Ethical and legal objections to learning analytics are barriers to development of the field, thus potentially denying students the benefits of predictive analytics and adaptive learning. Jisc, a charitable organization that champions the use of digital technologies in UK education and research, has attempted to address this with the development of a Code of Practice for Learning Analytics. The Code covers the main issues institutions need to address in order to progress ethically and legally. This paper outlines the extensive research and consultation activities carried out to produce a document that covers the concerns of institutions and, critically, the students they serve. The resulting model for developing a code of practice includes a literature review, setting up appropriate governance structures, developing a taxonomy of the issues, drafting the code, consulting widely with stakeholders, as well as publication, dissemination, and embedding it in institutions.