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 ActsAn LMS is usually a Processor for the institution that deploys it, and a Fiduciary for its own accounts.
In short
Where children are the end users, Section 9 flows through the LMS: verifiable consent, no behavioural monitoring, and airtight processor terms. Children-data penalties reach ₹200 crore.
What changes for this sub-sector.
Map where you are a processor for an institution and where you are a fiduciary for your own users.
If pupils use the LMS, the Section 9 protections apply; build them in, do not assume the client handles it.
Behavioural learning analytics on minors sits in a grey area the Board is expected to test; be conservative.
Give institutions the tools and records to obtain and evidence verifiable parental consent.
Protect pupil data with strong access control and encryption.
Disclose and control the vendors your LMS relies on.
Clarify your role and build consent pass-through first.
The readiness check maps role, consent-passthrough and analytics gaps.
Take the readiness check →Consultant-led and partner-backed.