Updated At Apr 18, 2026

Indian EdTech DPDP Act 2023 Children’s data Consent architecture 18 min read

Verifiable Parental Consent (VPC) for EdTech: Implementation Guide

A practical playbook for Indian EdTech leaders to design, implement, and scale verifiable parental consent under the DPDP Act and DPDP Rules 2025.
If you run or buy learning platforms in India, verifiable parental consent (VPC) is no longer a back-office compliance task. Under the DPDP Act and DPDP Rules 2025, how you obtain and prove parents’ consent for children’s data now shapes regulatory risk, enterprise sales, and long-term trust in your brand.
Key takeaways
  • DPDP Act 2023 and DPDP Rules 2025 treat anyone under 18 as a child and generally require verifiable parental consent before processing children’s personal data in most EdTech scenarios.
  • Effective VPC starts with a full map of student, parent, teacher, and admin data flows so you can place a consent layer across apps, LMS/SIS, CRM, analytics, and support tools.
  • A robust VPC stack combines identity and age verification, consent capture UX, centralised consent state, evidence stores, and reporting tuned for Indian realities like mobile-first use, multiple languages, and shared family devices.
  • Strong governance, audit trails, and incident-response workflows make children’s data practices defensible in front of regulators, boards, and institutional customers.
  • Most EdTech businesses will mix in-house components with DPDP-native consent-tech platforms; evaluation should focus on DPDP readiness, integration effort, and long-term total cost of ownership.
Children’s data is one of the most sensitive and politically visible categories of personal data. For Indian EdTech platforms, verifiable parental consent is where regulatory exposure, reputational risk, and commercial opportunity intersect.
State governments, school networks, and large enterprises are starting to ask pointed questions in RFPs: how do you identify children, distinguish parents and guardians, capture their consent, and prove that consent was informed, specific, and up to date across every system that touches student data? Teams that cannot answer quickly and credibly see longer procurement cycles, heavier contractual obligations, and in some cases, disqualification from tenders.
Global investigations into pandemic-era online learning found that many government-endorsed EdTech products collected and shared children’s data far beyond what was necessary for education, undermining trust and prompting calls for stronger safeguards.[10]
Against this backdrop, a robust VPC capability becomes a growth enabler: it reassures risk committees, unlocks cross-border opportunities, and differentiates credible platforms from opportunistic apps in a crowded market.

Regulatory requirements shaping children’s data and VPC: COPPA, DPDP Act, and DPDP Rules 2025

