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TRAI: NASSCOM & DSCI submit feedback on the Consultation Paper on Leveraging Artificial Intelligence and Big Data in the Telecommunication Sector
TRAI: NASSCOM & DSCI submit feedback on the Consultation Paper on Leveraging Artificial Intelligence and Big Data in the Telecommunication Sector

November 5, 2022

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Background

In August 2022, the Telecom Regulatory Authority of India (TRAI) released a Consultation Paper (Paper) on “Leveraging Artificial Intelligence and Big Data in the Telecommunication Sector” soliciting feedback from the public on the draft. On November 4th, NASSCOM & DSCI submitted their feedback on the Consultation Paper.

Our detailed submission is attached.

General Recommendation

In the paper, we identified two separate issues: (1) the sector-specific adoption of AI & BD within telecom and next-generation networks (2) the sector-agnostic adoption of AI & BD across sectors, where telecom and next-generation networks are one of the many enablers. We pointed towards a need for a more cohesive and integrated approach to AI & BD policy and regulation going forward. We need multiple stakeholders to collaborate, so that such initiatives are not limited in scope by sector-specific or enabler-specific perspectives.

Specific recommendations

  1. Rather than trying to define AI, it is better to define the application or product that is sought to be addressed. This is because, in practice, AI systems are built, not as “general-purpose” systems, but as domain-specific systems designed for specific tasks.
  2. TRAI may take up the exercise of identifying common themes that underpin the various existing terminologies available today and make such a thematic mapping generally available to stakeholders. It would also be useful in building on such a mapping and contextualising these themes to the Indian context.
  3. The discussion on regulation of AI must be based on reasonably well identified risks and harms which merit a regulatory and enforcement intervention.
  4. It is premature to look to set up a telecom/ICT sector specific or a common regulator to check and ensure compliance of national or sector-specific requirements for AI, or to enforce compliance with principled approaches to AI. We do note that there is a need for a coordination mechanism to ensure a whole-of-government approach can be achieved.
  5. There is still a lot of scope for capacity building in AI and need for alignment of skills of the AI workforce with the requirements of the industry. Like, mapping curriculum at institutional levels with industry job roles/standards.
  6. Build collaborations at the sectoral level between industry and students, so that directly adaptable skills for the industry can be built.
  7. It may be premature to create a list of pre-qualified suppliers, or creating a system for accreditation, of AI products or solutions. Such an approach may be counter-productive to the evolving AI ecosystem in India by creating entry barriers for start-ups and innovators.
  8. TRAI can look to analyse, more generally, on the responsible use of AI in the public sector. Various government bodies have already started deploying AI products and solutions in India. There is merit in exploring how to ensure accountability vis-à-vis unique risks and concerns posed by such deployments in the public sector.

For more information, kindly write to sudipto@nasscom.in, vertika@nasscom.in, and varun@nasscom.in


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20221104_trai_aipaper_nasscomdsci_final_submmission.pdf

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