A national data governance framework policy is a much-needed step in the direction of unlocking public data for various purposes: from improving service delivery, spurring innovation, to even assisting in the fight against misinformation. The World Health Organisation (WHO) recently highlighted the lack of trustworthy information as a major source of risk, impacting the implementation of crucial policy decisions made during the pandemic. Enhancing data collection, storage, processing, dissemination and use of data in decision-making, while safeguarding privacy and security, is a key step.
However, three key aspects need to be considered for the effective implementation of the policy. First, there has to be an assessment of the implementation capacity of the proposed institutions. For instance, the policy envisions that the proposed India Data Management Office (IDMO) will perform multiple strategic and operational responsibilities. The IDMO is expected to design and execute all aspects of the framework, right from identification, storage and management of datasets to ensuring accessibility, availability, responsible usage and governance of these datasets. The policy also puts the onus of capacity building and enforcement on the IDMO. Given the expansive list of roles and responsibilities allocated to the IDMO, it seems that the policy has positioned the unit as a silver bullet to tackle the issue of government departments operating in silos, which has plagued effective data sharing and accessibility in India.
Second, the learnings and experience of implementing previous policies should inform the roadmap for the current one. For instance, the National Data Sharing and Accessibility Policy (NDSAP), 2012 which also aimed to improve the accessibility of government data, has faced several hiccups in its decade-long run that deserve particular attention. This is discussed in further detail in the note.
Finally, the policy will have to align with other existing and proposed data regulations and policies in the country that attempt to govern data. These include existing open government data policies, future data protection legislation and plans for improving data sharing by private companies to build a coherent data governance ecosystem in the country.
Overall, the present draft of the policy provides a high-level overview of the envisioned National Data Governance Framework. The policy needs to provide more detail to make the public consultation process more effective. In our response, we highlight some of the gaps in the policy and provide recommendations that can inform its final draft and implementation. These include detailed recommendations on building a publicly accessible catalogue for the proposed datasets program, charting the jurisdictional clarity of the proposed policy and institutions, and establishing a grievance redressal mechanism independent of the proposed institutions.