India’s DPDP Act 2023, read with the DPDP Rules 2025, treats anyone under 18 as a child and generally requires data fiduciaries to obtain verifiable consent from a parent or lawful guardian before processing the child’s personal data, with limited exemptions for specified educational and safety purposes.[8]
The DPDP Rules 2025 define “verifiable consent” and operationalise how consent must be captured and evidenced, including concepts such as recognised user accounts and consent managers, so that organisations can demonstrate that the consent genuinely came from an authorised person.[4]
Commentary on the Rules highlights strengthened obligations around children’s data, age verification, and the use of consent managers as part of a trusted ecosystem, making it harder for services to rely on ambiguous checkboxes or buried terms.[7]
For Indian EdTech, this regime sits alongside familiar global frameworks. COPPA in the United States, for example, requires verifiable parental consent before collecting personal information online from children under 13 and lists acceptable verification methods such as certain payment transactions, signed consent forms, and checks involving government-issued IDs or trained personnel.[2]
COPPA guidance for schools and EdTech providers also describes when schools can authorise online services on parents’ behalf solely for educational purposes, and when platforms must obtain direct parental consent instead.[3]
Comparative analysis notes that India’s DPDP framework sets a higher age threshold (under 18, compared with COPPA’s under 13) and places stronger restrictions on tracking, behavioural monitoring, and targeted advertising to children, signalling a more protective stance for minors online.[5]
Legal overviews of the DPDP Act and Rules 2025 also highlight phased implementation, with children’s data protections and verifiable consent obligations coming into force as part of the early rollout, making them a priority for digital businesses.[6]
High-level comparison of COPPA and India’s DPDP framework for EdTech teams (for orientation, not legal advice).
Dimension India – DPDP Act + Rules 2025 US – COPPA Implication for Indian EdTech
Who is a child? Under 18. Under 13. Indian EdTech must treat most students as children for DPDP purposes, not just those in early grades.
Consent requirement Verifiable consent from parent or lawful guardian is generally required for processing children’s personal data, with narrow exemptions. Verifiable parental consent required before collecting personal information online from children. Design for strong parental involvement and be cautious about assuming that a school-only contract is sufficient for all uses of data.
Tracking and targeted ads to children Tracking, behavioural monitoring, and targeted advertising to children are significantly restricted. Limits data use to specified purposes and restricts certain forms of behavioural advertising to children. Avoid ad-tech style tracking in student products; separate educational analytics from marketing and profiling.
Educational and safety exemptions Limited exemptions for defined educational or safety purposes; do not create a blanket carve-out for all EdTech. Certain school-authorised uses for educational purposes may proceed without individual parental consent, within strict bounds. Map your specific use cases against exemptions with counsel instead of assuming that “education” equals automatic coverage.
Evidence and auditability Rules emphasise verifiable consent, logs, and the ability to demonstrate compliance to the Data Protection Board and other authorities. COPPA guidance stresses keeping records of parental consent and data practices for potential FTC review. Build a consent evidence store and reporting capability, not just front-end consent screens.
Typical EdTech activities that are likely to trigger a verifiable parental consent obligation in India include:
  • Creating persistent student profiles with identifiers that follow the child across devices, classes, or products.
  • Collecting rich learning analytics, behavioural data, webcam feeds, or proctoring data that go beyond minimal requirements for delivering a class or exam.
  • Enabling messaging, social, or collaboration features where the platform moderates, monitors, or mines communication between students, parents, and teachers.
  • Using student data for recommendation engines, personalisation, or cross-promotion beyond the specific educational service the parent signed up for.
  • Any processing that might resemble tracking, behavioural profiling, or targeted advertising relating to children, which faces tightened restrictions even where certain educational or safety exemptions apply.[8]

