DPDP Act 2023: Understanding Lawful Grounds of Data Processing for Playschools

Make Your Playschool’s Data Practices DPDP-Ready

Playschools handle some of the most sensitive personal data in society. Every admission form, photograph, daily update, or medical note relates to a very young child who cannot understand or consent to how their information is used.

India’s Digital Personal Data Protection Act (DPDPA) 2023 recognises this vulnerability. It clearly defines when and on what basis personal data can be processed. For playschools, understanding these lawful grounds is essential, not as a legal exercise, but as part of responsible child care.

This blog explains the lawful grounds of data processing under DPDPA in simple terms, specifically for playschools.

Why Playschools Must Be Extra Careful About Data Processing

In a playschool, children are entirely dependent on adults to protect them—both physically and digitally. Every piece of data collected creates responsibility.

Playschools routinely process:

• Child identity and admission details
• Parent and guardian contact information
• Photographs and videos
• Health, allergy, or medical notes
• Daily activity and behavioural observations

DPDPA makes it clear that processing children’s data must always be justified. “We have always done it this way” is no longer a valid reason.

Consent: The Primary Ground for Processing Children’s Data

For playschools, parental consent is the most common and important lawful ground for processing data.

Consent must be:

• Clear and understandable
• Specific to the purpose (photos, communication, apps, etc.)
• Given by a parent or lawful guardian
• Capable of being withdrawn

Consent cannot be hidden inside long admission forms or assumed through silence. Parents must know exactly what they are agreeing to.

In playschools, consent is not paperwork—it is a trust agreement with families.

Processing Data for Admission and School Administration

Certain data is processed because it is necessary for the child’s admission and day-to-day functioning of the playschool.

This includes:

• Name, age, and date of birth
• Parent contact details
• Emergency information
• Attendance and basic records

DPDPA allows processing when data is required to fulfil legitimate school functions, as long as it is limited, relevant, and secure.

Playschools must still ensure they do not collect more data than needed or keep it longer than required.

Processing Data for the Child’s Safety and Well-Being

Playschools often process data to protect a child’s health and safety. This may include allergy information, medical conditions, emergency contacts, or security footage.

DPDPA permits such processing because it is necessary to protect the child’s vital interests. However, this data must be handled with heightened confidentiality, limited access, and clear retention practices.

Safety-related data should never be reused for unrelated purposes.

Why Photo and Video Processing Requires Explicit Consent

Photos and videos are among the most sensitive forms of children’s data. While parents enjoy receiving updates, DPDP treats images as personal data that can affect a child’s dignity and long-term digital footprint.

Playschools must process photos and videos only with clear parental consent and only for the specific purpose stated.

Bulk sharing, informal messaging groups, or reuse of images beyond the agreed purpose are not aligned with DPDP expectations. Controlled, purpose-limited sharing is essential.

When Processing Without Consent Is Not Allowed

A critical takeaway for playschools is this:

If there is no clear purpose, no consent, and no safety necessity, the data should not be processed.

DPDPA does not allow playschools to:

• Collect data “just in case”
• Use children’s data for marketing or promotion without consent
• Share data with third parties without justification
• Retain old photos or records indefinitely

Every data action must have a lawful ground.

Why Understanding Lawful Grounds Protects Playschools

When playschools understand why they process data, compliance becomes natural.

Clear lawful grounds:

• Reduce parent complaints
• Prevent accidental misuse
• Strengthen trust
• Protect the institution during audits or inquiries
• Help staff make confident decisions

Instead of guessing what is allowed, staff act with clarity.

Process Data Only When It Serves the Child

DPDPA 2023 sends a clear message to playschools: children’s data is not a resource to be used freely—it is a responsibility to be protected carefully.

By processing data only when there is clear consent, necessity, or safety justification, playschools honour both the law and the trust parents place in them.

Lawful processing is not a restriction. It is responsible early education.

Understand lawful data processing, set up clear consent workflows, and protect children’s data with confidence. Book a Free Playschool DPDP Consultation