Consent Management for Minors: Practical Steps for Schools

Consent Requirements for Minors Every School Must Follow

In the evolving regulatory landscape of India, schools are no longer just educational institutions—they are custodians of extensive personal data. The Digital Personal Data Protection Act, 2023 (DPDPA) introduces important obligations for institutions processing children’s data, acknowledging that minors require enhanced protection when their personal information is handled. One of the most significant requirements is the need for verifiable parental consent before processing data of any child under the age of 18.

For schools, this means that consent cannot remain a casual form or a checkbox—it must be structured, transparent, traceable and integrated into every data-collection process involving students. Proper consent management builds trust with parents, supports regulatory compliance, and enables schools to operate with clarity and accountability.

Why Verifiable Parental Consent Matters

Processing student data without appropriate safeguards presents real risks—from privacy violations to reputational damage and regulatory penalties. Under the DPDPA, children are recognised as a vulnerable group whose “data principals” require extra protection. Obtaining verifiable parental consent is both a legal obligation and a practical foundation for ethical data-handling.

Consent serves multiple functions. It informs parents about what data is being collected, why it is needed, how it will be used, with whom it will be shared, and how long it will be kept. It ensures that the parent or legal guardian understands and agrees to the processing. It also provides a documented audit trail that the school, when required, can present as evidence of compliance.

Core Elements of a Robust Consent Workflow

To create a comprehensive consent-management system, schools should focus on these key components:

Clear Notice & Purpose Definition: Before any student data is collected—whether a photograph, video, attendance log, health form or learning-app activity—the school must provide parents with a clear notice. This notice should specify the purpose of collection, the category of data, the duration of processing, and any third-party vendors who will access it.
Verification of Parent/Guardian Identity: The DPDPA requires consent from a parent or lawful guardian, and that the identity of the consenting adult is verifiable. Schools must establish an appropriate method to confirm the parent’s or guardian’s identity, for example through parental login credentials, acknowledgement via a registered school portal, physical ID verification, or other reliable methods.
Opt-in and Documentation: Consent should be affirmative (opt-in) rather than implied. The school should record when consent was given, what version of the notice was accepted, the exact purpose covered, and provide an easy way for the parent to withdraw consent. These records should be stored securely and should be retrievable.
Granularity & Flexibility: Consent should be specific to each distinct purpose rather than a blanket approval for all activities. For example, consent for use of photographs in the school website is separate from consent for data sharing with a learning-app vendor. The system should allow parents to approve, decline or withdraw consent for specific items.
Ease of Withdrawal & Update: Parents must be able to withdraw consent or update their choices at any time, and that withdrawal must be honoured promptly. The system should reflect the change in the school’s processing workflows—data should cease being processed for the purpose for which consent was withdrawn.
Vendor and Third-Party Coordination: When schools engage vendors (photo-video services, learning-apps, transport tracking systems) that access student data, the consent mechanism must cover these relationships. The parent’s notice should clearly state which vendor will access the data and for what purpose. The vendor must abide by the same data-protection obligations as the school.
Auditability & Retention: The school should maintain audit logs of consent: who gave it, when, what they approved, what data is being processed under that consent, and whether any withdrawal happened. Retention of consent records must align with the school’s data-retention policy and the DPDPA’s requirement for minimised storage.

Practical Implementation for Schools

Putting consent management into practice requires both policy design and operational change. Schools might consider the following steps:

Inventory All Student Data Touchpoints: Identify every scenario where student personal data is collected, processed, shared or stored—admissions, annual forms, event photography, transport apps, digital learning platforms, videos of school activities, health-check logs.
Segment by Purpose & Risk: Classify each data-collection point by its purpose (educational, co-curricular, external vendor use), by its sensitivity (photograph vs health data vs behavioural analytics) and by the vendor/third-party involvement.
Design Consent Forms and Digital Portals: Develop consent notices and forms (paper and digital) aligned with each purpose. If using a digital portal or school-app, ensure the parent must log in and affirm the notice. For manual forms, store them in a searchable database.
Apply Verification & Role-based Access: Ensure staff responsible for consent collection are trained, the system verifies parents/guardians, and consent status is linked to the student record in your information system. Ensure only authorised personnel access consent logs.
Integrate Consent Status into Workflows: Before data is used (for publication, sharing with vendor, video upload, app-access), the system must check whether valid consent exists. If not, processing must stop or an alternate workflow (e.g., offline participation) should be provided.
Monitor, Review & Refresh: Consent does not remain static. Periodic reviews should assess whether the purpose has changed or whether new vendors are involved, necessitating renewed parental consent. Staff training should include refreshers on consent-management best practices.
Respond to Parent Requests: Parents may request to view data, correct inaccurate data, withdraw consent or request deletion. The school must have mechanisms to respond promptly and document the response.
Establish Incident-Response for Consent Breach: If data was processed without valid consent (for example a vendor used data for a purpose outside scope), there must be a defined process to notify parents, assess impact, remediate and update policies.

Benefits of Strong Consent Management for Schools

By adopting a well-structured consent management framework, schools gain several advantages:

Clearer transparency fosters trust among parents, reinforcing the school’s reputation and credibility.
Minimised legal and regulatory risk by aligning operations with DPDPA requirements and demonstrating accountability.
Better operational clarity: staff know exactly what data can be used for what purpose and by which vendor, reducing misuse or process confusion.
Improved data governance: consent records become part of the school’s data-protection fabric—enabling better audits, vendor oversight, and alignment with other compliance processes (vendor governance, data-protection audits, staff training).
Enhanced student and family experience: when parents feel their child’s data is handled responsibly, they are more engaged and supportive—benefiting the broader school ecosystem.

Consent management is not simply a compliance checkbox—it is a strategic pillar of data-responsibility in schools. For every data-processing activity involving students, verifiable parental consent provides the foundation of trust, transparency and legality. Schools that embed a robust consent framework transform their data governance from reactive to proactive.

As schools navigate the changing landscape under the DPDPA, establishing and maintaining a clear, traceable, flexible consent system ensures they are not only compliant but also viewed as guardians of student privacy.

Whether you are revisiting existing consent workflows or building a new framework from scratch, DPDPA for Schools can provide guidance, templates and audit-ready processes designed for the school environment. Secure your students’ data, empower parents, and ensure your institution leads in data protection.

Contact us today to begin your school’s consent management transformation.