Are Schools Ready for DPDPA? Key Changes in Student Data Handling

How the DPDPA Is Transforming Data Practices in Indian Schools

Schools are at a pivotal moment when it comes to managing student and staff data. With the enactment of the Digital Personal Data Protection Act, 2023 (DPDPA), educational institutions in India must align their data practices not just for convenience, but to meet legal and ethical standards.

The volume and variety of data handled by schools — admissions, attendance, health records, learning analytics, photos, vendor systems — mean that even small oversights can trigger serious consequences. What follows are the principal changes that schools must recognise and embed into policy and practice.

Major Shifts That Schools Must Account For

Here are some of the most important changes introduced by DPDPA and how they affect the school environment:

1. Verifiable Parental Consent for Children’s Data

Under the Act, any processing of a child’s (under 18) personal data must occur only after verifiable consent from the parent or legal guardian.
The school must ensure this consent is specific, informed, and recorded. Schools will need systems to track and manage consent, not just rely on a one-time form.

2. Prohibition of Tracking, Behavioural Monitoring & Targeted Advertising

The DPDPA strictly prohibits processing activities that involve behavioural profiling, tracking, or targeted advertising directed at children.
This means that analytics, applications, or vendor tools aimed at profiling students for marketing or non-educational outcomes must be discontinued.

3. Purpose Limitation, Data Minimisation & Storage Limitation

Schools must review their data collection to ensure that only data that is strictly necessary is gathered for educational purposes.
Retaining data beyond its useful life or collecting for undefined future use increases compliance risk.
Every school should be able to answer:

• Why are we collecting this data?
• How long will we keep it?
• Who has access to it?

4. Stronger Accountability & Audit Readiness

The DPDPA emphasizes the duties of “data fiduciaries” — including schools, boards, and platforms — to demonstrate compliance.
Schools must be audit-ready, maintaining documented policies, vendor agreements, access controls, training records, and incident response procedures.
Compliance is now a continuous responsibility, not a one-time exercise.

5. Rights for Students (and Parents) as Data Principals

Under the Act, individuals — including parents acting on behalf of minors — have the right to access, correct, erase, or restrict the use of their data.
Schools must establish channels to respond to such requests quickly and transparently.
Failure to comply may lead to both reputational damage and financial penalties.

Practical Implications for School Operations

The legislative changes under DPDPA translate into operational shifts across all school departments. Some key implications include:

1. Digital and Traceable Consent Workflows

Paper forms alone may no longer be sufficient proof of consent.
Schools should adopt digital consent systems that can record, verify, and track consent status — including when it is withdrawn or updated.

2. Vendor and Partner Review

Many school services — such as transport tracking, ERP systems, or learning apps — involve third-party vendors who access student data.
Schools must audit vendor contracts, verify compliance standards, and ensure vendors handle data responsibly and securely.

3. Clear Data Access, Storage, and Deletion Practices

Schools must define who can access which data, how long it is retained, and how securely it is deleted.
Cloud storage must be encrypted, and data should be deleted when no longer required for educational or administrative purposes.

4. Staff Training and Awareness

Even the best policies fail without awareness.
Teachers, administrators, and support staff should be trained on what qualifies as personal data, when consent is necessary, and how to handle data breaches or access requests.

5. Incident Response and Breach Management

Every school must have a data breach response plan — outlining steps for notification, investigation, impact assessment, and corrective measures.
Having predefined procedures minimizes confusion and helps maintain compliance during emergencies.

Building a Compliance Roadmap for Schools

To align effectively with DPDPA, schools can adopt the following roadmap:

1. Map all personal data flows — covering students, parents, and staff.
2. Classify data by sensitivity — e.g., health records, academic performance, photos.
3. Review and upgrade consent forms — include verifiable parental consent mechanisms.
4. Update vendor contracts — define data-sharing responsibilities and breach notification protocols.
5. Define retention and deletion policies — establish clear timeframes for data removal.
6. Conduct regular audits — to monitor data practices and vendor compliance.
7. Train staff and inform parents — build a transparent culture of data responsibility.
8. Maintain incident and request logs — track all access, correction, or erasure requests for accountability.

The Digital Personal Data Protection Act, 2023 is not just a regulatory requirement — it’s a framework for responsible digital education.
For schools, compliance is an opportunity to rebuild trust with parents and students by demonstrating transparency and care in how data is used.

By adopting proactive measures, schools can protect their communities, minimize risks, and lead by example in India’s new era of data privacy.

Need help becoming DPDPA-compliant?
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