Children’s Privacy Online: Can Verification Avoid Creating New Risks?

Arnold Masih
Arnold Masih
Intern, Policy & Advocacy, CyberPeace
PUBLISHED ON
Nov 3, 2026
10

Introduction

A child joining a learning platform may encounter a request for approval. I see that the step appears straightforward. The step raises a difficult question: how should the service verify consent without gathering unnecessary information about the family? India’s Digital Personal Data Protection Rules, 2025 provide mechanisms for parental consent with the relevant requirements subject to phased commencement. This creates an opportunity to examine how protection should work in practice. Verification can support accountability while designed systems could introduce additional collection and security risks. The policy challenge is to make consent meaningful while limiting exposure during the verification process. I think that consent should be clear and easy to give. Children’s privacy will depend on the design of the service well as the procedure used to obtain approval.

  • Understanding the Legal Framework

The Digital Personal Data Protection Act 2023 says a child is someone who's under eighteen years old. Section 9 creates a plan about permission, harmful processing, tracking, watching behavior and ads aimed at children plus some exceptions.

Rule 10 in the 2025 Rules explains how to get confirmed permission. It says that the person who says they are the parent must be an adult who can be identified using identity and age information or special digital codes.

Starting to use the rules needs explanation. Rule 1 says that Rules 3 5 to 16, 22 and 23 will begin after eighteen months from the day they are published. Rule 10 is part of that group. People who write about this should make sure to separate the framework from rules that are already in place.

This difference also helps companies get ready properly. Putting the rules into action means making choices, about alerts, checking identities, keeping data letting people see it and handling complaints. Looking at the framework as something to design gives advantage rather than just making compliance about clicking one button.

  • Consent and Age Checks Serve Different Purposes

Determining whether a user is a child and verifying the adult who provides consent are tasks but these tasks answer different questions. A service may need to understand which safeguards apply to an account. The service must separately consider whether its consent process meets the requirements.

For example, a hypothetical learning service might already hold adult identity information, for a parent who pays for an account. Another family may approach the service for the time. These circumstances raise implementation questions even when both families want the same educational access.

Designers should map these situations before choosing a verification process. Designers should identify what each check establishes, what remains uncertain and what evidence is necessary. Collecting documents without a clear purpose can complicate the process without resolving the underlying issue. A careful system should be able to explain why information is requested and how it contributes to the verification task.

  • The Privacy Cost of Verification

Verification can create a tension between feeling safe and being exposed. A service that wants to be sure about a person’s age may think about asking for identity information. The process should also look at whether keeping that information creates risks that go beyond the original purpose.

Consider a platform that keeps full document images forever after it finishes a check. The policy concern for Verification is whether the ongoing exposure is justified by a continuing need. Verification of a result and an entire identity document are kinds of information and they have different consequences if they are accessed improperly.

Privacy‑conscious design, for Verification should therefore look at collection and retention separately. Verification teams should ask what information must be received, what evidence must stay, who needs access and when deletion is appropriate following legal rules. Verification should not become a chance to build profiles. Verification safeguards should be checked before a system becomes routine when fixing a wide design may be harder.

  • Making Protection Accessible to Families

Even if a process is technically sound it can still leave people out when it assumes that every parent owns a smartphone, has the internet and feels confident using digital identity services. The policy objective must provide a route that fits families with varied circumstances and abilities

Services should give explanations that anyone can understand, offer language options that suit each user and give help when verification fails. A clear error message should show a person what to do keeping sensitive details private. If a person keeps failing the process should trigger a review rather than an unexplained rejection.

Children also need to understand. Parental consent alone does not remove the need to explain things to the child. A service can use age‑appropriate language to tell the child what data it collects and how the child can get help. The design must not push families to approve. An accessible process offers everyone a chance to grasp the decision and finish it without extra pressure or confusion.

  • Moving Beyond the Consent Screen

Consent is one part of a safety architecture. A platform should also look at the experience that happens after someone agrees. Which features are turned on what information other people can. Whether the design pushes someone to share more than they need to.

A pretend educational app might need a child's progress detail to give lessons. That does not mean every extra social feature should be turned on automatically. Teams that make products should check each feature on its own. Tell people why it is there instead of thinking that saying yes once means all future choices are settled.

Moving between accounts needs thinking about too. Services should think about how information and permissions will be checked as users get older and their lives change. They should also make it clear how to fix mistakes or report problems. Good management means people inside a company have to take charge of these choices. A privacy statement by itself cannot show if the real service matches the promises, in the written rules.

Conclusion

Children’s privacy needs to be protected through a balance between legal rules and everyday choices made by product creators. The DPDP framework offers a foundation for looking at parental consent. Putting it into practice also means thinking about fairness, how easy it is for people to use and how verification data is handled. Services should explain clearly what they need, why they need information and how they will keep data exposure to a minimum. When something goes wrong in the process families should get explanations and real help. Kids should not face a risky experience. Instead, the design should put children’s being first. Ultimately success means that verification helps make the service safer, without compromising the privacy of the children it is meant to protect.

References

  1. https://www.meity.gov.in/static/uploads/2024/06/2bf1f0e9f04e6fb4f8fef35e82c42aa5.pdf
  2. https://www.meity.gov.in/static/uploads/2025/11/53450e6e5dc0bfa85ebd78686cadad39.pdf

‍

PUBLISHED ON
Nov 3, 2026
Category
TAGS
No items found.

Related Blogs