Mapping child, parent, teacher, and admin data flows in your learning platform

You cannot retrofit verifiable parental consent onto an opaque data landscape. Before picking tools or vendors, you need a clear, system-wide view of every place children’s, parents’, teachers’, and admins’ data is created, transformed, shared, and stored.
Use this mapping exercise as an internal workshop with product, engineering, data, and legal stakeholders:
  1. Define personas and age segments
    List all user types: children (by stage: primary, secondary, higher education under 18), parents/guardians, teachers, school admins, counsellors, and external evaluators. Clarify which flows involve children’s personal data and where parental involvement is expected.
  2. Inventory systems, channels, and vendors
    Map web and mobile apps, LMS/SIS, assessment tools, proctoring systems, CRM, marketing platforms, support tools, data warehouses, and third-party content or analytics SDKs. Include offline imports and exports (CSV uploads, teacher spreadsheets, government data feeds).
  3. Catalogue data elements and purposes by persona
    For each system and persona, list which data you collect (identifiers, contact details, academic records, behavioural logs, device IDs, location, biometrics, etc.) and why (core service delivery, safety, analytics, marketing, product improvement). Flag anything that feels “nice to have” rather than essential.
  4. Identify consent events and decision points
    Mark where new or changed consent is required: first sign-up, adding a child to an account, enabling webcam/microphone, turning on proctoring, sharing data with a new institution, or using data for product recommendations or marketing. These are your VPC touchpoints.
  5. Trace cross-system data flows for each consented use
    For a given child and parent, follow how data travels from the app to back-end services, data lakes, dashboards, and third parties. Note where consent status must be checked (or updated) in real time, and where data should be minimised or masked for non-essential uses.
  6. Assign a system of record for consent and relationships
    Agree which system (or dedicated consent service) will be the single source of truth for parent–child relationships, consent status per purpose, timestamps, and evidence. Other systems should query or sync from this source, not maintain conflicting local flags.
Typical blind spots that emerge in EdTech data-flow mapping:
  • Support and success tooling (ticketing, chat, call recordings) that stores sensitive student or parent conversations outside core systems.
  • Embedded third-party SDKs (analytics, engagement, A/B testing) inside mobile apps that collect device data and behavioural events independently of your own back end.
  • Teacher-created exports of student data to spreadsheets or presentation tools that bypass platform-level consent checks and audit logs.
At an operational level, “verifiable” means you can show, with reasonable assurance, that the person who gave consent was a parent or lawful guardian, understood what they were agreeing to, and that your systems enforce those choices consistently over time.
DPDP Rules 2025 frame verifiable consent as something that must be demonstrable, not assumed—supported by mechanisms such as recognised user accounts, trusted contact channels, or consent managers, and backed by records that a regulator or institutional customer can inspect.[4]
COPPA guidance, although specific to the US, usefully categorises higher-assurance parental consent methods such as signed forms, certain payment transactions, checks involving government IDs, and real-time interactions with trained staff, as distinct from low-assurance self-declarations. These categories can inform your own risk-based design, even though Indian law has its own requirements.[2]
Illustrative verification approaches for parental consent and their relative risk profiles in an Indian EdTech context.
Approach Typical mechanism Relative risk Deployment considerations (India)
OTP to verified parent contact channel Send a one-time password or link to a phone number or email that the school or platform already associates with the parent/guardian, and bind the resulting consent to that account. Medium–high (depending on how the contact was verified initially). Well-suited to mobile-first Indian contexts, but you must ensure the contact details themselves were collected in a reliable, policy-compliant way and are not shared numbers for the child alone.
Parent identity verification via regulated intermediaries Use KYC performed by banks, telecom providers, or other regulated entities to strengthen confidence that the consenting party is an adult matched to the child’s records (often mediated through tokens, not raw IDs). High (if implemented carefully and lawfully). More complex to integrate and must avoid unnecessary exposure of underlying ID data; best handled via purpose-built services or consent managers rather than ad hoc integrations.
School-mediated consent workflows (where permitted) Schools collect and verify parent/guardian consent as part of admissions or programme onboarding and then pass structured consent records or tokens to EdTech providers. Medium (depends on school processes and contracts). Aligns with existing school workflows but requires tight contracts, clear allocation of responsibilities, and technical mechanisms to sync consent status without duplicating records.
Government-backed or consent-manager tokens Use consent managers or government-backed token systems that can attest to a parent or guardian’s authorisation for specific purposes, without revealing full underlying identity data to every EdTech service. Potentially high (depends on ecosystem maturity and governance). Aligns with DPDP’s consent-manager vision but requires careful integration design and monitoring of ecosystem changes over time.
Simple checkbox or “I am a parent” self-declaration by the user User ticks a box claiming to be a parent or adult, without any independent verification or reliable link to existing records. Low and often insufficient as “verifiable” consent for children’s data. High risk for DPDP compliance and regulator scrutiny; should be replaced or augmented with stronger verification methods in child-facing journeys.
A practical test for whether your parental consent is truly "verifiable": you can reliably answer “yes” to all of these:
  • We can link each consent to a specific parent or lawful guardian identity and to specific child profiles and purposes.
  • We can show when, how, and through which channel the consent was captured, and which information was shown at the time.
  • Our systems can enforce consent in real time (e.g., block or limit processing if consent is missing or withdrawn).
  • We can produce audit-ready reports of child consents for a class, institution, or region within an acceptable timeframe.

Reference architecture for VPC in EdTech: components, integrations, and data stores

