• Where privacy is concerned, children need better than ordinary protection—children need special safeguarding. The Digital Personal Data Protection (DPDP) Act, 2023 acknowledges that by establishing stringent provisions for data gathering, processing, and storage of children's personal data—particularly in virtual settings such as digital classrooms, where data gathering is prevalent and is frequently intangible.
• This blog deconstructs the child-specific provisions of the DPDP Act for DPOs, including prohibited practices such as targeted advertising, and provides compliance-first tips on how to engage more safely.

1. Why Children’s Data Needs Special Protection

Children are particularly susceptible to exploitation, profiling, and manipulation because they have a limited awareness of digital dangers. Aware of this, the DPDP Act considers them a “sensitive user group.”

Important Considerations:

• Low awareness regarding data rights: Children usually do not know when or how their data is collected.
• Long-term consequence: Abuse of their data today can affect them far into adulthood.
• Digital learning explosion: As EdTech and online education rise, data collection on kids is higher than ever before.

2. Who is a Child for the Purposes of the DPDP Act?

Definingthings is important for DPOs. The DPDP Act states a child as any person less than 18 years of age—a more stringent age limit than most international laws such as GDPR (which considers it 13 or 16).

What DPOs Should Know

• Universal 18-year cutoff: No deviation permitted between services.
• Universal to all platforms and sectors: Whether it’s an EdTech platform, gaming application, or school administration system, adherence isrequired.

Trivia thought: Most international platforms that are present in India will have to modify their default age limits in order to remain compliant.

3. Parental Consent is Non-Negotiable

Verifiable consent from the parent or guardian is required prior to collecting or processing any personal data of a child.

Practical Steps:

• Put strong age verification in place: Apply secure digital means to verify the age of a child.
• Draft consent forms simply: No technical terms; use visual prompts or child-friendly formats where appropriate.
• Record consent information: Keep time stamped records of who consented and when.

DPO Tip: Consent needs to be granular platforms to enable parents to opt-in to features and purposes of data collection.

4. Prohibited: Targeted Ads and Behavioral Monitoring

One of the most substantive limitations of the DPDP Act is the flat prohibition of targeted advertising and behavioral monitoring of children.

What’s Prohibited:

• No profiling kids for personalized ads.
• No algorithmic targeting ofpreviousbehavior.
• No dark patterns to nudge kids’ actions.

Why It Matters:This provision is designed to decrease exploitation and addictive behavior oftenencountered on digital platforms. DPOsare required to examine all vendor platformsutilized in the learning environment for compliance.

5. More Data Governance Needed in Digital Classrooms

With learning apps being used in schools to take attendance, grade work, give tests, and provide virtual instruction, huge volumes of data are being produced every day. Too many of them do not have privacy-by-design.

DPO Checklist:

• Vendor risk assessments: Make sure third-party EdTech tools comply with Indian children’s data laws.
• Restrict data collection: Collect only the necessary data such as name, class, or grades—no biometrics or behavioral data unless warranted.
• Train teachers and staff: Educators should be sensitized to best practices in data privacy.

Stat: In 2023, a study discovered that more than 60% of Indian EdTech tools captured extra data beyond necessity, in many cases, without explicit consent.

6. Safe Engagement Approaches to Digital Platforms

Instead of using data-intensive models, platforms can build child-safe, trust-based environments.

Alternatives to Explore:

• Context ads instead of behavior ads: Display generic educational products rather than tracking-based advertisements.
• Gamify without tracking: Employ progress-based rewards without monitoring user behavior data.
• Privacy nudges for parents: Provide frequent insights into how their child’s data is utilized.

✅ Pro Tip: youronly best friends in child-centric designis data minimization and purpose limitation

7. What Happens if You Don’t Comply?

Failure to abide by child data protection rules isn't only reputational costly—it's expensive as well.

Penalties in the DPDP Act:

• Up to ₹200 crore in fines for non-protection of children's data.
• Service prohibition or suspension for repeat offenders.
• Compulsory disclosures to parents and regulators upon a breach.

⚠DPOs must perform regular audits and review SOPs on processing data related to minors.

8. Final Thoughts: The Way Forward for DPOs

Young minds protection is not mere compliance—it's also ethical digital practice. As more digital classrooms are used, the focus on children's data is only set to increase. Here's what DPOs need to keep in mind:

• Keep privacy by design a top priority in all child-facing features.
• Validate and record parental consent.
• Prohibit all types of targeted profiling and behavioral nudges.
• Educate, audit, and evolve—data protection is an ongoing checklist.

Tune in to Patronus for more practical guides on how to navigate the DPDP Act by sector. Need to make sure your EdTech vendors are compliant? Get in touch for a free DPIA consultation today.