Independent Research and Policy Advocacy

Primer on Consumer Data Infrastructure

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Large scale data infrastructures (such as the proposed Public Credit Registry, the GSTN System and the Indiastack) are emerging to support the delivery of financial services in India. This raises questions regarding the role of the State and of the regulation of these infrastructures. The existing and proposed data infrastructures include databases that aggregate information and data utilities that allow for various databases to interact with each.

Data infrastructures seek to re-imagine and improve the credit information markets in India. The benefits of this aggregation are purported to improve financial inclusion and supervision of the financial sector. However, there is a need to understand the impact on individuals and firms whose information will be aggregated and shared. Consumer data will be one of the major constituents of the information that will be aggregated in these data infrastructures. Therefore, it is of interest to understand the issues that arise from the interplay between the regulation of data infrastructures and those of personal data.

The impact of these new projects will also be felt on the existing financial infrastructures and databases in the country. Emerging concerns such as the competition implications for the financial markets and the risks and harms arising from the large-scale aggregation and sharing of data must be considered by the regulators. Additionally, clarity on a liability framework for entities accessing these infrastructures and those responsible for maintaining them, especially in cases where harms or losses are suffered due to their misuse, breach or failure is required.

In this background, we have compiled a primer on Consumer Data Infrastructure. The primer emphasises on the benefits that come with the aggregation of data with state infrastructures. It also raises concerns attached with this aggregation, and some considerations which emerge for regulators operating in the digital financial space.

Click here to access the primer on Consumer Data Infrastructure.

(This primer is created to support the discussions of the panel on Consumer Data Infrastructure at the 4th Dvara Research Conference on Regulating Data-driven Finance. The discussants for the panel include Mr Rafe Mazer (FSD Kenya), Mr Dilip Asbe (NPCI), Prof Subhashis Banerjee (IIT-Delhi), Ms Malavika Raghavan (Dvara Research).

The primers for the conference are designed to give sufficient context to the discussions and provoke further conversation, rather than act as stand-alone research notes. The full agenda for the conference is available here. Read more about the research themes and motivations for the conference here. Following completion of the conference, proceedings and related documents will be available here.)

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