DPDP and Children’s Data: What Businesses Need to Do Before Processing Child Data

 Children’s data is becoming an increasingly important privacy and cybersecurity concern for businesses in India.

Educational platforms, gaming applications, healthcare services, e-commerce platforms, social applications, entertainment services, and AI-powered products may collect information from users below 18 years of age.

Under India’s Digital Personal Data Protection (DPDP) framework, organizations processing children's personal data need to implement stronger privacy and security controls.

The key question businesses should ask is:

Can our technology actually prevent unauthorized, unnecessary, or restricted processing of children's personal data?

What Does DPDP Say About Children's Data?

The DPDP framework treats an individual who has not completed 18 years of age as a child.

Section 9 introduces specific requirements for children's personal data, including verifiable parental or lawful-guardian consent, restrictions on processing that may negatively affect a child's well-being, and restrictions around tracking, behavioural monitoring, and targeted advertising directed at children, subject to prescribed exemptions.

The final DPDP Rules provide additional mechanisms and conditions around parental consent verification and specific exemptions.

This means organizations need to move beyond traditional privacy documentation and implement technical controls across their products.

7 Key Children's Data Privacy Controls Businesses Should Implement

1. Age Assurance

Businesses need a reliable way to determine when child-specific privacy controls should apply.

Simply asking for a date of birth may not always provide sufficient assurance.

At the same time, businesses should avoid collecting excessive identity information merely to establish age.

The objective should be necessity, proportionality, security, and purpose limitation.

2. Verifiable Parental Consent

Parental consent should be treated as a technical workflow rather than a simple checkbox.

Organizations should consider:

  • Parent identification
  • Adult-status verification
  • Consent capture
  • Consent status
  • Consent withdrawal
  • Audit trails
  • Processing restrictions before verification

The consent state should be properly connected to the relevant child account and downstream processing systems.

3. Restrict Behavioural Tracking

Analytics systems can collect a significant amount of behavioural information, including:

  • Clicks
  • Searches
  • Content views
  • Session duration
  • Device information
  • Location events
  • Interaction patterns

Businesses should evaluate whether such processing is permitted for child users and whether an applicable exemption exists.

4. Control Targeted Advertising

Child-related identifiers can move from the primary application into advertising platforms, analytics tools, data-management platforms, and other third parties.

Organizations should therefore build mechanisms to prevent child accounts from entering restricted advertising audiences where applicable.

5. Audit Third-Party SDKs

Third-party SDKs can create hidden data-collection pathways.

Businesses should maintain an inventory of analytics, advertising, attribution, engagement, crash-reporting, and other SDKs and determine:

What data does each SDK collect?
Why is it collected?
Where does it go?
Can child accounts be excluded?

6. Secure APIs and Applications

Child-data protection is also an application-security problem.

Businesses should test APIs and applications for authorization weaknesses, excessive data exposure, insecure object access, authentication issues, legacy API exposure, and other vulnerabilities.

A technical vulnerability that exposes one child's information to another user can quickly become a serious privacy incident.

7. Manage Retention and Deletion

Child data may exist across multiple systems even after an account is deleted.

Organizations should evaluate:

  • Primary databases
  • Analytics platforms
  • Data warehouses
  • Backups
  • Logs
  • Support systems
  • Third-party processors
  • AI systems

Deletion needs to be treated as a complete data-lifecycle process.

Don't Forget AI

AI systems create additional considerations when children interact with:

  • AI tutors
  • Chatbots
  • Recommendation systems
  • Content moderation systems
  • Conversational assistants
  • Personalization engines

Businesses should understand what information is collected through prompts, conversations, images, voice interactions, and uploads.

They should also assess retention, access, model-training practices, subprocessors, monitoring, and deletion.

DPDP Compliance Needs Privacy-by-Design

Children's privacy cannot be handled only by the Legal or Compliance team.

Effective implementation requires collaboration between:

Legal + Privacy + Product + Engineering + Security + Marketing + Procurement + Compliance

Privacy requirements should ultimately be enforced through technology.

For example:

  • Advertising restrictions should be technically enforced.
  • Restricted analytics should be automatically disabled where applicable.
  • Parental consent should be validated by backend systems.
  • APIs should enforce authorization.
  • Deleted data should not remain accessible through downstream systems.

How Digital Defense Can Help

Digital Defense helps organizations assess their DPDP readiness, children's data privacy controls, application security, API security, cloud security, data governance, and privacy-by-design practices.

Our assessment can help identify gaps across:

  • Age assurance
  • Parental consent
  • Child-data processing
  • Analytics
  • Advertising
  • Third-party SDKs
  • APIs
  • AI systems
  • Cloud infrastructure
  • Access controls
  • Data retention
  • Data deletion
  • Security controls
  • Governance and compliance evidence

The goal is to help businesses move from policy-based compliance to privacy-by-design and security-by-design.

Read the Complete Guide

For a detailed breakdown of children's data privacy requirements, technical controls, common mistakes, exemptions, security considerations, and DPDP readiness, read the complete Digital Defense article:

DPDP and Children's Data: Privacy Controls Businesses Need to Implement

Is your organization technically ready to protect children's personal data under DPDP?

Digital Defense can help you assess where your privacy and security controls stand—and where they need improvement.

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