• As the world prioritizes data privacy, the Digital Personal Data Protection (DPDP) Act, 2023 comes with certain expectations regarding gathering, storing, and processing children’s personal data.
• For Education Data Protection Officers (DPOs) or those handling EdTech platforms, obtaining consent from parents or guardians is not a mere formality—it's the bedrock of legal data processing.
• In this article, we demystify the intricacies of handling student and parent permissions, point out common missteps, and provide you with a ready-to-configure checklist to develop compliant consent processes.

1. The Rulebook: Understanding Consent in the Context of Minors

DPOs must grasp the concept of ‘valid consent’ under the DPDP act with special attention to minors [below 18 years of age]. This understanding is crucial for building complaint data processing systems that respect user rights and adhere to regulatory requirements.
Key Takeaways:
 Consent for children is compulsory
→ Processing a child's personal data is only allowed by law if the child's verifiable consent has been obtained from a parent or lawful guardian (Sections 9(1) and (2) of the DPDP Act).
 Consent must be "free, specific, informed and unambiguous"
→ Leaving out the passive or vague option is not good enough, and companies must use clear wording and disallow any pre-ticked boxes.
 Consent must be revocable
→ Parents must have an unobstructed view if they want to withdraw their consent to the processing of their child's personal data at any time, and the platform must have a mechanism in place to act on it promptly.
Trivia Thought:
According to UNESCO, over 55% of Indian students aged 5–17 use EdTech platforms. If even a fraction is collecting data without valid consent, that’s a compliance red flag waiting to be triggered.

2. Scenario Spotlight: How Consent Plays Out in Real Institutions

To bridge the gap between theory and practice, let’s understand by exploring common Edtech and school scenarios that illustrate the law’s application for DPOs. Examples and insights: -
Admissions Forms (Offline Schools):
→ Schools must ensure that any form that collects children’s data must also collect a consent clause with digital or paper signature of a guardian.
Learning Apps (EdTech):
→ The app should also contain a parents onboarding flow, separate from the child flow, including OTP verification or parental email verification.
Live Classes and Recordings:
→ If you are capturing student images and or voice data, you must obtain explicit consent for content capture, storage, and distribution.
Pro Tip: Log every consent as a time stamped entry to create an auditable trail in case of disputes or audits.

3. Building a Consent Workflow That Works and Scales

Establish a structured compliance workflow to ensure consistent and lawful data processing which is applicable to both schools and EdTech startups. Workflow essential
Stage 1: Catalog all student data touch points
→ Determine all steps from sign-up and assessments and identify every point where personal data has been collected or used.
Stage 2: Add consent as an access gate to data collection
→ No consent, no data. Set-up logical gates in the backend which will allow data flow only once verified.
Stage 3: Create granular options for consent
→ Allow parents to select what data their child is allowed to be used for – an assessment, the ability to share with third parties, or allow analytics.
Stage 4: Implement version control around policy or consent update
→ Each version change in policy or consent will create a new consent flow and it should include version log tracing.
Quick Stat: A 2024 report by IAMAI revealed that 83% of parents are still unaware of the fact that EdTech platforms use their child’s data. This gap is your compliance opportunity.

4. Common Pitfalls in Parental Consent: What to Avoid

Many organizations, even those with good intent, fall into pitfalls that move away from the DPDP framework. Red Flags to Watch For:
• Assuming consent from a parent account applies to the child
→ Consent needs to be explicitly linked and clear.
• Obscure consent forms
→ Are you burying legalese, or trying to ask for multiple consents in one checkbox? Not compliant.
• No ability to opt-out/withdraw
→ If the user cannot easily change their mind, your consent mechanism is broken.
• Ignoring updates to child status
→ When a child turns 18, they change their data controller—they must be able to give independent consent.

5. Record-Keeping: The Silent Compliance Hero

Consent isn’t a one-time activity; it is a living document. DPOs should store adequate logs for auditability and user trust.
Best Practices can be: -
• Use secure, centralized systems: Store consent records with metadata: date, time, user ID, method.
• Allow for traceability: The parent should be able to see when and how they consented and revoke it.
• Train your staff: Ensure that teachers, app developers, and admin teams know the consent lifecycle.
• Conduct regular audits of consent: Each quarter, look for inconsistencies, expiries, and validate flows.

6. Integrating Consent with Other DPDP Principles

Consent is only one piece of the compliance puzzle and must be taken with the overarching obligations of the Act.
Integration Checks:
• Purpose Limitation: Use the data only for the purpose outlined in the consent form.
• Data Minimization: Collect only the data needed for specific use.
• Children’s Rights: No profiling, targeted ads or automated decision making based on a student’s performance.
• Limits on Data Retention: Delete the data once the purpose is satisfaction or consent removed.

7. Final Thoughts: Consent is Your Compliance Anchor

Consent is the fulcrum of your compliance. Parental permissions are not just check-boxes; in India’s new data protection framework, they are laws and ethical underpinnings.
Some things for DPOs to think about:
• Start by mapping the flow of consent across the system.
• Get true, verifiable and purpose bound consent from a parent or guardian.
• Build systems that avoid friction in managing, changing and withdrawing consent.
• Position yourself in alignment with the overarching DPDP principles, to remain ready for audit and be trusted.
In education, trust is the currency of data. Consent? That’s your vault key.