Security & privacy
Privacy by design for children's data
Face templates are biometric personal data and most of our users are children. So we treat this as the most sensitive data there is: consent first, processing at the edge, minimal storage and full transparency.
- DPDP Act 2023 & Rules 2025
- Hosted in India
- AES-256 at rest
Controls
Twelve privacy-by-design controls
Each control is enforced in the product, not just written in a policy.
Consent before enrollment
A consent record (guardian, method OTP / DigiLocker / signed form, notice version, timestamp) must exist. Enrollment is blocked without it.
Opt-out alternative
Students without consent use RFID, QR or manual marking - the product works fully without face recognition.
Purpose limitation
Face data is used only for attendance and safety. No emotion or behaviour analytics on children, ever.
Data minimisation
We store encrypted face templates, not raw video. Video never leaves the edge. Snapshots are kept 7-30 days for disputes, then purged.
Encryption
Encrypted in transit and at rest; face templates encrypted with separate keys for each institution.
Access control
RBAC plus object scope: teachers see only assigned sections, parents only their children, the bus map only during trips.
Retention & deletion
Templates are deleted when a student leaves or consent is withdrawn - propagated to every edge device. Attendance kept per institution policy.
Rights handling
Parent portal: view data, download, request correction, withdraw consent and contact the grievance officer.
Breach handling
Incident runbook; the Data Protection Board and affected users are notified as required by the Rules.
Audit
Immutable audit log of every create, update, delete, login, export and every access to biometric data.
Data residency
Hosted in an Indian region (e.g. AWS Mumbai / Azure Pune) or an Indian data centre of your choice.
Anti-spoofing
Passive liveness at the gate and bus blocks photo and phone-screen proxies; uncertain matches go to human review.
India
DPDP Act 2023 & DPDP Rules 2025
What the law means for attendance and safety data - and how EduPresence is designed around it.
Research notes, not legal advice
Applies to every institution
The Digital Personal Data Protection Act, 2023 applies to schools, coaching centres and colleges processing personal data, including ERP and biometric-device data. The institution is the Data Fiduciary; EduPresence acts as its Data Processor.
A child is anyone under 18
That covers almost all school students and some first-year college students. Adult students and staff consent for themselves.
Section 9: verifiable parental consent
Processing a child's data needs verifiable consent of the parent or lawful guardian - free, specific, informed and withdrawable. Tracking or behavioural monitoring of children and targeted advertising are prohibited; EduPresence does neither.
DPDP Rules, November 2025
The Rules were notified in November 2025 with obligations phased in over roughly 18 months. Rule 10 deals with verifiable parental consent (for example DigiLocker-based tokens), which our consent flow supports alongside OTP and signed forms.
Outside India
GDPR (biometric data is a special category), COPPA/FERPA and state biometric laws such as Illinois BIPA apply in other markets and are planned per market.
Consent flow
How consent works, end to end
Consent is captured per purpose and per guardian, and can be withdrawn as easily as it was given.
- 1
Notice
The guardian receives a plain-language notice (versioned) explaining what is collected, why, retention, and their rights - in their language.
- 2
Verifiable consent
Consent is given per purpose (biometric face, photo use, communication) by OTP to the registered mobile, DigiLocker-based verification or a signed form.
- 3
Recorded
The record stores guardian, method, timestamp and notice version. Only then can the student be enrolled for face recognition.
- 4
Enrollment
5-10 images are converted into encrypted face templates. Raw images are deleted unless policy says otherwise.
- 5
Withdrawal at any time
One tap in the parent app withdraws consent; templates are deleted in the cloud and every edge device on the next gallery sync.
Encryption
Edge-first means less data to protect
- Video is processed on the campus edge box and the bus device - it never leaves the premises
- Only small attendance events (person, place, time) and optional short-lived thumbnails reach the cloud
- Face templates are encrypted numeric codes, not photos, with separate keys for each institution
- Campus devices keep their data encrypted; consent withdrawal removes templates everywhere
- Encryption for every connection and for all stored data, including on campus devices
- Highly sensitive fields such as Aadhaar get an extra layer of encryption
Technical safeguards
Retention
How long we keep what
Defaults below; institutions can shorten them in policy settings.
Data residency
Production data is hosted in Indian cloud regions (such as AWS Mumbai or Azure Pune) or in an Indian data centre. Enterprise customers can choose a dedicated deployment or on-premise installation.
Data Processing Agreement
Our DPA sets out processing purposes, sub-processors, security measures, breach notification and deletion on termination. Request a copy through the contact form.
Security reviews
Load tests, security audits and penetration testing are part of every major release cycle. Responsible disclosure: write to support@edupresence.example.
Grievance Officer
As required in India, you can contact our Grievance Officer about any privacy concern or data rights request. Parents can also raise requests from the parent portal.
- Name
- [Grievance Officer Name]
- Designation
- Grievance Officer / Data Protection Contact
- Phone
- +91 90000 00001
- Address
- Placeholder Address, Sector 00, City, State 000000, India
- Response time
- Acknowledgement within 48 hours; resolution within 30 days
Placeholder details - to be replaced before launch.
Works better together
Explore related modules
Attendance, leave, transport and alerts share one data model - so an approved leave quietly suppresses the absent and missed-bus alerts.
Questions from your management or parents?
We'll walk your team through consent, retention and our DPA - and join a parent meeting if that helps.
- Free campus survey
- Live in days without hardware
- Hosted in India