Ch IPreliminary
S.1 Short title and commencementS.2 DefinitionsS.3 Application and scopeCh IIObligations of Data Fiduciary
S.4 Grounds for processingS.5 NoticeS.6 ConsentS.7 Certain legitimate usesS.8 Data Fiduciary obligationsS.9 Children’s dataS.10 Significant Data FiduciaryCh IIIRights and duties of Data Principal
S.11 Right to accessS.12 Correction and erasureS.13 Grievance redressalS.14 Right to nominateS.15 Duties of the Data PrincipalCh IVSpecial provisions
S.16 Transfer outside IndiaS.17 ExemptionsCh VData Protection Board of India
S.18 Establishment of the BoardS.19 Composition of the BoardS.20 Salary and term of officeS.21 DisqualificationsS.22 Resignation and vacanciesS.23 Proceedings of the BoardS.24 Officers and employeesS.25 Members as public servantsS.26 Powers of the ChairpersonCh VIBoard powers and procedure
S.27 Powers and functions of the BoardS.28 Procedure followed by the BoardCh VIIAppeal and dispute resolution
S.29 Appeal to the Appellate TribunalS.30 Tribunal orders as a decreeS.31 Alternate dispute resolutionS.32 Voluntary undertakingCh VIIIPenalties
S.33 Penalties and the ScheduleS.34 Penalties to Consolidated FundCh IXMiscellaneous
S.35 Good-faith protectionS.36 Power to call for informationS.37 Blocking of accessS.38 Consistency with other lawsS.39 Bar of jurisdictionS.40 Power to make rulesS.41 Laying of rules before ParliamentS.42 Power to amend the ScheduleS.43 Power to remove difficultiesS.44 Amendments to other ActsSchools process the data of minors by definition, so Section 9 governs almost everything they do.
In short
Because pupils are children, Section 9 applies: verifiable parental consent, an outright ban on tracking and targeted ads at children, and age assurance. A narrow educational exemption may cover core academic data, but assume the strict reading. Children-data breaches carry penalties up to ₹200 crore. For step-by-step help, read the complete DPDP Act compliance guide for schools.
What changes for this sub-sector.
Before processing a pupil data, get verifiable consent from a parent or guardian, using a government- or law-authorised identity or virtual-token mechanism.
Behavioural monitoring and targeted advertising at children are banned outright, regardless of consent.
A school-contracted platform may claim a limited exemption for core academic data, not for ad-supported or analytics uses; assume the strict reading until the Board clarifies.
Gate accounts by age so you know when Section 9 applies.
Support access, correction and erasure exercised by parents and older pupils.
LMS, communication and analytics vendors are processors you must oversee.
Stand up verifiable parental consent and age assurance first.
The readiness check maps consent, age-assurance and vendor gaps.
Take the readiness check →Consultant-led and partner-backed.