Call for Inputs: Report of the Committee on Non-Personal Data Governance

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Call for Inputs: Report of the Committee on Non-Personal Data Governance

Indrajeet Sircar

@IndrajeetSircar

January 4, 2021

Public Policy

392

As you might be aware, the Committee of Experts on Non-Personal Data Governance (NPD Committee), chaired by Shri. Kris Gopalakrishnan, has issued its revised Report for public consultation, and is inviting comments before 31 January 2021.

The Committee which was convened in September 2019, issued its draft Report for public comment earlier in July 2020. As a part of the public consultation process, NASSCOM submitted its detailed feedback in September 2020, recommending inter alia that:

Grounds and scope for mandatory NPD sharing be limited, and be defined through a white-list of categories considered for sharing;
Data processed by Data Processors under contractual arrangements with clients, and foreign data, be left out of the scope of NPD sharing obligations;
Overlaps with other laws, including the Personal Data Protection Bill, 2019 should be addressed;
Concerns relating to Intellectual Property Rights over NPD, and competitive sensitivity of certain NPD and meta-data should be addressed.

The Final Report of the NPD Committee, takes on board the feedback received in the course of the public consultation, and proposes a new framework for the designation and sharing of certain limited High-Value Data Sets (HVDS) with high economic and social value. Further, the revised Report explicitly excludes certain Data Processors’ data and foreign data from the applicability of the framework. Likewise, concerns over public disclosure of competitively sensitive meta-data, has been addressed by making the meta-data submitted by Data Businesses a part of a controlled data-set maintained by the Non-Personal Data Authority (NPDA), wherein entities may query but not download such meta-data.

In order to unpack these, and other new recommendations of the NPD Committee, NASSCOM will be hosting a Webinar and discussion with members of the NPD Committee on 13 January 2021 from 11:30 am to 1:00 pm. Details of the meeting will be shared closer to the date with members.

We are also inviting inputs from members on the revised recommendations of the NPD Committee. We request you to kindly share your inputs with NASSCOM by sending the same to policy@nasscom.in, before 22 January 2021.

Should you have any further queries, please feel free to reach out to indrajeet@nasscom.in.

PDP Bill industry consultation non-personal data NPD kris gopalakrishnan high value data sets

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Indrajeet Sircar

Consultant, Public Policy and Outreach