SC-008·critical·Component: Scope & ClassificationWhat this control requires
Implement technical and procedural controls to: (a) verify age before processing personal data (date-of-birth validation with system enforcement); (b) obtain verifiable parental/guardian consent for under-18 data subjects; (c) prohibit behavioural tracking, monitoring, and targeted advertising directed at children; (d) restrict processing likely to cause detrimental effect to child well-being. Objective: Protect children's personal data from unlawful processing and ensure verifiable parental consent is obtained before any processing of child data commences.
In plain English
Implement technical and procedural controls to: (a) verify age before processing personal data (date-of-birth validation with system enforcement); (b) obtain verifiable parental/guardian consent for under-18 data subjects; (c) prohibit behavioural tracking, monitoring, and targeted advertising directed at children; (d) restrict processing likely to cause detrimental effect to child well-being. In practice, this means you can prove you implement children's data processing controls-level controls on a defined cadence.
Why it matters
Penalties under the DPDP Act reach ₹250 crore per instance of significant non-compliance, and the Act applies extra-territorially to any entity processing personal data of individuals in India in connection with offering goods or services.
This control is rated critical in the source catalogue. Treat gaps here as production incidents in the risk register, not housekeeping.
What an auditor looks for
Indian DPAs and statutory auditors will look for: documented consent capture and revocation flows, a designated Data Protection Officer (for Significant Data Fiduciaries), breach-notification workflows tied to Data Protection Board notification timelines, and Records of Processing that match the consent notice the user saw.
Within Scope & Classification, the assessor will trace your implementation back to the catalogue reference (Control SC-008) and look for objective evidence on the latest two assessment cycles.
How to implement
Policy Management
Docs. Keep each policy in version-controlled Markdown alongside the code that implements it; ship a signed PDF snapshot at each annual review and link the SHA into the SoA.
Asset Inventory
AWS. AWS Config Aggregator across every account + region gives a real-time inventory; ship the daily snapshot to S3 and surface drift in Security Hub.
Azure. Azure Resource Graph plus Defender for Cloud's inventory blade enumerates every subscription; export to Log Analytics for retention and Workbooks for reporting.
GCP. Cloud Asset Inventory exports a daily feed of every resource and IAM binding; query via BigQuery and alert on appearance/disappearance.
Endpoints. Pipe MDM telemetry (Intune / Jamf / Workspace ONE) into your CMDB so laptops and phones are inventoried with the same rigour as cloud resources.
Operational checklist
- Implement. Document the trigger, the owner and the cadence.
- Ensure. Document the trigger, the owner and the cadence.
- Monitor. Document the trigger, the owner and the cadence.
- Scope: children's data processing controls.
Evidence to collect
- Policy Document. A signed and version-controlled policy / standard / procedure document.
Signed policies, procedures, and registers document the safeguard. Focus: Children's Data Processing Controls.
Common pitfalls
- Policies that no engineer has read; the version in Confluence drifts from the version that's actually being enforced.
- Inventories that exclude SaaS, shadow IT and ephemeral cloud resources (Lambda, Cloud Run, K8s pods) miss the assets where most modern incidents start.
How it maps to other frameworks
Computed from shared tags, control component and key-operation subjects — handy when you are reconciling controls across an audit.
- ISO/IEC 27701:2025 A.1.2.9 — Records related to processing PII
- GDPR Article 14 — Information to be provided where personal data have not been obtained from the data subject
- SOC 2 (2017 TSC) P2.1 — Communication of Data Subject Choices and Consequences
Related controls in India DPDP Act 2023
- Control SC-007 — Lawful Processing Matrix
- Control SC-001 — Digital Personal Data Inventory
- Control SC-003 — Data Fiduciary Role Assignment & ROPA
- Control SC-005 — Data Processor Register & DPA Management
- Control SC-002 — Data Principal Identification & Guardian Consent Management
- Control SC-004 — Significant Data Fiduciary (SDF) Self-Assessment
References
- Ministry of Electronics and Information Technology (India) — India DPDP Act 2023
- Catalogue identifier:
Control SC-008
Topics: governance riskdata protectionprivacy managementpolicy managementasset inventory