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Submitted Comments on the Telangana State Open Data Policy 2016
http://editors.cis-india.org/openness/comments-on-the-telangana-state-open-data-policy-2016
<b>Last month, the Information Technology, Electronics & Communications Department of the Government of Telangana released the first public draft of the Telangana State Open Data Policy 2016, and sought comments from various stakeholders in the state and outside. The draft policy not only aims to facilitate and provide a framework for proactive disclosure of data created by the state government agencies, but also identify the need for integrating such a mandate within the information systems operated by these agencies as well. CIS is grateful to be invited to submit its detailed comments on the same. The submission was drafted by Anubha Sinha and Sumandro Chattapadhyay.</b>
<p> </p>
<p><strong>Download the submitted document: <a href="http://cis-india.org/openness/files/cis-telangana-state-open-data-policy-v-1-submission/at_download/file">PDF</a>.</strong></p>
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<h3><strong>1. Preliminary</strong></h3>
<p><strong>1.1.</strong> This submission presents comments and recommendations by the Centre for Internet and Society (“CIS”) <strong>[1]</strong> on the proposed draft of the Telangana Open Data Policy 2016 (“the draft policy”). This submission is based on Version 1 of the draft policy shared by the Information Technology, Electronics & Communications Department, Government of Telangana (“the ITE&C Department”).</p>
<p><strong>1.2.</strong> CIS commends the ITE&C Department for its generous efforts at seeking inputs from various stakeholders to draft an open data policy for the state of Telangana. CIS is thankful for this opportunity to provide a clause-by-clause submission.</p>
<h3><strong>2. The Centre for Internet and Society</strong></h3>
<p><strong>2.1.</strong> The Centre for Internet and Society, CIS, is a non-profit organisation that undertakes interdisciplinary research on internet and digital technologies from policy and academic perspectives. The areas of focus include digital accessibility for persons with diverse abilities, access to knowledge, intellectual property rights, openness (including open data, free and open source software, open standards, open access, open educational resources, and open video), internet governance, telecommunication reform, digital privacy, and cyber-security. The academic research at CIS seeks to understand the reconfiguration of social processes and structures through the internet and digital media technologies, and vice versa.</p>
<p>2.2. This submission is consistent with CIS’ commitment to safeguarding general public interest, and the interests and rights of various stakeholders involved. The comments in this submission aim to further the principle of citizens’ right to information, instituting openness-by-default in governmental activities, and to realise the various kinds of public goods that can emerge from greater availability of open (government) data. The submission is limited to those clauses that most directly have an impact on these principles.</p>
<h3><strong>3. Comments and Recommendations</strong></h3>
<p><em>This section presents comments and recommendations directed at the draft policy as a whole, and in certain places, directed at specific clauses of the draft policy.</em></p>
<h3>3.1. Defining the Scope of the Policy in the Preamble</h3>
<p><strong>3.1.1.</strong> CIS observes and appreciates that the ITE&C Department has identified the open data policy as a catalyst for, and as dependent upon, a larger transformation of the information systems implemented in the state, to specifically ensure that these information systems.</p>
<p><strong>3.1.2.</strong> CIS commends the endeavour of the draft policy to share data in open and machine-readable standards. To further this, it will be useful for the preamble to explicitly mandate proactive disclosure in both human-readable and machine-readable formats, using open standards, and under open license(s).</p>
<p><strong>3.1.3.</strong> CIS recommends that the draft policy state the scope of the policy at the outset, i.e. in the Preamble section of the document. This will provide greater clarity to the stakeholders who are trying to ascertain applicability of the draft policy to their data.</p>
<p><strong>3.1.4.</strong> CIS commends the crucial mandate of creating data inventory within every state government ministry / department. We further recommend that the draft policy also expressly states the need to make these inventories publicly accessible.</p>
<p><strong>3.1.5.</strong> CIS commends the draft policy’s aim to build a process to engage with data users for better outcomes. We suggest that the draft policy also enumerates the “outcomes” of such engagement, in order to provide more clarity. We recommend that these “outcomes” include greater public supply of open government data in an effective, well-documented, timely, and responsible manner.</p>
<p><strong>3.1.6.</strong> Further, CIS suggests that the draft policy define “information centric and customer centric data” to provide more clarity to the document, as well as its scope and objectives.</p>
<h3>3.2. Provide Legal and Policy References</h3>
<p><strong>3.2.1.</strong> Strengthening transparency, predictability, and legal certainty of rules benefits all stakeholders. Thus, as far as possible, terms in the draft policy should use pre-existing legal definitions. In case of ambiguities arising after the implementation of the policy, consistency in definitions will also lead to greater interpretive certainty. It must be noted that good quality public policies which promote legal certainty, lead to better implementation.</p>
<p><strong>3.2.2.</strong> CIS observes that the draft policy re-defines various terms in Section 4 that have already been defined in National Data Sharing and Accessibility Policy (“NDSAP”) 2012 <strong>[2]</strong>, the Right to Information 2005 (“RTI Act”) <strong>[3]</strong>, and IT (Reasonable security practices and procedures and sensitive personal data or information) Rules 2011 <strong>[4]</strong>. We strongly recommend that the draft policy uses the pre-existing definitions in these acts, rules, and policies.</p>
<p><strong>3.2.3.</strong> Further, CIS observes that while certain sections accurately reflect definitions and parts from other acts, rules and policies, such sections are not referenced back to the latter. These sections include, but are not limited to: Sections 3, 7, 8, 4 (definitions of Data set, Data Archive, Negative list, Sensitive Personal data). We strongly recommend that accurate legal references be added to the draft policy after careful study of the language used.</p>
<h3>3.3. Need for More Focused Objective Statement</h3>
