the basis for most humanrights standards. The International Bill of Human Rights
consists of the Universal Declaration of Human Rights,
and the main instruments through which it has been
codified: the International Covenant on Civil and Political
Rights and the International Covenant on Economic,
Social and Cultural Rights.

In 2011, the United Nations Human Rights Council
endorsed the business-specific Guiding Principles
on Business and Human Rights. Based on extensive
consultations with a wide set of stakeholders, including
businesses, they are the recognized global standard
for preventing and addressing business-related
human rights harm. Following the recommendationof the Guiding Principles that ‘business entities
have a responsibility to respect human rights in theiroperations and supply chains’, it is clear that this
responsibility also applies to gaming companies.

The Convention on the Rights of the Child, the mostwidely ratified human rights treaty in the world, builds
on the Declaration of the Rights of the Child, which
maintains that children merit specific protections,
including legal protection, due to their physical andmental immaturity. Governments that have ratified theConvention are legally bound to uphold these rights, andthe Convention outlines the rights and responsibilitiesof parents and caregivers. Expectations on the private
sector are more fully developed in a general comment by
the Committee on the Rights of the Child.
The International Labour Organization (ILO) brings
together governments, employers and workers of 187
member States, to set labour standards, develop policies
and devise programs promoting decent work for all.
Among the eight fundamental conventions of the ILO

26

Following the publication of the Guiding Principles ofBusiness and Human Rights, in 2012, UNICEF, Save
the Children and the UN Global Compact published theChildren’s Rights and Business Principles (CRBP), which
outline ten requirements for businesses to respect andsupport the realisation of child rights. These range fromthe elimination of child labour to ensuring the safetyof products and services and that marketing practices
respect the rights of children. There are a wealth of tools
available based on the CRBPs which businesses can use
to test and manage their impact on children. A numberof these are referenced throughout this document.

RECOMMENDATIONS FOR THE ONLINE GAMING INDUSTRY ON ASSESSING IMPACT ON CHILDRENANNEX B

Annex B - Additional references
In addition to the references footnoted or included as pull-outs in this document, there were a numberof sources that have given inspiration for these recommendations. These resources can also offer further
input and guidance for companies looking to further work on their practices.

UNICEF MATERIALS:

FROM INDUSTRY:‘Access to the Internet, Education and Digital Literacy, Discussion
Paper’ (2017), available at <https://www.unicef.org/csr/css/
UNICEF_CRB_Digital_World_Series_ACCESS.pdf>

AnyKey - Gender in esports tournaments, available at<http://www.anykey.org/wp-content/uploads/Gender-bestpractices.pdf>

Child Online Safety Assessment Tool and Guidelines, available
at <https://www.unicef.org/csr/ict_tools.html>

AnyKey - Live streaming moderation best practices forevent organisers, available at <https://www.anykey.org/
wp-content/uploads/AnyKey-Moderator-Best-PracticesSept-2018-1.pdf>‘Children and Digital Marketing: Rights, risks and opportunities(2019)’, available at <https://www.unicef.org/csr/css/
discussion-paper-digital-marketing-v2.pdf>
Children Are Everyone’s Business: Workbook 2.0 – A guide for
integrating children’s rights into policies, impact assessments andsustainability reporting (2014), available at <https://www.unicef.
org/csr/css/Workbook_2.0_Second_Edition_29092014_LR.pdf>
Children’s Rights and Business Principles, all documents
available at <https://childrenandbusiness.org/>Children’s Rights in Sports Principles, available at <https://childinsport.jp/assets/downloads/Children’s_Rights_in_Sport_
Principles_English.pdf>‘Children’s Online Privacy & Freedom of Expression: Industry
Toolkit’, available at <https://www.unicef.org/csr/files/UNICEF_Childrens_Online_Privacy_and_Freedom_of_Expression(1).pdf>
Child Rights and Security Check List, available at <https://www.unicef.org/csr/files/Child_rights_and_Security_
Checklist_ENG.pdf>‘Freedom of Expression, Access to Information andParticipation, Discussion Paper’ (2017), available at <https://www.unicef.org/csr/css/UNICEF_CRB_Digital_World_Series_
EXPRESSION.pdf>
Global Kids Online, Comparative Report (Nov 2019), available
at <https://www.unicef-irc.org/publications/1059-global-kidsonline-comparative-report.html>
Privacy, Protection of Personal Information and Reputation,
Discussion Paper (2017), available at <https://www.unicef.org/csr/
css/UNICEF_CRB_Digital_World_Series_PRIVACY.pdf>
State of the World’s Children (2019), available at <https://www.
unicef.org/reports/state-of-worlds-children-2019>27

