NASSCOM Feedback on Indian Digital Ecosystem Architecture 2.0 (IndEA 2.0)

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NASSCOM Feedback on Indian Digital Ecosystem Architecture 2.0 (IndEA 2.0)

Jayakumar Selvaraj

@Jayakumar

March 3, 2022

Public Policy

432

The Ministry of Electronics and Information Technology (MeitY) had released the Indian Digital Ecosystem Architecture 2.0 (IndEA 2.0) for inputs. The framework is envisaged to enable Governments and private sector enterprises to design IT architectures that can span beyond their organisational boundaries and enable delivery of holistic and integrated services to the customers. It builds on the principles and models recommended in IndEA 1.0.

NASSCOM made a submission providing feedback on the paper. Key highlights of our feedback below.

The allocation between public and private sector needs a relook. Allowing private sector in design, development and maintenance of core building block can provide an opportunity for leveraging their experience and expertise of building large IT systems.

While the paper addresses most aspects of the developing PDI it does not dwell into the question of funding. There will be some capital costs incurred for developing any PDI and recurring costs for operating any PDI. we believe that the framework should consider including aspects of funding. In this context, it should explore the possibility of availing private and philanthropic funding, and also dwell into the various modes in which the cost incurred can be recovered.
Most government departments have legacy e-governance systems. While the document calls for transition to ecosystem approach from an enterprise approach, it does not provide for a clear transition or migration strategy. The document or framework should dwell into the issues in migration and suggest appropriate mechanism for effective migration. A well-planned migration strategy can reduce disruption to the working of the existing system till the new system is in place and ensure that resources are used effectively.
While we welcome the idea of certifying projects as InDEA2.0 compliant, it is unclear what the proposal refers to as Testing. The document should provide some clarity on the testing that has been proposed. The stage at which this certification is to be applied – whether at a design stage or after development stage – should also be made clear.
While the paper has laid down security and privacy principles to be followed, such as privacy and security by design, it does not dwell into how these privacy and security principles will be operationalised. it will be necessary to ensure that this framework accommodates current constitutional guarantees afforded in relation to the fundamental right to privacy, as laid down in Puttaswamy I judgement More specifically, the paper should establish a framework whereby data principals will be afforded access to clear remedies in relation to cases where their privacy is not adequately protected.
The InDEA 2.0 report, as it stands right now, does not make a reference to NDSAP 2012. Therefore, it is not clear if it will conform to the principles laid down in NDSAP. The data sharing principle as espoused in InDEA 2.0 framework should be in consonance with the principles laid down in NDSAP, 2012, such as:

requiring maintenance of a negative list i.e., list of non-shareable data;
requiring maintenance of restricted data i.e., data that is accessible only through a prescribed process;
prescribing the various types of access such as open, registered and restricted; technology for sharing and access including maintaining a user-friendly interface, dynamic menus etc.

INDEA 2.0

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Jayakumar Selvaraj

Jayakumar