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FinTech in India: A Study of Privacy and Security Commitments

Posted by Aayush Rathi and Shweta Mohandas at Apr 30, 2019 10:00 PM |
The unprecedented growth of the fintech space in India has concomitantly come with regulatory challenges around inter alia privacy and security concerns. This report studies the privacy policies of 48 fintech companies operating in India to better understand some of these concerns.

 

Access the full report: Download (PDF)

The report by Aayush Rathi and Shweta Mohandas was edited by Elonnai Hickok. Privacy policy testing was done by Anupriya Nair and visualisations were done by Saumyaa Naidu. The project is supported by the William and Flora Hewlett Foundation.


In India, the Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011 (subsequently referred to as SPD/I Rules) framed under the Information Technology Act, 2000 make privacy policies a ubiquitous feature of websites and mobile applications of firms operating in India. Privacy policies are drafted in order to allow consumers to make an informed choice about the privacy commitments being made vis-à-vis their information, and is often the sole document that lays down a companies’ privacy and security practices.In India, the Information Technology (Reasonable Security Practices andProcedures and Sensitive Personal Data or Information) Rules, 2011 (subsequently referred to as SPD/I Rules) framed under the Information Technology Act, 2000 make privacy policies a ubiquitous feature of websites and mobile applications of firms operating in India. Privacy policies are drafted in order to allow consumers to make an informed choice about the privacy commitments being made vis-à-vis their information, and is often the sole document that lays down a companies’ privacy and security practices.

The objective of this study is to understand privacy commitments undertaken by fintech companies operating in India as documented in their public facing privacy policies. This exercise will be useful to understand what standards of privacy and security protection fintech companies are committing to via their organisational privacy policies. The research will do so by aiming to understand the alignment of the privacy policies with the requirements mandated under the SPD/I Rules. Contingent on the learnings from this exercise, trends observed in fintech companies’ privacy and security commitments will be culled out.

 

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