Children's data is where casual product design stops being casual.

Children's data readiness under the DPDP Act

Children's data readiness under the Digital Personal Data Protection Act, 2023 is not only an age-gate question. It asks whether the business knows when a user may be a child, what personal data is collected, how parental consent is handled, which features use behavioural signals, and whether teams can prove the choices made in product, support and marketing.

For apps, platforms, edtech tools, gaming products, marketplaces and community features, the hard part is operational. A policy may say that children are treated carefully, but product flows, analytics settings, notifications, support scripts and vendor tools may still behave as if every user is an adult. Readiness means aligning the actual experience with the compliance position.

What to review

Start with user journeys that may involve children. Review sign-up, onboarding, profile creation, classroom or parent accounts, family plans, referrals, contests, chat, community features, rewards, targeted content, analytics and advertising integrations. A child-risk review should include both obvious child-facing products and general products with meaningful child usage.

Review how the business identifies child users. The DPDP Act treats a child as an individual below eighteen years of age. That does not mean every product should collect date of birth without thought. Teams should decide when age information is necessary, what level of assurance is proportionate, and how to avoid collecting more personal data than the feature requires.

Check consent and guardian flows. Where parental or lawful guardian involvement is required, the business should know what evidence is captured, how consent is linked to the child account, how withdrawal works, and what happens if the parent-child relationship changes or cannot be verified.

Implementation steps

Create a children's data map. List the data categories, collection points, purposes, systems, vendors, retention periods and feature owners for users who may be children. Include support tickets, learning records, gameplay data, device identifiers, analytics events, communication logs and uploaded content where relevant.

Separate age assessment from parental consent. Age assessment asks whether the user may be a child. Parental consent asks whether an appropriate adult has authorised processing where required. These are connected, but they are not the same control. Mixing them leads to weak records and confusing support responses.

Review product features for higher-risk uses. Teams should examine profiling, behavioural monitoring, targeted advertising, nudges, public posting, direct messaging, location features, rewards and third-party SDKs. If the product cannot explain why a feature is appropriate for child users, it should be paused, limited or redesigned before launch.

Build support and escalation scripts. Support teams need plain-language guidance for parent requests, account correction, deletion, consent withdrawal, suspected child accounts and complaints about harmful or inappropriate processing. Sensitive cases should move to a privacy or trust-and-safety owner quickly.

Keep evidence records. The readiness file should include the data map, age-assessment logic, consent flow, vendor checks, feature decisions, retention rules, training notes and issue log. This record helps the business show that children's data was addressed as a product and governance issue, not as a last-minute privacy-policy paragraph.

Common mistakes

• Treating an age gate as the whole compliance programme, while leaving analytics, advertising, chat and support flows unchanged.
• Collecting excessive identity or age proof from all users without deciding whether that level of collection is necessary.
• Recording parental consent without linking it to the exact child account, purpose, withdrawal path and evidence trail.

How DataNuance can help

DataNuance helps teams assess children's data risks across product, support, vendors and governance. We review age-assessment flows, parental consent design, child-user data maps, feature risk decisions, support scripts, training material and evidence records. The aim is a practical readiness model that product teams can maintain as features change.

For a children's data readiness review under the DPDP Act, contact DataNuance.

FAQs

Does every app need to collect date of birth?

No. The right approach depends on the product, likely users, risk level and feature design. Some teams may need explicit age checks; others may need a lighter assessment, clear restrictions or separate child-facing flows.

Is parental consent enough for all child-user processing?

No. Consent is only one part of readiness. Teams should also review purpose limitation, data minimisation, feature design, vendor tools, retention, support workflows and whether certain product behaviours should be restricted for child users.

What teams should be involved in children's data readiness?

Product, engineering, privacy, legal, security, support, marketing and vendor management should all be involved. Children's data controls often fail when they are treated as only a legal or policy task.

How often should the children's data review be refreshed?

Refresh it before major feature launches, new SDKs, new marketing integrations, new user journeys or expansion into child-heavy segments. A quarterly review is sensible for products with active child-user risk.

Sources

Digital Personal Data Protection Act, 2023, Ministry of Electronics and Information Technology official copy.

Digital Personal Data Protection Rules, 2025, Ministry of Electronics and Information Technology official copy.