Internet Democracy Project

The Ministry of Electronics and Information Technology has invited public comments in its consultation on the Non-Personal Data Governance Framework Report. The report has been drafted by a committee of experts under the chairmanship of K. Gopalakrishnan. The committee prescribes for a framework to govern non personal data. It categorises non personal data into various categories and suggests mechanisms to reap maximum economic value from non personal data. On 13 September, the Internet Democracy Project made a submission to the consultation, highlighting fundamental concerns as well as making additional comments on ​‘non personal data’ and some other concepts discussed in the report.   More

On 2 June 2020, the Ministry of Civil Aviation invited public comments for consultation on the draft Unmanned Aircraft System Rules, 2020, or in short the draft Drone Rules. On 3 July 2020, the Internet Democracy Project made a submission and recommendations to the consultation, to address the privacy, freedom of speech and discrimination concerns arising from the Rules, 2020, so that this technology can be used to benefit the society. You can read our full submission below.    More

The Ministry of Electronics and Information Technology invited public comments for consultation on the National Open Digital Ecosystems (NODE), White Paper. The paper proposes for a paradigm shift from earlier approaches to digital governance. It aims to build a citizen centric, interoperable and open digital ecosystem, in order to do that it presents certain principles and use cases. On 31 May, the Internet Democracy Project made a submission into the consultation, highlighting fundamental concerns as well as making additional comments on the NODE guiding principles against the backdrop of these concerns.    More

In a public consultation, the Joint Parliamentary Committee has sought comments on the Personal Data Protection Bill 2019. The Internet Democracy Project submitted its inputs on 25 February. We highlighted how the Bill has skewed the fiduciary relationship between the data fiduciary and data principal by favouring the data fiduciaries in several ways, thereby leaving data principals vulnerable to a range of privacy harms. You can read the full submission below.    More

The Department for Promotion of Industry and Internal Trade released a draft national e‑commerce policy and invited public comments. The Internet Democracy Project submitted comments highlighting why the policy is dangerous in its framing of data as a resource to extract for national development.    More

Instead of understanding ​‘data’ as a resource to be tapped, what if we employ other metaphors around data? How does that change our reading of the draft Personal Data Protection Bill? Data as bodies, data as labour, data as exhaust, data as distraction – so much turns on which metaphor we choose to give precedence to! Taking this as a starting point, a group of activists and researchers got together to understand what the draft Personal Data Protection Bill means for social movements and issues they might be embedded in, and in turn, how different movements can contribute their wisdom to strengthen the bill. This was jointly drafted by participants following two workshops organised in Bangalore and Delhi by the Internet Democracy Project in September 2018.   More

The Ministry of Electronics and Information Technology invited public comments to the draft Personal Data Protection Bill and accompanying report. The report claims that the proposed framework is a fourth way (others being the European Union model, the United States model and the Chinese model) that is tailored to suit India and other developing countries. The Internet Democracy Project made a submission, with general comments as well as some specific suggestions.    More

The Government of India constituted a committee of experts to draft a data protection bill that would be put in place the data protection framework for India. The committee published a white paper and invited comments and feedback. The Internet Democracy Project made recommendations to the committee, drawing from the Report of the Committee of Experts headed by Justice AP Shah, and highlighting the need to center the data subjects, incorporate new articulation of rights and have strong implementation mechanisms. Read our submission here.   More

The Telecom Regulatory Authority of India (TRAI) invited comments for consultation paper no. 09/2017 on Privacy, Security and Ownership of User Data in the Telecom Sector. The Internet Democracy Project submitted comments to TRAI, asking the regulator to centre users’ rights over their data as part of the fundamental right to privacy, while balancing these rights with innovation in uses of data and also innovation in regulation. We also submitted that TRAI should not go as far as to recommend data protection requirements for ​‘all players in the ecosystem’, as this goes beyond the TRAI’s mandate.   More

The United Nations’ Special Rapporteur on Violence against Women, Its Causes and Consequences (‘SRVAW’) issued a call for input and information on online violence against women – particularly on the manner in which legal frameworks, courts and intermediaries in different countries recognise online abuse and provide redressal mechanisms for the same. The Internet Democracy Project made a submission outlining India’s fairly comprehensive legal framework for online abuse. We believe that the focus of all stakeholders should not be on the creation of more laws to address online abuse, since such an approach disregards the influence of prevailing social norms on the interpretation and implementation of laws in India. We therefore, made suggestions for the adoption of more non-legal measures instead.   More