Children's Consent Under the DPDP Act: What Product & Compliance Teams Need to Know

Under the Digital Personal Data Protection (DPDP) Rules in 2025, enterprises processing the personal data of children are required to obtain parental consent before collecting or using that data. As enterprises continue to enhance their privacy programs under the DPDP Act, one area that requires particular attention is the handling of children's personal data.

Consumer-facing businesses across industries, such as education, healthcare, gaming, and digital platforms, generally interact with users below the age of 18. This changes how businesses design digital onboarding journeys, user verification, consent workflows, and ongoing governance.

As enterprises focus on implementation, teams must work together to build processes that support children's privacy while delivering a smooth digital experience.

Why Children's Data Requires a Different Compliance Approach

Children may not fully know how their personal information is collected, shared, or retained by businesses, this is the reason why privacy regulations typically provide additional security when organizations process children's data.

According to the Government of India, processing children's personal data requires parental consent intended to protect children's interests. In such a case, the DPDP Act follows this rule by holding Data Fiduciaries responsible for handling information belonging to individuals under 18 years old.

Here’s why businesses should not rely completely on adding another checklist to a single consent option during registration. Instead, they need a consent governance framework that verifies the age of individuals under 18 years of age, confirms parental authorization when necessary, and maintains evidence throughout the consent lifecycle.

Also Read: Why the DPDP Act Transition Window Matters for Privacy & Consent Teams

Understanding Verifiable Parental Consent

As per the latest rules, the DPDP Act requires enterprises to obtain consent from parents or legal guardians before processing a child's personal data. “Verifiable” means the Data Fiduciary must use appropriate technical and organisational measures to confirm that the person giving consent is an adult (18+) and is the parent or lawful guardian of the child, for example, by using reliable identity details already held, or government backed identity checks where legally available.

Creating Simple & Secure Consent Journeys

Enterprises should focus on creating simple yet secure consent workflows that:

• Identify potential child users
• Request parental details (where required)
• Initiate parental verification
• Collect verifiable consent before activating services and record every consent event

Purpose-specific consent requests also improve transparency for parents making privacy decisions on behalf of their children.

Also Read: Digital Privacy in Digital Platforms: Protecting Buyer Data Across Checkout, Payments, and Support

Operational Challenges for Product and Compliance Teams

Complying with children's consent requirements involves more than legal documentation and affects multiple operational processes across digital platforms.

While this approach might be suitable in some cases, it is essential for organizations to evaluate whether stronger verification methods are necessary, based on their business model, customer base, and the level of privacy risk involved.

Product teams should design onboarding journeys that determine whether additional parental consent is necessary before collecting personal information.

Maintaining Reliable Consent Records

Obtaining children's consent creates additional governance responsibilities throughout the customer relationship. Enterprises should maintain records that include:

• Parent or legal guardian verification details
• Consent purpose
• Date and time of consent
• Version of the privacy notice
• Updates or withdrawals
• Retention timelines

Comprehensive audit records demonstrate that consent was captured and managed appropriately if questioned during internal reviews or regulatory assessments.

Also Read: How a Consent Management And Monitoring System Keeps You Audit-Ready in India

Why User Experience Matters in Children's Consent

If parental verification becomes complex, users may leave the onboarding process before completing registration. Compliance must avoid unnecessary friction for legitimate users.

Product teams can balance compliance by:

• Providing simple instructions
• Explaining why parental consent is necessary
• Minimizing unnecessary information requests
• Keeping verification steps transparent
• Allowing parents to manage consent preferences easily

A clear and straightforward experience helps improve trust and meets regulatory requirements.

Consent Governance Should Continue Beyond Registration

Obtaining parental consent is only the first stage in compliance. Enterprises should also establish governance processes for the following:

• Consent Renewal: Consent should remain current and, where necessary, aligned with applicable policies.
• Withdrawal Management: Parents should have simple access to withdraw previously granted consent where applicable.
• Data Retention: Children's personal data should not be retained longer than the necessary duration for the stated purpose.
• Access Requests: Organizations should be prepared to respond appropriately to lawful requests relating to children's personal information.

Manually managing these activities across multiple applications can become increasingly difficult as customer volumes grow.

Building Enterprise-Ready Children's Consent Governance

A centralized governance approach helps enterprises maintain consistency across customer journeys. As they expand across websites, mobile applications, partner ecosystems, and digital services, children's consent often becomes fragmented across multiple systems. Key practices include:

• Implement Purpose-Based Consent: Collect parental consent separately for each clearly defined purpose instead of combining unrelated permissions.
• Synchronize Consent Across Systems: Consent updates should be synchronized across customer-facing platforms, marketing systems, and operational applications.
• Maintain Complete Audit Trails: Every consent interaction should be timestamped and securely recorded to support compliance evidence.

Conclusion

As organizations continue to implement the Digital Personal Data Protection (DPDP) Act following the regulatory guidance issued in November 2025, greater attention is being given to how children's personal data is collected, managed, and protected.

Compliance extends beyond obtaining parental permission during registration. Organizations should establish processes for age verification, parental authorization where applicable, consent record management, and governance of children's personal data throughout its lifecycle.

As privacy programs mature, enterprises with clear governance processes, user-friendly consent journeys, and centralized controls will be better positioned to meet regulatory requirements and build customer trust.

Enterprises can create safer digital experiences and improve long-term privacy readiness by treating children's consent as an ongoing governance process rather than a one-time compliance task.

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