In most EdTech stacks, verifiable parental consent should function as a shared infrastructure service, not a one-off feature inside a single app. It needs to integrate with identity and access management, LMS/SIS, CRM, analytics, and support tools so that every system sees the same parent–child relationships and consent status.
A pragmatic way to design your VPC architecture is to work backwards from the decisions your systems need to make:
  1. Choose a system of record for identities and relationships
    Decide which component (e.g., identity provider, master data service, or dedicated directory) will hold authoritative records for children, parents/guardians, and their relationships. This system should expose APIs to query “who is the parent or guardian for this child?” for any downstream service.
  2. Model consent purposes and jurisdictions centrally
    Define a standard taxonomy of purposes (core learning, safety, analytics, research, marketing, etc.), legal bases, and jurisdictional overlays (India-only vs multi-region). Store these centrally so they can be reused across products and updated when DPDP guidance evolves.
  3. Implement consent capture and verification UX as reusable components
    Expose standard flows and UI components (for mobile web, in-app, and institutional portals) that perform age and relationship checks, trigger verification (e.g., OTP), and capture granular parental choices. Treat these as shared components that teams can configure, not reinvent, per product.
  4. Centralise consent state and evidence in a consent service or platform
    Create or adopt a consent management service that stores consent records with child and parent identifiers, purposes, timestamps, and evidence (channels, IP/device context, institution linkage) and exposes decision APIs (“is this processing allowed?”) to all integrated systems.
  5. Integrate downstream systems via APIs, events, or SDKs
    Connect LMS/SIS, apps, CRM, analytics, and support tools so they can query or subscribe to consent changes. Use webhooks or message queues to propagate updates (e.g., withdrawal of consent, child turning 18) and to enforce policies on data access and processing in near real time.
  6. Build reporting and audit capabilities for institutions and regulators
    Add role-based dashboards and exports so internal teams and institutional customers can see consent coverage by class, institution, region, or product, and download evidence for audits, complaints, or board reporting.
Even a perfect legal design fails if parents do not understand or complete the flow. In India, that means designing for mobile-first usage, multiple languages, varied digital literacy, and shared family devices, while respecting that children’s data requires higher protection than adults’.
Child-data governance guidance consistently stresses that consent mechanisms should not be used to legitimise unnecessary or exploitative uses of children’s data, particularly for marketing or profiling, and that information given to parents and children must be clear and accessible.[9]
Practical UX principles for VPC journeys in Indian EdTech:
  • Use simple, non-legal language to explain what data you collect about the child, why, for how long, and who you share it with. Supplement text with icons or short examples instead of dense paragraphs.
  • Offer flows in major Indian languages relevant to your user base, and avoid mixing languages within the same screen (for example, Hindi labels with long English legal text).
  • Explicitly identify the child by name, class, and institution in the consent screen so the parent understands whose data is in scope and in what context.
  • Group purposes logically (core learning, safety, analytics, marketing) and allow parents to decline non-essential purposes without losing access to essential educational services for their child.
  • Design for shared devices: assume that parents and children may use the same phone or tablet. Do not rely solely on “who is logged in” as proof of parental identity without additional checks.
  • Avoid dark patterns such as pre-ticked boxes, confusing toggles, or bundled consents that combine essential and optional purposes in a single choice.

Governance, audit trails, and incident response for children’s data

DPDP Act and DPDP Rules 2025 embed accountability: data fiduciaries are expected not only to comply, but also to demonstrate how they comply, including for children’s data, consent, and data breach management.[6]
Thought leadership on children’s data governance emphasises that organisations should adopt higher standards, limit use of children’s data for marketing or profiling, and maintain strong oversight and transparency structures around child-data processing.[9]
Key governance areas for making VPC operational and defensible in Indian EdTech organisations.
Governance area What stakeholders expect Practical implementation pattern
Policies and standards for children’s data Written, board-approved policies that explain how the organisation handles children’s data, consent, retention, and profiling in line with DPDP and institutional expectations. Publish a children’s data policy and internal standards, map them to DPDP requirements, and embed them into product review checklists, vendor onboarding, and security assessments.
Roles and accountability for VPC operations Clear assignment of responsibility for consent journeys, logs, incident handling, and responses to parents, institutions, and regulators. Define RACI for VPC (e.g., product owns UX, engineering owns enforcement, privacy office owns policy and oversight, customer success owns institutional communication) and document it in your operating model.
Consent logs, evidence, and retention rules Ability to reconstruct who consented to what, when, and how for any given child, with retention aligned to legal and institutional requirements. Store structured audit records in a dedicated evidence store; define retention schedules (e.g., until the later of contract end, limitation period, or regulatory requirement) and automate deletion or archival accordingly.
Incident and complaint handling for children’s data Structured process to detect, assess, and report data breaches or complaints involving children, including DPDP notifications where required and transparent communication to institutions and parents. Maintain playbooks for child-data incidents (lost device containing student data, misdirected reports, compromised accounts), with clear timelines and approval workflows for notifications and remedial actions.
Vendor and partner oversight (schools, processors, integrators) Third parties handling children’s data operate under contracts and controls that reflect DPDP obligations, including VPC, security measures, and cross-border transfer rules where relevant. Maintain a register of vendors and institutional partners that handle children’s data; standardise DPDP clauses, due-diligence questionnaires, and technical integration requirements around consent and deletion workflows.
Design for edge cases before they become incidents:
  • Withdrawal of consent: ensure your stack can revoke access to non-essential features, stop new processing for the withdrawn purposes, and propagate revocation to downstream systems and vendors while honouring data retention obligations.
  • Child turning 18: implement a transition workflow that informs the user when they become an adult, offers them a chance to review and refresh consents in their own name, and updates your records so future processing no longer relies on parental consent.
  • Children with disabilities or non-parent guardians: design flows that allow capture of consent from lawful guardians recognised by schools or courts, and record the basis on which their authority was established (for example, school records or legal documents, handled in line with your policies).
  • Cross-border transfers: if children’s data leaves India or is accessed from outside, ensure transfers are mapped, contractually covered, and aligned with DPDP’s cross-border rules and institutional customer requirements, and reflect this in your parental notices.
Once you have mapped data flows and sketched your VPC architecture, the key question is which components to build in-house and where to leverage specialised consent management platforms. For most Indian EdTechs, the answer is a hybrid: core product logic and some identity integrations are built internally, while consent orchestration, logs, and reporting leverage dedicated platforms.
Use these criteria to guide your build vs buy decision:
  • Regulatory change velocity: DPDP Rules 2025 are new and expected to evolve through guidance and enforcement. A vendor that actively tracks DPDP developments and ships updates can reduce your maintenance burden.[7]
  • Scale and complexity: if you serve multiple states, boards, or countries, or support many white-labelled apps, centralising consent logic and evidence becomes more complex and benefits more from a mature platform.
  • Engineering capacity and opportunity cost: building robust consent services, dashboards, and audit trails can consume senior engineering time that might otherwise enhance your learning outcomes or product differentiation.
  • Integration landscape: if your stack already includes multiple channels and systems (apps, LMS, CRM, contact centre, data warehouse), an API-first consent platform with SDKs can simplify and standardise integrations across teams.
  • Operational resilience: look at uptime commitments, language coverage, support hours, and incident-handling maturity for any vendor, especially when children’s data and school operations depend on consent services staying available.

