Comments Due on India’s Data Protection White Paper; Info, resources, & draft comments


The government of India has published an important white paper discussing its approach to data protection legislation, White Paper of the Committee of Experts on Data Protection Framework for India. The government of India is accepting comments on its white paper until January 31, 2018.

This paper is particularly important because of its future impact on legislation that will determine the data protection rules regarding the Aadhaar national biometric ID ecosystem. Aadhaar is now mandatory in India, and has been controversial for its lack of data protection and its data breaches, among other issues. WPF has done extensive in-field research in India regarding the Aadhaar ecosystem, and knowing the importance of what is at stake here, WPF will be submitting comments. Here is a guide to help those who would like to comment.

White paper and submission information and guidelines:

Due Date:

January 31, 2018, IST.

White Paper: 

White Paper of the Committee of Experts on Data Protection Framework for India is available at:

Submission Guidelines: 

Submission guidelines for commenting on the White Paper are available at:

If you plan to submit comments, please be advised that comments are due Jan. 31, 2018 in India Standard Time. Plan to submit a full day early to avoid any time-zone mishaps, particularly if you are filing from North America or the EU region. The World Clock meeting planner will help with time zone details.

Draft comments on the white paper:

Dr. Graham Greenleaf, the leading Asia privacy and data protection expert, has drafted substantive, thorough comments on the White Paper. Dr. Greenleaf has posted his draft comments on SSRN to assist those who are writing comments.  He has requested that citations made to his document note that the comments are a draft, and to provide a URL to the comments on SSRN.

Here is the full citation, with URL:

Greenleaf, Graham, Data Protection: A Necessary Part of India’s Fundamental Inalienable Right of Privacy – Submission on the White Paper of the Committee of Experts on a Data Protection Framework for India (January 16, 2018). Available at SSRN:

Background on Aadhaar:

For those who would like a background on Aadhaar, I have written an extensive original paper on the Aadhaar ecosystem and its policies, A Failure to “Do No Harm” — India’s Aadhaar biometric ID program and its inability to protect privacy in relation to measures in Europe and the U.S.  This research was conducted in India from 2010 onwards, and was published in a special issue of Springer-Nature in June 2017. My research article is available free of charge via open access. You can access the paper here:

Here is the full citation, with URL:

Dixon, Pam. Health Technol. (2017) 7: 539.  



You can see more of our work on National IDs here:

And more of our work, including video, on India, here: