Zainab Bawa

Zainab Bawa

@zainabbawa

Bhavani Seetharaman

Bhavani Seetharaman

@Bhavani-21

Anish TP

Anish TP

@anishtp

Nadika N

Nadika N

@nadikanadja

Impact of IT Rules on tech workers’ ecosystem - professional concerns

Submitted Sep 19, 2021

Introduction

As discussed in the chapter on respondent profiles, a quantitative survey was conducted with tech workers to assess awareness, understanding and impact of the IT Rules.

The survey helped to gain insights about the following questions:

  1. As frontline workers who will be tasked with implementing compliance for the mandates in the IT Rules, are developers, designers and product managers aware of the law and its impact on users of the products they build?
  2. In what ways do tech workers’ personal and professional opinions about IT Rules differ? How do the differences in the impact on professional and personal lives influence their decision to voice/not to voice concerns about the IT Rules and their participation in advocacy?
  3. Do tech companies invest in training workers about the law and legalese, and hold internal discussions about the consequent changes in processes, product, workflows and impact on customers?
  4. Do tech workers have access to independent forums, and resources to learn about IT Rules outside their organizations?

Questions were accordingly included in the survey to draw out data about tech workers’ professional and personal concerns regarding IT Rules.

Respondent demographics

Quantitative survey respondents were broadly engaged in one or more of the following three activities:

  • Coding
  • Design
  • Documentation

From these activities, we can approximately conclude that the broad category of tech workers who participated in this survey included software developers, designers and product managers (whose primary work responsibility is documentation)1. Each profile will be differently involved in the organization’s work on compliance with IT Rules. Therefore, opinions about the professional impact of IT Rules among these profiles varies2. Our hunch is that about one year after the enforcement of the IT Rules, it will be important to survey Product Managers, especially from media-tech organizations, because they will play a pivotal role in defining product features and specs to comply with IT Rules. This will have a big impact on Indian users’ experience and privacy.

This section is divided into the following three sub-sections to explain the findings:

  1. Description and analyses of work-related concerns (and impact of IT Rules) among developers, designers and product managers.
  2. Analyses and inferences about personal concerns with IT Rules.
  3. Conclusions about advocacy and participation among tech workers on tech-policy issues.

In this chapter, we will look at the work-related concerns.

In the survey, we asked tech workers how their professional roles, reporting structures and relationships within their organizations, and overall job security will be impacted by the IT Rules. The survey’s findings show that work-related concerns do not necessarily influence tech workers to to voice concerns - individually or collectively - about tech-policies such as IT Rules because their fundamental sense of job security is not threatened.

Impact of IT Rules on organizational processes and workflows

About 44% of the respondents from small, medium and large organizations opined that the IT Rules will impact organizational processes and workflows. This impact was perceived by all three roles i.e., software development, design and documentation. While the survey did not dig deeper into the specifics of workflow and process changes, the intent of this question was to understand respondents’ perceptions about how the legislation might affect their work, and transform their relationship with the structure and hierarchies in the organization.

Despite the perception that organizational processes and workflows will be impacted by IT Rules 2021, when asked about effects on organization structure, 59% of the respondents opined that there will be no effect.

Organization structure

Size Strongly benefit Offer some benefits No effect Pose challenges Seriously harm N/A Grand Total
Large 2.02% 2.02% 30.30% 14.14% 3.03% 4.04% 55.55%
Medium 12.62% 4.55% 1.52% 18.69%
Small 0.50% 16.67% 4.04% 1.01% 3.54% 25.76%
Grand Total 2.02% 2.52% 59.6% 22.73% 4.04% 9.09% 100.00%

IT Rules 2021 require organizations to hire for new roles such as the CCO and Nodal Officers. However, for frontline tech workers, there is no real impact of the presence of these officers because they don’t necessarily interact with these officers. The CCO and Nodal Officers are more likely to interact with the business heads and CXO teams. Frontline workers only have to follow the leadership’s mandates, especially in large organizations.

We also know from previous research that tech workers are rarely aware of the powers and jurisdictions that specialized roles such as the Chief Data Officer (CDO) and Privacy Officers have in their organizations. For example, the research on “Privacy Practices in the Indian Technology Ecosystem” shows that 52% of the respondents in the study reported lack of awareness about the CDO’s or Compliance Officer’s power to veto product decisions if there were real data privacy concerns3.

One of the direct impacts of any policy is compliance related work once implementation is done. Compliance processes and workflows have to be codified in every organization. Hence, tech workers will likely experience an increase in the initial workload. Later, depending on the compliance-related tasks and their periodicity - whether monthly, quarterly, half-yearly or annually - tech workers will see an increase in their responsibilities and tasks. The survey results show that 41% of the respondents perceived an increase in their daily workload.

Will workload increase due to compliance requirements?

