Module 8: Children’s Data & Significant Data Fiduciaries
Special rules for anyone under 18 and the extra obligations for Significant Data Fiduciaries, including how AI-driven processing is touched. This DPDPA 2023 course page explains children’s data and significant data fiduciaries in plain language.
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Module 8 lessons (about 3 hours) (children’s data and significant data fiduciaries)
Read the lessons in order, like chapters of a book. Each has reading, a click-through diagram, an activity and a quiz.
What you will learn about children’s data and significant data fiduciaries
- Apply verifiable parental consent
- Know what is banned for children’s data
- List extra SDF duties
- Understand algorithmic due diligence
Children (Section 9)
A child is anyone under 18.
- Obtain verifiable consent of a parent or lawful guardian before processing
- No processing likely to harm the child’s well-being
- No tracking, behavioural monitoring or targeted advertising directed at children
- The Rules list classes of fiduciaries and purposes that are exempt, for example some healthcare and education uses
Significant Data Fiduciaries (Section 10) (children’s data and significant data fiduciaries)
Notified by the Government. Extra duties:
- Appoint a Data Protection Officer based in India who reports to the board
- Appoint an independent data auditor
- Carry out periodic Data Protection Impact Assessments and audits
- Follow algorithmic due diligence under the Rules
What about AI and automated decisions?
DPDPA has no standalone right against automated decisions. Accuracy, security, consent and SDF algorithmic checks still apply to AI systems that use personal data.
Children’s data is treated as high risk: verify the parent, and do not track or target the child.
Check your understanding of children’s data and significant data fiduciaries
Q1. In DPDPA, a child is someone under…
Q2. Which is prohibited for children’s data?
Q3. Which is an extra duty of an SDF?
Quick FAQs (children’s data and significant data fiduciaries)
How do we verify a parent?
The Rules allow methods such as reliable details already held, or a digital token from an authorised source.
Are schools covered?
Yes, though some educational uses are exempt within the limits in the Rules.
Do it yourself: practical guides
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.