These are a set of preliminary remarks put together to address some of the issues around the text of the draft available for feedback. We think that the draft needs better consultation and factor in elements of data protection which it currently lacks.

The text of this draft is available at this link
A topic map is also available at this link

The complete length of the document for such a policy is curious. It is short 11 pages which would indicate that certain essential elements are not adequately explained or clarified
The absence of a robust data governance and regulatory framework creates a set of issues around monetizing the datasets - which is clearly marked out as the objective
Reviewing the objectives and purposes it is clear that the draft has more focus on data exchange and monetization whereas the citizen focused objectives are smaller in number (refer to the mindmap)
The policy talks about High Value Datasets (HVDs) but does not quite clarify how these are identified, selected and determined to have specific rights related to choice. Data retention and shelf life of HVDs are not clarified
There are technical inaccuracies in the draft around mentions of data anonymization and it does not make it adequately clear the process of enabling such anonymization will make it irreversible
It discusses monetization but does not go into the model through which States and the Union Government (and ministries) collaborate and the consequences of designing an economic model around citizen data shared with a plethora of 3rd parties
The “data sharing toolkit” does not have adequate details around guardrails for mitigating risk. It defers the method to the ‘negative list’ which is unlikely to be adequate and sufficient considering the scope of data under discussion.

Policy Reviews

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