Size No it won’t Cannot Say Yes it will N/A Grand Total
Large 7.54% 24.62% 19.60% 3.52% 55.28%
Medium 1.50% 8.04% 8.54% 0.50% 18.58%
Small 3.02% 9.05% 13.07% 0.50% 25.64%
N/A 0.50% 0.50%
Grand Total 12.06% 42.21% 41.21% 4.52% 100.00%

Among coding, design and documentation tasks, workload increase was perceived as maximum for coding-related tasks.

Additional tasks / duties for tech / development

Size Fewer tasks Same amount of tasks More tasks N/A Grand Total
Large 2.00% 17.09% 33.67% 2.52% 55.28%
Medium 0.50% 5.53% 11.06% 1.50% 18.59%
Small 8.54% 16.08% 1.01% 25.63%
N/A 0.50% 0.50%
Grand Total 2.50% 31.16% 61.31% 5.03% 100.00%

In a session on IT Rules conducted by Medianama, Kawaljit Singh Bedi, CTO at NDTV, explained the steps involved in doing compliance for IT Rules:

  • Anyone can file a complaint against any intermediary. The intermediary has to respond within 24 hours. The intermediary must also take a decision within 15 days on how to act on the complaint.
  • All action taken for a complaint has to be put on a ‘publicly displayed website’. Information about the details of the complaint received, response the intermediary gave, and the action taken have to be mentioned on the public website.

Kawaljit concluded that such compliance involves a great deal of paperwork and is very onerous. He also explained that organizations cannot reduce the burden of compliance by programming technical filters for batching complaints that can be sent to the junior staff to handle. This is because every complaint has to be treated with the same level of seriousness, where the company’s legal personnel, compliance officer and editor(s) have to be consulted on how to respond to the complaint and what action has to be taken4.

Corresponding to Kawaljit’s point about the requirement to document complaints and complaints handling process, survey respondents also reported an increase in documentation tasks i.e., many respondents perceived that documentation and reporting requirements will go up as part of the compliance with the IT Rules.

Role Fewer tasks Same amount of tasks More tasks N/A Grand Total
Code 1% 17.09% 31.66% 2.52% 52.27%
Design 6.53% 13.57% 1.01% 21.11%
Documentation 1% 2.01% 9.55% 0.50% 13.06%
None of the above 0.50% 5.53% 6.53% 1.0% 13.56%
Grand Total 2.50% 31.16% 61.31% 5.03% 100.00%

Impact of IT Rules on tech workers’ job security

Most respondents reported no impact on their job security, though 28% of the respondents expressed challenges to their job security. It is unclear whether the latter group felt that the challenges to their job security will stem from their personal opinions about the IT Rules (and if these are expressed in public forums). Nevertheless, the point of this question was to understand whether a law has the effect of putting an entire segment of workers in industry and society into uncertainty, which then leads to larger changes including increased consciousness among workers. The IT sector has often been considered a producer of precarious work5, due to the long hours, lack of protection and large-scale retrenchment6. It is therefore important to understand whether tech workers are sensitive to any changes in policy that might affect their job security.

Job security in the current market

Size of org Strongly benefit Offer some benefits No effect Pose challenges Seriously harm N/A Grand Total
Large 2.01% 2.01% 25.13% 17.09% 6.02% 3.01% 55.27%
Medium 0.50% 0.50% 13.07% 2.51% 1.01% 1.01% 18.59%
Small 1.01% 2.01% 13.57% 8.04% 1.01% 0.50% 26.14%
Grand Total 3.52% 4.52% 51.76% 27.64% 8.04% 4.52% 100.00%
Roles Strongly benefit Offer some benefits No effect Pose challenges Seriously harm N/A Grand Total
Code 1.51% 2.52% 31.16% 11.56% 3.52% 2.01% 52.28%
Design 0.50% 1.00% 10.05% 7.04% 1.01% 1.51% 21.11%
Documentation 1.51% 0.50% 6.03% 4.52% 1.51% 13.06%
None of the above 1.00% 0.50% 4.52% 4.52% 2.01% 1.00% 13.55%
Grand Total 3.52% 4.52% 51.76% 27.64% 8.04% 4.52% 100.00%

Similarly, across coding, design and documentation, nearly 50% of the tech workers don’t see any significant impact on job security.

Job opportunities

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To probe further into how tech workers perceived the impact of IT Rules on their organizations and consequently on job security, we asked questions about upskilling, cost of compliance and likelihood of criminal liability on their organizations, and other such fallouts of the IT Rules

Need for upskilling

Despite the vehement agreement about increase in workload and compliance-related tasks, tech workers do not simultaneously perceive the need to learn new skills to do compliance. Perhaps this reticence about learning new skills also stems from the fact that no new job opportunities will open up as a result of IT Rules, as discussed above.

