Aapti’s submission to MEITY’s National Data Governance Framework Policy

By The Data Economy Lab

June 11th, 2022

The National Data Governance Framework Policy was published on the Ministry of Electronics and Information Technology website on May 25th, 2022. This was released after its precursor Draft India Data Accessibility and Use Policy, 2022 which was published for consultation in February 2022 was subsequently scrapped. The government has invited inputs on the Draft National Data Governance Framework Policy (NDGFP) that aims to unlock the potential of non-personal data which is stored by different Government entities in silos by launching a non-personal India Datasets program. The Draft Policy seeks to transform and modernise government data collection systems through standardised guidelines for collection, processing and use. The Draft Policy however fails to acknowledge the mounting privacy and digital rights concerns posed by its provisions, necessitating considered democratic deliberation and public review before it is rolled out.

What is needed to make the Draft Policy a meaningful and implementable regulatory instrument is an enabling ecosystem that creates mechanisms for sharing non-personal data such as data exchange platforms and data collaboratives. Elsewhere, mechanisms such as confidential clean rooms and data sharing layers, like the X-road, may be explored as alternatives for sensitive data. More fundamentally, the Draft Policy should establish standards for data storage, interoperability and appropriate controls for data use such that data quality, usability and privacy are upheld through the lifecycle of a dataset.

Please find below the document detailing Aapti’s comments on the Policy.