Update: Release of the Telangana Agriculture Data Management Framework

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Update: Release of the Telangana Agriculture Data Management Framework

Varun Sen Bahl

@varunsenbahl1

August 31, 2023

Public Policy

On August 11, 2023, the Telangana Government unveiled the Agriculture Data Management Framework (ADMF or Framework), which seeks to promote the collection, processing, and sharing of agricultural data to support the development of use-cases for the agricultural sector in a rights-respecting manner.

We had submitted our feedback on the draft version of this framework that had been released last year in August 2022 (see here). In this blog, we provide a brief overview of the ADMF and a snapshot of how the final framework has incorporated our recommendations. The ADMF is available here.

Overview: the Telangana ADMF

The ADMF is to be followed by all government departments that deal with agriculture, horticulture and allied activities specified in the Annexure, the information technology departments, and any other department or geographical area that the government may notify.

The ADMF defines the concepts of Agricultural Information Providers (AIPs), Agricultural Information Users (AIUs) and Data Service Providers (DSPs) to clarify its scope.

The framework lays down overarching principles that govern the process of collecting, using, and processing data for the purposes of implementing this framework. These include, principles of notice and consent, responsible sharing, purpose limitation, rights of individuals, among others.

The ADMF establishes an Inter-Departmental Committee (IDC) that is empowered to, inter alia, create guidelines, SOPs for data sharing, develop policies for interoperability, coordinating with other agencies for the smooth functioning of the digital infrastructure, data standards and protocols established by the Government under this framework.

The ADMF also creates a grievance redressal framework and enables a compliant mechanism. It also establishes an appellate tribunal for appeals.

Snapshot: our feedback and the final ADMF

Issue	Suggestion from nasscom	Final framework
Scope	We had suggested clarifying the terms 'providers' and 'consumers' and distinguishing them from data principals, AIPs, and AIUs.	The ADMF no longer uses “providers” and “consumers” and now only uses AIUs, AIPs, and Data Service Providers (DSPs).
Definitions	We had suggested that the scope of an AIU should be clarified as the phrase “need and use data” was vague.	The ADMF clarifies that the scope of an AIU is limited to data an agreement with the AIP.
Definitions	We had suggested defining “anonymized data” and a “restricted/negative list”.	The ADMF adds these definitions.
Principles	We had suggested ensuring that the guardrails of fair, lawful and limited data collection should also encompass other processing activities.	The ADMF extends these protective guardrails to both the collection and processing of personal data.
	We had suggested clarifying the scope of the guardrail on secondary purposes.	The ADMF now states Using personal data beyond its initial purpose will only be valid if it aligns with a purpose specified in the annexure and is done with the individual's consent.
	We had recommended that the framework should clarify the definition of ‘privacy by design’ and security by design as principles.	The ADMF shifts away from these terms and refers to the more well-understood concept of ‘privacy-protecting technologies’ instead.
Rights	We had recommended that including the right to access and correction, individuals should also have the right to deletion and portability.	The ADMF now includes these rights.
Grievance redressal	We had suggested that the role of the grievance redressal officer should be clarified as it would risk creating conflict with the role of the Data Management Officer.	The ADMF clarifies that the grievance redressal officer would not be a DMO.
Data exchanges	We had recommended that the framework should explicitly apply to the Agriculture Data Exchanges envisioned by the Telangana Government.	The revised framework empowers the Government to elucidate on this through SOPs.

For more information, kindly write to varun@nasscom.in or priyanshi@nasscom.in with a copy to policy@nasscom.in.

Telangana Agriculture Data data protection

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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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