Sector reference
DPDP for School and Child Transport
- What is processed
- Where a child is during the journey to and from school, tracked for her own safety.
Why it is allowed, and when
A transport provider that the school, creche or centre has engaged to carry enrolled children may track where those children are during that journey, without a parent being asked each time.
Where the permission stops
It is scoped to the journey. It does not cover tracking outside it, and it does not cover keeping or reusing the trail afterwards for something else.
Questions people actually ask
Do I have to give consent for my child to be tracked on the school bus?
For that specific tracking, no. The exception removes both the need for a parent's consent and the general ban on tracking children.
But it is narrow on four counts at the same time. Only a transport provider engaged by the school, creche or centre. Only tracking of location. Only in the interests of the children's safety. And only during travel to and from it.
Step outside any one of those four and the exception simply is not available, and you are back to being asked.
Can the transport operator keep the location history after the child is dropped?
The allowance covers tracking during the journey, for the child's safety. Once the journey is over, holding on to where your child has been needs a reason of its own. The transport exception does not stretch to storing it or reusing it afterwards.
Can the same GPS data be used to send marketing messages to parents?
No. The allowance is strictly about safety during the journey. Marketing is a different purpose, and nothing in that exception reaches it.
Can other parents see my child's location on the bus tracking app?
The allowance covers the transport provider tracking children for their safety during the journey. Showing one child's live location to other parents is a disclosure to people that allowance never mentions, and it is not something the safety reason requires.
That needs its own footing, which in practice means a parent's verifiable consent. A shared map is convenient, and convenience is not one of the reasons the law recognises.
What people get wrong
We keep the full location history permanently, for safety.
The exception covers tracking during travel to and from the institution, in the interests of the child's safety. Keeping the trail indefinitely afterwards is a separate thing, and it needs its own justification.
Other parents can see your child's location on the app.
The exception is for that child's safety on her own journey. It is not authority to show her location to other parents, or to anyone else.
Related questions
This sector sits inside the full Sector Reference, which covers 26 sectors and 160 questions. To work through your own organisation rather than the general case, the Template Builder starts from your answers.