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Impact on the organization in terms of costs of compliance

As the table below shows, 42% of the respondents felt that the IT Rules will pose challenges to their organizations in terms of costs of compliance and increase in associated expenses. Interestingly, respondents from medium-sized organizations were most vocal about the increase in costs of compliance to their organizations.

Size of organization Strongly benefit Offer some benefits No effect Pose challenges Seriously harm N/A Grand Total
Large 1% 2.53% 18.69% 22.22% 6.57% 4.55% 55.56%
Medium 8.08 9.09% 1% 0.5% 18.67%
Small 0.51% 1% 8.59% 10.61% 1.52% 3.54% 25.77%
Grand Total 1.51% 3.53% 35.36% 41.92% 9.09% 8.59% 100.00%

Imposition of criminal liability or punishment due to non-compliance

To probe work-related concerns further, the survey asked tech workers to share concerns about whether their organizations will be punished or held criminally liable owing to non-compliance.

Size of the organization Yes I have read the rules but I am unsure I have not read the rules and I don’t know No N/A Other Grand Total
Large 18.18% 15.66% 14.65% 4.04% 2.53% 0.51% 55.57%
Medium 4.04% 5.56% 7.07 2% 18.67%
Small 10.1% 5.56% 5.05% 2.02% 2.02% 1.01% 25.76%
Grand Total 32.32% 26.78% 26.77% 8.06% 4.55% 1.52% 100.00%

Nearly 33% of the respondents share the fear of punishment and criminal liability for their organizations. More than 50% of the respondents were either unsure or unaware whether IT Rules will impose such penalties on their organizations. Among respondents who said that the Rules will not impact their organizations, they likely viewed the Rules as applicable only to media-tech organizations, and not applicable to their organizations/workplaces which operated in other domains.

Impact on professional life

Overall, tech workers opined that they were unable to predict the impact of IT Rules on their professional lives, including questions about changes in job roles, job security and even the need for upskilling.

Will the IT Rules affect your professional life?

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In this chapter, we have discussed how tech workers perceive the impact of IT Rules on their professional lives, including changes in the structure, workflows and processes inside their organizations. Tech workers are unable to fathom the impact of the IT Rules in this regard.

As explained in the chapter on respondent profiles, awareness about IT Rules is far lesser among the lower rungs of the organizational hierarchy i.e., tech workers in junior roles - less than 5 years’ experience - have less awareness and therefore understanding about the Rules. It is unclear whether organizations make significant investments in creating awareness about tech-policy developments and impact on business/product among junior tech workers.

Privacy Mode’s research on privacy practices in the technology ecosystem found that over a third of respondents’ organizations lacked forums in which employees can discuss and debate privacy needs and tools. The current survey substantiates this finding, in that tech workers feel they lack the know-how and/or spaces to discuss how IT Rules will impact their work and how they can mitigate any effects. This lack of awareness leads to vacuums inside organizations, as tech workers don’t understand the impact of their work (in relation to tech-policy implementation) on their organization and on society in general.

The tech workers’ survey reveals that the strongest professional impact of the IT Rules is the increase in workload and compliance-related tasks. As we saw, tech workers reported a potential increase in coding and documentation tasks following enforcement of IT Rules.

Finally, tech workers reported fears and concerns of criminal liability and punitive action on their organization due to non-compliance. Despite this fear, respondents did not report threats to job security. Since there is no immediate fear of losing jobs, and neither is there awareness of the larger impact of IT Rules on their organizations, tech workers do not feel urgency or the need to voice concerns about the legality and unconstitutional nature of IT Rules in the public domain. Instead, they are more concerned about the impact of IT Rules on their personal lives, but are reticent to articulate the same. We examine personal concerns in the next chapter.


  1. Respondents’ personal information such as company name and designation were not asked in the survey questionnaire. This was done to preserve respondents’ privacy and anonymity. 

  2. Opinions about the impact of IT Rules on work also depend on the domain that individual respondents are working in. For example, a product manager from a health-tech firm concluded that IT Rules are not of direct concern for their organization. Instead, HIPAA compliance is far more important. 

  3. Hasgeek: Privacy practices in the Indian technology ecosystem https://hasgeek.com/PrivacyMode/privacy-in-indian-tech-2020/sub/analysis-of-survey-responses-KKbY5mYjoDtZuP3d62fHsX 

  4. Medianama: The Impact of IT Rules 2021 on News https://www.youtube.com/watch?v=tEb0YHQSWLo&t=223s 

  5. Platypus, the CASTAC blog: Precarity, Exclusion, and Contract Work in the Tech Industry https://blog.castac.org/2019/05/precarity-in-tech/ 

  6. Livemint: Mass Layoffs Brewing in IT Sector Amid Uncertainties https://www.livemint.com/companies/news/mass-layoffs-brewing-in-it-sector-amid-uncertainties-11594174446353.html 

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