Personalisation is monitoringwith a better name.

Section 9(3) does not ask what you call it. It asks what you do.

In one line: Section 9(3) bars tracking, behavioural monitoring and targeted advertising directed at children, subject to exemptions notified in the Rules. Adaptive features must fit within an exemption or be redesigned.

The estate · EdTech & children's dataHover to inspect

The product watches the child. The law watches the product.

The scene

The engagement dashboard ranked students by ‘drop-off risk’: hesitation time, rewinds, late-night sessions. The sales team used the same signals to time upgrade offers to parents. Two teams, one data stream, one child.

Where the thinking breaks

The unclear thoughtWhat it breaksThe clearer thought
Learning analytics aren't tracking. Behavioural monitoring of children is restricted unless an exemption in the Rules applies. Identify the exemption for each signal, or stop collecting it.
Ads to parents aren't ads to children. Targeting built on a child's behaviour is still directed by that behaviour. Never let child telemetry feed commercial targeting.

Proctoring

Camera and screen monitoring during exams is behavioural monitoring. Where used, limit it to the exam, keep it no longer than the result needs, and never repurpose it.

Monday morning

  1. 01List every behavioural signal collected from under-18s.
  2. 02Mark which feed learning and which feed revenue.
  3. 03Cut the link between the two.

Questions, answered plainly

Does DPDPA ban adaptive learning for children?

Section 9(3) bars tracking, behavioural monitoring and targeted advertising directed at children, subject to exemptions notified in the Rules. Adaptive features must fit within an exemption or be redesigned.

Is online exam proctoring allowed under DPDPA?

Proctoring involves monitoring. For children it must fit the Section 9 framework and any Rules exemption, be limited to its purpose, and be secured and erased appropriately.

Sector · EdTechA child's data is not a cookie. Stop treating it like one.Read → EdTech & children's data · Deep diveA tick from a twelve-year-old is not a parent's consent.Read → EdTech & children's data · Deep diveThe exemption follows the purpose, not the product.Read →

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