Lesson 8.4: Exemptions for children’s data: Rule 12 and the Fourth Schedule
Some services need to process child data. Know the narrow exceptions. This DPDPA 2023 course page explains rule 12 and the fourth schedule in plain language.
What you will learn about rule 12 and the fourth schedule
- List the exempt classes
- Understand purpose limits
- Document reliance
What is exempt (rule 12 and the fourth schedule)
Certain classes, such as clinical establishments and healthcare professionals providing health services, educational institutions for educational activities and safety, childcare and transport providers for safety, may be exempt from parental consent and the tracking ban for specified purposes only. The Rules also allow processing where needed to confirm a person is not a child or to protect the child from harm.
Click each class
Select a numbered box to read more.
Limits (rule 12 and the fourth schedule)
| Point | Rule |
|---|---|
| Purpose | Only the listed purpose |
| Data | Only what is necessary |
| Duration | Only as long as needed |
| Records | Document why exemption applies |
Worked example
A school tracks bus location for safety. It does not use that data for ads or any other purpose.
Activity (5 minutes) (rule 12 and the fourth schedule)
If you rely on an exemption, write down the class and the purpose.
Check your understanding of rule 12 and the fourth schedule
Q1. Exemptions apply to:
Q2. A school bus tracker may:
Q3. Security duty during exemption:
Educational material for learning purposes, not legal advice. Check the official text of the DPDP Act, 2023, the DPDP Rules, 2025 and MeitY notifications for the latest position.
