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Representations to Government

Our positions on governmental policies and papers

C-DEP provided representations to the Minister of Home Affairs and Additional Secretary, MeitY on the consideration of banned Chinese mobile applications reappearing in the Indian app ecosystem post the imposed ban. Specifically, it was pointed out that ‘Kwai’, a banned application under Beijing Kuaishou Technology Co., has come back into popular app stores retitled as ‘Snack Video’ operating under Symphony Tech Pte. Ltd., a Singapore based entity owned by the same Beijing Kuaishou Technology Co.
The application was highlighted for consideration after it was discovered that it posed similar significant data and security risks to Indian citizens and Indian National Systems as the previously banned ‘Kwai’ app, especially with regards to the applications ability to;

  1. Acquire user permissions that granted access to critical and sensitive personal data
  2. Circumvent Indian privacy laws protecting underage users from data acquisition and leakage
  3. Censor and alter media content within the application designed to maliciously target specific personal and societal entities.
  4. Deploy predatory behavior making it possible for the application to misuse sensitive user data.
The files submitted to the Ministry can be found below:

C-DEP was invited to provide inputs to the Data Governance Committee, headed by Mr. Gopalakrishnan, on the following aspects;

  1. To address privacy concerns
  2. To create incentives for the free flow of data
  3. To provide certainty and incentives for new business creation.
  4. To improve competition
  5. To protect economic benefits of citizens and communities
  6. To understand better the uses and benefits of data
  7.  To prevent predatory apps from misusing user data
  8. To encourage a single source of truth for government data

C-DEP was requested to provide expert comments to Ministry of Commerce on the National Digital Health Blueprint. Some of the key inputs made centered around issues of;

  1. Evaluation of number of entities involved – Could translate to integrity of data becoming a huge loss, that could result in information loss and transfer of blame.
  2. Evaluation of Data collection and maintenance – Quality of captured data and its validation at the capture source would need to be done regularly.
  3. Enterprise approach – Advocacy of distributed ledger over C.E.P
  4. Data and information security
  5. Use of Blockchain as a more flexible, scalable and cheaper alternative, while addressing privacy concerns through certain mechanisms.
  6. Opening up the system to private sector through API’s in order to provide collaborative governance
  7. Having a single source of truth for data

C-DEP provided directional inputs to Ministry of Commerce on Cloud Computing & Local Data storage as the potential next generation export of IT Services.

Some key inputs included, but were not limited to;

  1. Recognising India as a global powerhouse in software infrastructure and application software, facilitating export of Cloud computing services would provide a platform to application developers to tap international markets which otherwise involves significant cost of sales through alternate sales channels.
  2. Necessary to locate cloud computing infrastructure close to cheap, inflation-proof sources of electricity (areas close to Hydel power would be ideal for such infrastructure). In this context, it would also be prudent to adopt Green Computing, i.e. computing powered by green sources of electricity, so as to reduce carbon footprint of computing.
  3. Imperative to adopt appropriate policies to notify and create Cloud Computing Parks in the Himalayan States, with sufficient bandwidth.
  4. Focus to be put on trans-border legislations that inhibit the export of Cloud Computing Services.
  5. Need for stable regulatory requirement.

C-DEP was requested to provide inputs on Implementation Guidelines that focused on, but not limited to issues on;

  1. Ensuring Service Level Agreements of Database Scalability – Best Practices to be adopted by API owners in terms of data coupled with rigorous testing before APIs go live.
  2. Due consideration to be given to supporting the service in terms of the SLAs.
  3. From a commercial standpoint, API owners ought to be compensated for the task of exposing data and ensuring the upkeep of the services.
  4. Greater need to look into creation of CivicTech to enable the Government to move towards a regime of API driven government (Open API Policy).

C-Dep was invited to provide  expert comments to Ministry of Commerce on the Draft National Strategy for AI.

The Report aims to bring focus on how India can leverage the transformative technologies to ensure social and inclusive growth in line with the development philosophy of the government. The approach advocates identifying sectors that may have the potential of greatest externalities while adopting AI solutions, and hence require the government to play a leading role in developing the implementation roadmap for AI.

Some of the important considerations put forward by C-DEP was to put a greater focus for AI in sectors of Manufacturing, eCommerce, Service delivery and Transportation, which would have a transformative effect on India.

Additionally, it was recommended that the initiative needs to be commercially led in order to be sustainable and to have a greater impact on economy and jobs. Therefore, there is a need to have a sustained program to evangelize AI with the corporates and to provide them with incentives to be early adopters of AI in their domain of operations.

C-DEP was invited to comment on the Draft Competition Act as well as provide observations and feedback on the proposed amendments to the Competition Act.

Some key pointers, highlighted were;

  1. Recommendation to amend the act to incorporate digital monopolies as they are anti-competitive in nature as they natural monopolies due to network effect (such as messaging systems) or are due to data.
  2. Exchange of data and exchange of exposure to advertisements or advocacy on websites (particularly Social Media platforms) should be recognised as a ‘trade and sale’. Such forms of purchase should also be within the ambit of the Competition Act.
  3. It was advocated that penalties be based on income as well as revenue as Large companies in the digital domain choose to stay as loss making in order to avoid anti-competition regulation. Their income may be negative but they have extremely large turnovers and would display anti-competitive behavior.
  4. Recommended that anti-competitive behavior in the digital world should include blocking access to known personalities who could endorse apps, thereby monopolizing certain sectors such as gaming wherein all key known figures are blocked by one or two apps, thereby creating a monopoly

C-Dep was requested to provided observations and feedback on the Draft National Logistics Policy.

  • Promoted API based integration with private sector
  • Promoted single source of truth for all data related to logistics