Independent Research and Policy Advocacy

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 14 April 2017 on the draft circular on “Master Directions on Issuance and Operation of Pre-paid Payment Instruments (PPIs) in India” (Draft Circular) released by the Reserve Bank of India (RBI)

The Future of Finance Initiative (FFI) is housed within the IFMR Finance Foundation (IFF) and aims to promote policy and regulatory strategies that protect individuals accessing finance given the sweeping changes that are reshaping retail financial services in India. Our vision is for every individual to have universal access to suitable financial services using a range of channels that enable them to transact securely and confidently.

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 to the draft circular “Rationalisation of Merchant Discount Rate (MDR) for Debit Card Transactions”

The Future of Finance Initiative (FFI) is housed within the IFMR Finance Foundation (IFF) and aims to promote policy and regulatory strategies that protect citizens accessing finance given the sweeping changes that are reshaping retail financial services in India. Our vision is for regulation and policy to develop to support universal access for all citizens to a range of channels through which they can transact securely and confidently.