Nagaraj BS, Legal Advisor, IP, Tech and Data Privacy Lawyer

In today’s digital age, schools are no longer confined to classrooms and corridors — they have evolved into vast data ecosystems. From collecting Aadhaar numbers at admission, to using biometrics for attendance, hosting virtual classes, or storing medical information, educational institutions handle large volumes of sensitive personal data.

With the enactment of the Digital Personal Data Protection Act, 2023 (DPDPA), schools must now confront a new legal reality: protecting personal data — especially that of minors — is no longer optional. It’s a legal obligation carrying serious financial and reputational consequences.

What Is the DPDPA?

The DPDPA is India’s first comprehensive law governing the collection, processing, and storage of digital personal data. It applies to all entities handling such data, including schools. Under the Act:

• Data Principals are individuals whose data is collected (students, parents, staff).

• Data Fiduciaries are entities deciding the purpose and means of data processing (schools).

• Data Processors are third-party service providers acting on behalf of schools (e.g. ERP or edtech platforms).

The Act is especially strict when handling children’s data (under 18 years), requiring verifiable parental consent and strictly limiting its use to educational purposes — not profiling or marketing.

Why Schools Must Take Compliance Seriously

Historically, personal data collection in schools has been casual. The DPDPA changes that. Mishandling even a single piece of data could expose a school to penalties up to ₹250 crore. For example:

1. Conduct a Data Audit
Begin with a thorough inventory of data collected, stored, and shared. Identify all platforms, vendors, and access points.

2. Perform a Data Protection Impact Assessment (DPIA)
Before implementing new technologies like AI tools or facial recognition, assess privacy risks — especially for minors.

3. Appoint a Data Protection Officer (DPO)
Large schools should designate a DPO to oversee compliance, respond to data requests, manage breaches, and liaise with regulators.

4. Obtain Verifiable Parental Consent
Ensure consent is informed, specific, and opt-in. Vague blanket consents won’t suffice under the law.

5. Publish a Transparent Privacy Policy
Clearly state what data is collected, why, for how long, with whom it is shared, and the rights of students and parents.

6. Enable Data Rights Requests
Establish clear processes for parents and adult students to request access, correction, or deletion of their data — and respond within statutory timelines.

7. Strengthen Data Security
Implement encryption, strict access controls, two-factor authentication, regular backups, and staff training in data hygiene.

8. Review Vendor Contracts
Ensure all third-party service providers are DPDPA-compliant. Contracts must define responsibilities, safeguards, and breach protocols.

More Than Compliance — A Digital Opportunity

Beyond legal mandates, DPDPA compliance is a chance to lead with digital integrity. Schools that invest in data privacy build trust with parents, meet global education standards, and demonstrate future-readiness.

It’s also a valuable teaching moment: integrating digital rights and cyber safety into the curriculum will prepare students for the realities of life in a connected world.

Final Thoughts

DPDPA compliance is not a box to tick in the future — it demands immediate and structured attention. The question is not if your school must comply, but how well and how soon.

Ignoring the law risks penalties and public trust. Embracing it positions your school as a forward-thinking, responsible institution in the digital education era.

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