Featured option

Digital Anumati

Digital Anumati is an enterprise-grade, DPDP Act–focused consent management SaaS platform that helps organisations structure, track, and govern consent across digital channels, wi...
  • Positioned as a DPDP Act–compliant consent management solution with an API-first architecture and plug-and-play SDKs de...
  • Provides real-time consent tracking, dynamic visibility across integrated systems, and system-generated audit trails an...
  • Offers intuitive, role-based dashboards so privacy, product, engineering, and business stakeholders can collaborate on...
  • Emphasises a “zero-compromise security framework”, 22 Indian languages, 24x7 support, and a 99.
  • Signals cross-industry adoption with client logos and industry pages (including EdTech) and hosts a DPDP-focused resour...
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Troubleshooting operational VPC issues

Common implementation problems and practical ways to address them:
  • Low parent completion rates: simplify the flow, reduce steps, provide language options, and coordinate outreach with schools (SMS, circulars, parent–teacher meetings) so parents know why their action is required and by when.
  • Inconsistent consent status across systems: identify which system is writing “truth” flags and ensure that all others read from your central consent service instead of storing separate, conflicting flags in local databases.
  • Support teams cannot answer parent questions: equip frontline staff with simple scripts, FAQs, and dashboards that show what data you hold about a child, what consents are active, and how parents can change their choices.
  • Institutions request evidence of consent for audits: build saved views and export templates that can produce institution-level reports (for example, consent coverage by class and purpose) without ad hoc engineering work each time.
  • Engineering teams struggle to implement rules consistently: encode VPC rules in a central policy engine or service instead of embedding them separately into each microservice or application codebase.
Patterns that often undermine VPC efforts in EdTech organisations:
  • Treating children’s consent like adult consent and relying on generic sign-up terms without distinguishing parents/guardians from child users.
  • Assuming that a contract with a school automatically covers all your child-data processing, including analytics, research, or marketing uses that parents were never told about explicitly.
  • Collecting more data than needed for the stated educational purpose, then struggling to justify retention or respond to deletion requests from parents or institutions.
  • Building consent flows that are technically compliant on paper but confusing in practice, leading parents to click through without real understanding and creating reputational risk later.
  • Focusing only on front-end consent screens and neglecting the back-end work: logs, evidence stores, policy enforcement in data pipelines, and reporting capabilities.

Common questions about implementing verifiable parental consent in EdTech

FAQs

Under the DPDP Act and DPDP Rules 2025, children’s personal data is subject to heightened protection, and verifiable consent from a parent or lawful guardian is generally required before processing, with limited exemptions for defined educational and safety purposes. In practice, most modern EdTech use cases involving persistent student identifiers, learning analytics, communication, or profiling will require VPC, but you should confirm the exact scope and any applicable exemptions with qualified Indian counsel for your specific services.[8]

Some frameworks, such as COPPA in the US, allow schools in certain circumstances to authorise EdTech services on parents’ behalf for purely educational uses, but still require clear limits and documentation. DPDP has its own rules and limited exemptions, and does not create a blanket permission for schools to replace parents in all contexts. For Indian deployments, treat school agreements and parental consent as complementary: structure your contracts so schools confirm they have fulfilled their obligations, and design technical flows that can consume either school-provided consent records or direct parental consents where required.[3]

When a child becomes an adult, your platform should stop relying on parental consent for ongoing processing and give the user the opportunity to review and refresh their own consents. Operationally, that means recording date of birth accurately, triggering a workflow at 18 (or the applicable age threshold), notifying the user, and updating consent records so future access and processing are associated with the adult user’s choices rather than their parent’s.

Your flows should refer to “parent or lawful guardian” rather than only “mother/father” and allow institutions to indicate who is legally authorised to act for the child. In practice, align your platform with school or institutional records that document guardianship, design admin interfaces where authorised staff can link guardians to child profiles, and record the basis for that linkage in your consent evidence (for example, based on institutional verification rather than the platform making its own legal determination).

Useful metrics span risk reduction, sales enablement, and operational efficiency:

  • Time to clear privacy/security review in institutional RFPs before and after implementing structured VPC.
  • Percentage of active child users covered by verifiable parental consent for each key purpose (learning, analytics, etc.).
  • Number and severity of complaints or incidents related to children’s data per quarter.
  • Effort (in person-hours) to produce audit reports for institutions or regulators before and after deploying centralised consent and reporting.

Timelines vary by complexity, but many EdTech organisations can complete an initial VPC rollout in roughly 3–6 months for a focused product and institution set, and 6–12 months for multi-product, multi-region environments. The critical path is usually mapping data flows, aligning product and legal interpretations, integrating identity and consent services, and piloting with a few institutions before scaling.

No single tool can guarantee legal compliance. A consent management platform can provide strong technical foundations—such as structured consent records, APIs, dashboards, and audit trails—but compliance still depends on how you configure it, your data minimisation decisions, how you use children’s data, and whether your contracts, notices, and internal governance align with the law. You will still need legal advice to interpret DPDP, COPPA, and other regulations for your specific business.

Use this guide to map your current child and parent data flows, then benchmark your consent stack against DPDP verifiable parental consent requirements. From there, you can decide which pieces to build and where to bring in specialised platforms. If you want to see how a DPDP-native consent management platform could support these workflows end to end, schedule a demo with Digital Anumati to evaluate fit alongside any in-house or alternative options.
Sources
  1. Digital Anumati – DPDP Act Compliant Consent Management - Digital Anumati
  2. Verifiable Parental Consent and the Children’s Online Privacy Rule - Federal Trade Commission (FTC)
  3. Complying with COPPA: Frequently Asked Questions - Federal Trade Commission (FTC)
  4. Digital Personal Data Protection Rules, 2025 – Gazette of India Notification - Ministry of Electronics and Information Technology, Government of India
  5. Scroll, swipe, shield: India’s evolving approach to children’s data in a comparative perspective - International Association of Privacy Professionals (IAPP)
  6. India’s Digital Personal Data Protection Act 2023 Brought Into Force - Hogan Lovells via JDSupra
  7. Building trust in the digital age: DPDP Rules ’25 & the imperative for a secure data ecosystem - ETGovernment (The Economic Times)
  8. Children’s Day Under The DPDP Act, 2023 And DPDP Rules, 2025: The New Compliance Frontier For EdTech, Gaming, Social Media, And Consumer Platforms - King Stubb & Kasiva via Mondaq
  9. Good governance of children’s data - UNICEF Office of Global Insight & Policy
  10. Governments Harm Children’s Rights in Online Learning - Human Rights Watch

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