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NASSCOM-DSCI Feedback on the Draft National Data Governance Framework Policy
NASSCOM-DSCI Feedback on the Draft National Data Governance Framework Policy

June 15, 2022

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Earlier in May, the Ministry of Electronics and Information Technology (MEITY) had released a draft National Data Governance Framework Policy (NDGFP) for public consultation. We had summarised this draft policy in an earlier post on this blog (available here).

On June 11, NASSCOM and the Data Security Council of India (DSCI) jointly submitted their feedback to MEITY on the NDGFP. Our submission is attached herewith. In brief, we provided the following inputs:

  1. We welcomed the (a) fact that the policy recognises that private entities will only be expected to play a voluntary role in sharing non-personal data to the government (b) the emphasis on a consultative approach as a clear way forward.
  1. We recommended that this policy be aligned with both existing policies and regulations, such as the National Data Sharing and Accessibility Policy of 2012, as well as with expected new legislations, such as the (Draft) Data Protection Act of 2021 (DPB 2021). We provided examples of several other policies and regulations that may be touched by this policy.
  1. We also noted that this contained several elements found in an earlier draft policy, the India Data Accessibility and Use Policy (summarised here and our feedback on that is available here) and sought clarity on whether this was replacing that earlier draft or not.
  1. On anonymisation, we pointed out the need to (a) keep in mind that this is a topic that will also be addressed under the DPB 2021 (b) see anonymisation as a risk management process and (c) highlighted the general need for strong anonymisation standards in line with current and emerging international best practice.
  1. We highlighted several aspects of the policy meriting further clarification and refinement, including, inter alia, the material scope, the design of the proposed India Data Management Office, the expectations from private companies, and the proposal to limit access to start-ups and researchers.

For any queries or inputs on our feedback, please reach out to varun@nasscom.in, apurva@nasscom.in or anisha@dsci.in. 

 


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20220608-NASSCOM-DSCI-NDGFP-JointSubmission-v2.pdf

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Varun Sen Bahl
Manager - Public Policy

Reach out to me for all things about data regulation, cybersecurity policy, and internet governance.

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