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: https://innovate.mygov.in/data-protection-in-india/

Submission Guidelines:

Submission guidelines for commenting on the White Paper are available at: https://innovate.mygov.in/wp-content/uploads/2017/11/Guidelines.pdf

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: https://papers.ssrn.com/sol3/papers.cfm?abstract_id=3102810

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: http://rdcu.be/ERhO

Here is the full citation, with URL:

Dixon, Pam. Health Technol. (2017) 7: 539. https://doi.org/10.1007/s12553-017-0202-6

You can see more of our work on National IDs here: https://www.worldprivacyforum.org/2017/07/national-ids-around-the-world/

And more of our work, including video, on India, here: https://www.worldprivacyforum.org/2013/03/privacy-in-india-video-series/

Posted January 16, 2018 in Aadhaar, Biometrics, Cybersecurity, International Privacy, National ID, Region: India

New Report: Risky Analysis: Assessing and Improving AI Governance Tools

We are pleased to announce the publication of a new WPF report, “Risky Analysis: Assessing and Improving AI Governance Tools.” This report sets out a definition of AI governance tools, documents why and how these tools are critically important for trustworthy AI, and where these tools are around the world. The report also documents problems in some AI governance tools themselves, and suggests pathways to improve AI governance tools and create an evaluative environment to measure their effectiveness. AI systems should not be deployed without simultaneously evaluating the potential adverse impacts of such systems and mitigating their risks, and most of the world agrees about the need to take precautions against the threats posed. The specific tools and techniques that exist to evaluate and measure AI systems for their inclusiveness, fairness, explainability, privacy, safety and other trustworthiness issues — called in the report collectively AI governance tools – can improve such issues. While some AI governance tools provide reassurance to the public and to regulators, the tools too often lack meaningful oversight and quality assessments. Incomplete or ineffective AI governance tools can create a false sense of confidence, cause unintended problems, and generally undermine the promise of AI systems. The report contains rich background details, use cases, potential solutions to the problems discussed in the report, and a global index of AI Governance Tools.
National IDs Around the World — Interactive map

About this Data Visualization: This interactive map displays the presence...
Report: From the Filing Cabinet to the Cloud: Updating the Privacy Act of 1974

This comprehensive report and proposed bill text is focused on the Privacy Act of 1974, an important and early Federal privacy law that applies to the government sector and some contractors. The Privacy Act was written for the 1970s information era -- an era that was characterized by the use of mainframe computers and filing cabinets. Today's digital information era looks much different than the '70s: smart phones are smarter than the old mainframes, and documents are now routinely digitized and stored and perhaps even analyzed in the cloud, among many other changes. The report focuses on why the Privacy Act needs an update that will bring it into this century, and how that could look and work. This work was written by Robert Gellman, and informed by a two-year multi-stakeholder process.

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

White paper and submission information and guidelines:

Draft comments on the white paper:

Background on Aadhaar:

Related: