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Government of Telangana : NASSCOM's Feedback on Agricultural Data Management Policy
Government of Telangana : NASSCOM's Feedback on Agricultural Data Management Policy

August 25, 2022

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The Government of Telangana had released the draft Agricultural Data Management Policy, 2022 for stakeholder consultation. The objective of the policy is to ensure that agricultural data is managed efficiently for the advancement of the agriculture sector by promoting digital agriculture and extensive use of technologies including the emerging technologies like AI, ML, IoT, Drones and satellite imagery.

The policy is applicable to all the departments and agencies of the Government dealing with agriculture, horticulture, and allied activities; Information Technology and Communications Department of the Government; all the providers and consumers of agricultural data; all the institutions dealing with research and innovation in agriculture and horticulture; all the individuals, teams, entities who collect, process, or share personal data of any individuals associated with the agriculture sector.

We submitted our feedback on the consultation which has been summarised below:

  • Setting the policy context is imperative to making the provisions holistic.  It is necessary to highlight the need to cover the regulation of personal data of the people engaged in the agricultural sector to protect privacy and redress harms from data misuse. A common framework, offering sector-specific solutions would be most effective here.
  • Agricultural Data Exchanges (ADEx) must be discussed in appropriate detail. The need of ADEx, its status as a Data Service Provider or outside entity and other questions regarding the data accessibility to Agriculture Information Users, responsibility of the ADEx to such Users and the infrastructure establishment needs to be addressed as well.
  • It was suggested that terms like “providers” and “consumers” must be clarified and that terms like individuals, entities and institutions associated with the sector should be defined. Specific laws that the ADMP will be subject to should be clarified in addition to the notification process certifying the “other departments” and the extension procedure.
  • The scope of what is captured in the agricultural sector must be defined and this includes defining the term agricultural sector itself. It is important to reduce the risk of processing sensitive personal data of the farmers. It is suggested that the scope of agricultural data must be limited to only include information on agricultural production, decision-making, operations, or management, a further layer of restriction may be included.
  • It was also suggested that it is necessary to clearly interpret the term “permissible purpose”, “performance of functions”, “security-by-design”, “and privacy-by-design”, “privacy-protecting technologies” and establish a framework for respecting the processing personal data of individuals. In addition to these rights, data principals should also have the rights to request the (a) deletion (b) restriction of disclosure and (c) portability of their personal data.

 

Read our detailed submission in the attachment below. For more information, kindly write to varun@nasscom.in and apurva@nasscom.in.


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Download Attachment

20220807-ADMP-NASSCOM-Feedback.pdf

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Apurva Singh
Senior Policy Associate

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