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Rule 12, children's data exemptions

Rule
12
Instrument
DPDP Rules 2025
Source
G.S.R. 846(E), 13 Nov 2025
Commencement
Rule 1(4) group
Last reviewed
15 August 2026

In short

Rule 12 disapplies sub-sections (1) and (3) of Section 9 of the Act in two situations: for the classes of Data Fiduciary specified in Part A of the Fourth Schedule, and for the purposes specified in Part B. Each is subject to the conditions stated in the relevant Part.

The exemption is from those two sub-sections only. The rest of Section 9 continues to apply.

01Part A, classes of Data Fiduciary

ClassCondition
Clinical establishment, mental health establishment or healthcare professionalProcessing restricted to provision of health services to the child by that establishment or professional, to the extent necessary for the protection of her health
Allied healthcare professionalProcessing restricted to supporting implementation of a healthcare treatment and referral plan recommended by that professional for the child, to the extent necessary for the protection of her health
Educational institutionProcessing restricted to tracking and behavioural monitoring for the educational activities of the institution, or in the interests of the safety of children enrolled with it
Individual in whose care infants and children in a creche or child day care centre are entrustedProcessing restricted to tracking and behavioural monitoring in the interests of the safety of children entrusted to that care
Entity engaged by an educational institution, creche or child care centre for transport of enrolled childrenProcessing restricted to tracking the location of those children, in the interests of their safety, during travel to and from the institution, creche or centre

02Part B, purposes

PurposeCondition
Exercise of a power, performance of a function or discharge of a duty in the interests of a child under any law in force in IndiaRestricted to the extent necessary for that exercise, performance or discharge
Providing or issuing a subsidy, benefit, service, certificate, licence or permit in the interests of a child under Section 7(b) of the ActRestricted to the extent necessary for that provision or issuance
Creation of a user account for communicating by emailRestricted to the extent necessary to create the account, the use of which is limited to email communication
Determination of the real time location of a childRestricted to tracking real time location in the interest of her safety, protection or security
Ensuring that information, a service or an advertisement likely to cause a detrimental effect on the well being of a child is not accessible to herRestricted to the extent necessary to ensure inaccessibility
Confirmation by the Data Fiduciary that the Data Principal is not a child, and observance of due diligence under Rule 10Restricted to the extent necessary for that confirmation or observance

The condition column is the operative half of both tables. An entity in a listed class that processes beyond the stated restriction is outside the exemption for that processing.

03Common questions

Which obligations does Rule 12 lift?

Sub-sections (1) and (3) of Section 9 of the Act, and only those, subject to the conditions in the Fourth Schedule.

Can a platform process a child's data to check she is not a child?

Part B lists confirmation that a Data Principal is not a child, and observance of due diligence under Rule 10, as an exempt purpose, restricted to the extent necessary.

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