Designing DPDP-Compliant Sign-Up Flows

What DPDP expects from a “notice”


Your notice must be:

  • standalone (understandable independently of any other information),
  • written in clear, plain language, and
  • include at minimum:
    • an itemised description of the personal data you’ll process, and
    • the specified purpose(s) and the service/use enabled by that processing.

It must also provide:

  • the link/means to withdraw consent (as easy to withdraw as it was to give),
  • the link/means to exercise rights, and
  • the link/means to complain to the Board.

The golden rule for EdTech UX: “Just-in-time notices”

Instead of one long privacy notice at sign-up, use short notices at the exact moment you need data. This improves consent quality and reduces drop-offs.

Recommended “notice moments” in EdTech

  1. Account creation (student/parent/teacher)
  2. Profile completion (class, board, interests, location)
  3. Payments (billing and transaction identifiers)
  4. Marketing opt-in (WhatsApp/SMS/email updates)
  5. Camera/Mic access (classes, doubt sessions, proctoring)
  6. Sharing with third parties (video hosting, analytics, CRM, proctoring partners)

Each notice should clearly state:

• what data is collected now
• why it’s needed now
• what the user gets now
• how to withdraw / manage consent (one tap)

What is a “user account” in DPDP Rules (and why it matters)

DPDP-compliant sign-up flows (recommended patterns)

Screen 1: Choose account type

  • Student (18+)
  • Parent/Guardian
  • Teacher/Tutor
  • Institution Admin

Screen 2: Minimal sign-up

  • Mobile/email + OTP
  • Name (optional until later)

Notice block (must-have)

  • Itemised data: mobile/email, device identifiers (if any), basic profile fields
  • Purpose: account access, course access, support communications
  • Links: withdraw consent / rights / complaint path

Screen 3: Consent controls

  • Required: account + service communications
  • Optional toggles: marketing, personalisation, analytics cookies (where applicable)

If the user is a child, you must ensure verifiable parental consent before processing the child’s personal data.

Recommended flow

  1. Child enters basic info → selects “I’m under 18”
  2. Parent verification step begins
  3. Parent reviews notice + gives verifiable consent
  4. Only then: child account is created / activated

Implementation note: Don’t allow a “full account” creation for a child until the parent step is completed.

This is often the lowest-friction model.

Recommended steps

  1. Parent signs up first (OTP)
  2. Parent sees a child-account notice + consent screen
  3. Parent adds child profile (only necessary fields)
  4. Parent dashboard: manage consent, withdraw, requests

The Rules also describe practical methods to verify parent/adult status (reliable identity+age details, authorised checks, virtual token, Digital Locker route).

For teachers, the highest risk is “over-broad access” to student data.

Recommended steps

  1. Teacher sign-up (minimal)
  2. Teacher verification (institution email, admin approval, or document check as per your policy)
  3. “Teacher Notice” specific to:
    • what student data they can see
    • purpose: teaching, doubt support, grading

Role-based access enforced technically (not policy-only)

Mandatory links you must publish

You should prominently publish:

Your notice must be:

  • how users can make rights requests, and
    what identifier you need (username / enrolment ID / email / mobile etc.).

You must also publish a grievance timeline not exceeding 90 days and implement measures to meet that timeline.

Practical UX tip

Put these links in:

– Sign-up notice footer (“Manage consent / Rights / Grievance”)

– App settings → “Privacy & DPDP”

– Help/Support page

What your sign-up notice should contain

  • (Example) Mobile number / email
  • Name (optional)
  • Role (student/parent/teacher)
  • (Optional) City/state, class/grade (if collected at sign-up)
  • Account access and authentication
  • Course enrollment and learning access
  • Important service updates and support
  • Marketing messages (optional toggle)
  • Personalisation (optional toggle)
  • Withdraw consent anytime (link)
  • Request access/correction/deletion etc. (link)
  • Raise grievance (link)
  • Complain to Board (link)

High-risk EdTech screens

Implementation blueprint

Minimum backend objects (recommended)

  • NoticeVersion (versioned text + language + effective date)
  • ConsentLedger (append-only events: asked / given / withdrawn)
  • UserRole (student/parent/teacher)
  • ChildLink (child ↔ parent relationship)
  • GrievanceTicket (SLA timer up to 90 days)

Minimum logs to keep (audit-friendly)

  • Notice version shown + timestamp
  • Consent action + timestamp
  • Channel used (app/web)
  • Withdrawal history

Quick compliance checklist

  • Sign-up notice is standalone + plain language + itemised data + specified purpose
  • Withdrawal is as easy as giving consent
  • Rights request mechanism and identifier requirements are published
  • Grievance timeline ≤ 90 days and operational measures exist
  • Under-18 flow triggers verifiable parental consent before processing child data

Need these screens designed?

We deliver: UX copy + notice versions + consent ledger spec + parent consent flow + audit-ready evidence pack.