Schools, kindergartens and tuition centres handle personal data every day, not only from students, but also from parents and guardians.
Where children are involved, expectations are naturally higher, and education providers should take compliance with the Personal Data Protection Act 2010 (PDPA) seriously, and this guide explains the practical PDPA obligations that they should understand.
Must education institutions register under PDPA?
Mandatory registration applies to organisations falling within the prescribed Education Sector, which includes:
- private schools or private educational institutions registered under the Education Act 1966
- private higher educational institutions registered under the Private Higher Educational Institutions Act 1996
Other education centres are not automatically subject to mandatory registration but still need to comply with the general obligations under the PDPA when handling personal data.
If you are unsure whether your organisation is required to register, you may refer to our step-by-step guide on data controller registration.
Do you need a Data Protection Officer?
Some larger education groups may process large volumes of student and parent data. This may be relevant for:
- multi-branch centres
- franchised tuition brands
- operators using large online learning systems
Where applicable thresholds or regulatory expectations apply, appointment of a Data Protection Officer (DPO) should be assessed. If you are unsure whether your organisation requires a DPO or how to appoint one, you can refer to our guide on DPO requirements and responsibilities.
Why education providers face higher risk
Education providers often handle personal data relating to minors (individuals below 18 years old).
This creates higher privacy risk because children may not fully understand how their personal data is collected, used, or shared. As a result, schools, kindergartens and learning centres should take extra care when handling student information. Where personal data relates to a minor, consent should be properly obtained from a parent or legal guardian.
Compliance across daily operations
Student registration
Most educational institutions collect personal data at the point of registration or enrolment to properly manage student records and ensure safety. This typically includes student details, parent or guardian information, emergency contacts, and relevant health alerts such as allergies. Since minors are involved, the responsibility to handle this data carefully is even higher.
Practical point:
- Inform parents what data is collected
- Explain why the data is needed
- Clarify who the data may be shared with
- Provide a contact point for privacy-related matters
- Use a clear privacy notice to support compliance
Attendance, results and internal records
Schools and education centres maintain ongoing records throughout a student’s time with the institution. These records support academic tracking, behavioural monitoring, and overall student development, and may include attendance logs, progress reports, exam results, behavioural notes, and counselling records.
Practical point:
- Restrict access to student records to staff who need the information
- Ensure not all employees have unrestricted access to sensitive data
CCTV and safety monitoring
CCTV systems are commonly used in schools and centres to enhance safety and security. While generally acceptable, their use must be responsibly managed to avoid unnecessary intrusion into privacy. Proper safeguards should be in place to ensure recordings are handled appropriately.
Practical point:
- Notify parents and visitors that CCTV is in use
- Avoid placing cameras in sensitive areas
- Secure recorded footage properly
- Limit access to authorised personnel only
Photos, events and social media
Capturing and sharing photos or videos of students is a common practice during school events, classes, and promotional activities. However, this is also one of the highest-risk areas for misuse of personal data . Examples include graduation photos, class activity videos, performances, and social media content.
Practical point: Obtain clear parental consent before using student images publicly
WhatsApp groups and communications
Many schools and tuition centres rely on messaging platforms like WhatsApp, apps, or learning systems to communicate with parents and students. While convenient, these channels can easily lead to accidental data exposure if not handled carefully, particularly in group settings.
Practical point:
- Avoid discussing individual student issues in group chats
- Do not casually circulate student records
- Double-check recipients before sending score reports or sensitive information
- Avoid recording online classes without proper notice or controls
- Use structured and controlled communication methods where possible
Student pickup risk
Student pickup arrangements involve both personal data and physical safety considerations, making them a sensitive operational area. Situations such as authorised pickup lists, last-minute changes, collections by relatives or helpers, and custody-related issues require careful handling to prevent mistakes or unauthorised disclosures.
Practical point:
- Implement clear procedures for verifying authorised pickup persons
- Ensure staff do not disclose collection arrangements to unauthorised individuals
- Handle special cases, such as custody disputes, with extra care and documentation
Retention and security of records
Educational institutions often retain student records for extended periods for administrative, legal, and academic purposes. However, proper systems should be in place to ensure that data is not stored indefinitely without review, and that both physical and digital records remain secure throughout their lifecycle.
Practical point:
- Store physical files in locked cabinets
- Password-protect digital systems
- Limit staff access based on roles
- Periodically review and manage old records
- Dispose of outdated files securely
PDPA compliance checklist
At a minimum, education providers should:
- assess registration obligations
- implement a clear privacy notice
- obtain proper parental consent
- control access to student records
- adopt safe communication practices
- secure physical and digital files
Good data practices build trust with parents and strengthen professionalism.
PDPA compliance in 90 days with ELP
If your business requires assistance in reviewing data protection practices, preparing privacy notices, or developing PDPA compliance frameworks, our team at ELP can help ensure your organisation’s data handling practices align with the requirements of the PDPA