DNA Finland: Lapset ja pelaaminen (Children and
Gaming) (2018), available at <https://www.sttinfo.fi/
data/attachments/00809/614884fd-c040-4d13-ac16211075dd264e.pdf>
Fair Play Alliance – FAQ, available at <https://fairplayalliance.
org/faq/>
ISFE: GameTrack - In-Game Spending Study (November2019), available at <https://www.isfe.eu/wp-content/
uploads/2019/12/GameTrack-In-Game-Spending-2019.pdf>
Google: Change the Game – Driving inclusivity and belonging
in gaming (2019), available at https://static.googleusercontent.
com/media/play.google.com/en//about/changethegame/assets/static/pdf/white-paper-2019.pdf
PEGI Code of Conduct, available at <https://pegi.info/pegicode-of-conduct>
Telia Company – What Adults Should Know About Gaming,
Findings from the children’s advisory panel (2019), reportavailable at <https://www.teliacompany.com/globalassets/teliacompany/documents/sustainability/children-online/cap-2019final-report-gaming.pdf>
Twitch: How to Manage Harassment in Chat, available at<https://help.twitch.tv/s/article/how-to-manage-harassment-inchat?language=en_US>
Twitch: Guide to Building a Moderation Team, available at<https://help.twitch.tv/s/article/guide-to-building-a-moderationteam?language=en_US>
UKIE: Ask About Games, available at <https://www.
askaboutgames.com/>

RECOMMENDATIONS FOR THE ONLINE GAMING INDUSTRY ON ASSESSING IMPACT ON CHILDRENANNEX B

FROM NGOS:InternetMatters: Parenting Generation Game (research),
available at <https://www.internetmatters.org/hub/research/
parenting-generation-game-report/>
ParentZone: The Rip-Off Games: How the new businessmodel of online gaming exploits children, available at <https://parentzone.org.uk/the-rip-off-games>
ParentZone: Skin gambling: teenage Britain’s secret habit,available at <https://parentzone.org.uk/skingambling>

GOVERNMENT MATERIALS
Swedish Consumer Agency: Kartläggning av konsumentskyddet
vid lotteri- eller kasinoliknande inslag i datorspel (Survey ofconsumer protection relating to lottery or casino-type featuresin computer games) (2019), available at < https://www.
konsumentverket.se/contentassets/83509d8dffff48559d44de6
546ecc362/kartlaggning-av-konsumentskyddet-vid-lotteri--ellerkasinoliknande-inslag-i-datorspel-fi-2019-01630-ko.pdf>

28

Swedish Media Council: Ungar & medier (Youth & Media)(2017), available at <https://statensmedierad.se/downl
oad/18.7b0391dc15c38ffbccd9a238/1496243409783/
Ungar+och+medier+2017.pdf>
UK Digital, Culture, Media and Sport Committee - Immersive
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RECOMMENDATIONS FOR THE ONLINE GAMING INDUSTRY ON ASSESSING IMPACT ON CHILDRENAfter publishing a Discussion Paper on Online Gaming
and Child Rights and extensively engaging with theonline gaming community, UNICEF is publishing a listof recommendations designed to help online gaming
companies of all kinds – game developers, publishers,
distributors, platforms, esports companies and streaming
services – to assess their current practices and identify
areas where they can improve or make a difference inrelation to the rights of children.
The recommendations can be used to identify gaps inprocesses and policies overall or to focus on practices in
specific issues, ranging from healthy game play to toxic
behavior and commercial practices.