Response dated 13 September 2020 to the Report by the Committee of Experts on Non-Personal Data Governance Framework released by the Ministry of Electronics and Information Technology in July 2020
This response identifies some overarching concerns with the Report that we seek to convey and substantiate.
They are categorised under the following three sections:
Section 1: The Report fails to identify the basis for a separate regulatory regime to regulate non-personal data (NPD).
Comments to the Ministry of Electronics and Information Technology (MEITy) on the draft Personal Data Protection Bill 2018, dated 27 July 2018, submitted by the Committee of Experts on a Data Protection Framework for India
In this document, we present our comments on the draft Personal Data Protection Bill 2018 (hereafter “the draft Bill”) in response to the call for comments from the public by MEITy (Ministry of Electronics and Information Technology, 2018)
Responses dated 31 January 2018 to the “White Paper of the Committee of Experts on a Data Protection Framework for India” dated 27 November 2017 (White Paper) released by the Ministry of Electronics and Information Technology (MeitY)
In this document, we present our responses to the public consultation on the White Paper which is based on our broader approach on data protection. This approach looks past a consent-led approach to data protection, and seeks to embed a bundle of rights for all individuals with respect to their personally
identifiable data that apply even where consent has been validly obtained for data collection
Comments dated 20 March 2017 on the draft of the “Information Technology (Security of Prepaid Payment Instruments) Rules 2017” dated 8 March 2017 (Draft Rules) released by the Ministry of Electronics and Information Technology, Government of India (MeitY)
Our comments in response to the Draft Rules are presented in two sections below. In the first section titled “I. Overarching Comments”, we raise two broad points on (1) extending the data protection principles consistently to avoid regulatory gaps, and (2) the need for regulatory coordination to avoid dual regulation, mitigate potential capacity constraints for MeitY and any adverse impact on the ease of doing business for pre-paid instrument (PPI) issuers. In the second section titled “II.
Comments on the Ministry of Electronics & Information Technology’s Draft Rules for Security of Prepaid Payment Instruments
On 8 March 2017, the Ministry of Electronics & Information Technology (MeitY) released a set of draft rules for security of prepaid payment instruments (Draft Rules), inviting comments by 20 March 2017.
