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GuideHeightened duties
Children's data under Section 9 of the DPDP Act
Heightened duties for teams building products that may process a child's personal data.
Data>Nuance
Section 9 addresses processing personal data of children. Products that are used by, aimed at, or reasonably likely to include children require deliberate assessment before launch.
Operational questions
- Can the service identify whether the heightened duty applies?
- What verifiable parental consent mechanism is appropriate?
- Could tracking, monitoring or advertising create prohibited risk?
- Are vendors and analytics tools aligned with the same restrictions?
A children's-data review should be built into product approval, not deferred until a complaint occurs.
This publication is general information and is not legal advice for a specific organisation or matter.