Why Schools Must Treat EdTech Platforms as Data Fiduciaries

Vendor & LMS Compliance: Why Schools Must Treat EdTech Platforms as Data Fiduciaries

As schools, colleges, and universities rapidly adopt digital tools—ERPs, LMS platforms, CCTV systems, mobile apps, attendance trackers, and cloud-based storage—their responsibility to protect student data has never been greater.

The Real Risk: Breaches Often Start with Vendors

Most education data breaches don’t start within the school—they start with a third-party vendor.
A poorly secured LMS or learning app can expose thousands of student records in seconds.

Under India’s Digital Personal Data Protection Act (DPDPA), schools remain fully accountable for how vendors manage personal data.
That means EdTech providers must be treated as data fiduciaries, not just service suppliers.

Why Vendor Compliance Matters

A typical institution uses multiple tools that collect student data, such as:

LMS and ERP software
CCTV and biometric systems
Fee payment gateways
Cloud platforms and apps

These tools increase data exposure risks because:

Schools often don’t know what data vendors collect.
Vendors may use unsafe or non-compliant systems.
In case of a breach, parents blame the school—not the vendor.

Vendor compliance is now central to school data safety and governance.

Who Qualifies as a Vendor?

Any external party that collects, stores, or accesses student data—including EdTech apps, cloud services, or even parent communication tools—qualifies as a vendor under DPDPA.

Once a vendor interacts with school data, the school remains responsible for its handling.

DPDPA Expectations from Schools

Schools must perform due diligence before onboarding or renewing vendors.

Key Requirements

Written contracts specifying:
- Purpose and limits of data use
- Retention and deletion rules
- Security standards and reporting duties
Vendor audits to ensure data safety
Transparency on what data is collected, where it’s stored, and who has access
Mandatory breach reporting within 72 hours

Building a Vendor Compliance Framework

1. Create a Vendor Inventory

List every app, platform, and service that accesses student data.
Most schools have 20–50 active vendors.

2. Assess Vendor Risks

Check:

Data sensitivity and storage methods
Security certifications and past breaches
Compliance with Indian privacy standards

3. Strengthen Contracts

Include clauses for:

Limited data use
No resale or sharing
Secure processing and deletion
Breach reporting and audit rights

4. Conduct Regular Audits

Verify vendors:

Follow DPDP rules
Delete data after contracts end
Restrict data access to authorized staff

5. Manage Vendor Exit Securely

When changing vendors:
Ensure all data is deleted
Obtain deletion certificates
Revoke access and update records

Case in Point: The LMS Breach Example

A school uploaded student photos and exam results to an LMS platform stored on an unsecured cloud.
The data leaked online, parents blamed the school, and the breach had to be reported.
All of it could’ve been prevented with a proper vendor contract and periodic audits.