<p><strong>3.3.1.</strong> While the draft policy has a very comprehensive statement of its objectives, including "<em>all issues related to data in terms of the available scope of sharing and accessing spatial and non-spatial data under broad frameworks of standards and interoperability</em>," it may consider offering a more focused statement of its key objective, which is to provide a policy framework for proactive disclosure of government data by the various agencies of the Government of Telangana.</p>
<p><strong>3.3.2.</strong> Further, the objective statement must clearly state that the policy enables publication of data created by the agencies of the Government of Telangana, and/or by private agencies working in partnership with public agencies, using public funds as open data (that is, using open standards, and under open license). The present version of the objective statement mentions "<em>sharing</em>" and "<em>accessing</em>" the data concerned under "<em>broad frameworks of standards and interoperability</em>" but does not make it clear if such shared data will be available in open standards, under open licenses, and for royalty-free adaptation and redistribution by the users concerned.</p>
<h3>3.4. Suggestions related to the Definitions</h3>
<p><strong>3.4.1.</strong> The term “Data” has not been defined in accordance with NDSAP 2012. We suggest that the definition provided in NDSAP is followed so as to ensure legal compatibility.</p>
<p><strong>3.4.2.</strong> The term “Sensitive Personal Data” seems to have been defined on the basis of the definition provided in the IT (Reasonable security practices and procedures and sensitive personal data or information) Rules 2011. Please add direct reference so as to make this clear. We further suggest that the term “Personal Information”, also defined in the same IT Rules, is also included and referred to in the draft policy, so that not only Sensitive Personal Data is barred from disclosure under this policy, but also Personal Information (that is "<em>any information that relates to a natural person, which, either directly or indirectly, in combination with other information available or likely to be available with a body corporate, is capable of identifying such person</em>") <strong>[5]</strong>.</p>
<p><strong>3.4.3.</strong> The term “Negative List” is defined in a manner that allows the state government ministries and agencies to identify which data are to be considered as non-shareable without any reference to an existing policy framework that list acceptable grounds for such identification. The term must be defined more restrictively, as this definition can allow an agency to avoid disclosure of data that may not be legally justifiable as non-shareable or sensitive. Thus, we recommend a more limited definition which may draw upon the RTI Act 2005, and specifically consider the factors mentioned in Sections 8 and 9 of the Act as the (only) set of acceptable reasons for non-disclosure of government data.</p>
<p><strong>3.4.4.</strong> The terms “Shareable Data” and “Sensitive Data” are used in several places in the draft policy but are not defined in Section 4. Both these terms are defined in NDSAP 2012. We suggest that both these terms be listed in Section 4, in accordance with the respective definitions provided in NDSAP 2012.</p>
<p><strong>3.4.5.</strong> The terms “Data Archive”, “Data Acquisition”, “Raw Data”, “Standards-Compliant Applications”, and “Unique Data” are defined in Section 4, but none of these terms appear elsewhere in the draft policy. We suggest that these terms are either better integrated into the document, or may not be defined at all.</p>
<h3>3.5. Rename Section 6 to Focus on Implementation of the Policy</h3>
<p><strong>3.5.1.</strong> Though the Section 6 is named as “Shareable Data”, it instead categorically lists down how the policy is to be implemented. This is a very welcome step, but the Section title should reflect this purpose of the Section.</p>
<p><strong>3.5.2.</strong> The decision proposed in the draft policy to make it mandatory for "<em>each funding organization</em>" to "<em>highlight data sharing policy as preamble in its RFPs as well as Project proposal formats</em>" is much appreciated and commendable. For a clearer and wider applicability of this measure, we recommend that this responsibility should apply to all state government agencies, including agencies where the state government enjoys significant stake, and all public-private partnerships entered into by the state government agencies, and not only to "<em>funding organizations</em>" (a term that has also not been defined in the draft policy).</p>
<p><strong>3.5.3.</strong> While the Section details out various measures and steps of implementation of the policy, it does not clarify which agency and/or committee would have the authority and responsibility to coordinate, monitor, facilitate, and ensure these measures and steps. Not only governmental representatives but also non-governmental representatives may be considered for such a committee.</p>
<h3>3.6. Host All Open Government Data in the State Portal</h3>
<p><strong>3.6.1.</strong> We observe that the Section 6 indicates that , the designated domain for the open government data portal for the state of Telangana, will only store metadata related to the proactive disclosed data sets but not the data sets themselves. This is further clarified in Section 10. We strongly urge the ITE&C Department to reconsider this decision to not to store the actual open data sets in the state open government data portal itself but in the departmental portals. A central archive of the open data assets, hosted by the state open government data portal, will allow for more effective and streamlined management of the open data assets concerned, including their systematic backing-up, better security and integrity, permanent and unique disclosure, and rule-driven updation. This would also reduce the burden upon all the government agencies, especially those that do not have a substantial IT team, to run independent department-specific open data portals.</p>
<h3>3.7. Reconsider the Section on Data Classification</h3>
<p><strong>3.7.1.</strong> While it is clear that the Section 7 on Data Classification follows the classification of various data sets created, managed, and/or hosted by government agencies offered in the NDSAP 2012, it is not very clear what role this classification plays in functioning and implementation of the draft policy. While Open Access and Registered Access data may both be considered as open government data that is to be proactively disclosed by the state government agencies via the state open government data portal, the Restricted Access data overlaps with the kinds of data already included in the Negative List defined in the draft policy (and elsewhere, like the RTI Act 2005). Further, the final sentence in this Section ensures that all data users provide appropriate attribution of the source(s) of the data set concerned, which (though is an important statement) should not be part of this Section on Data Classification. We suggest reconsideration of inclusion of this Section.</p>
<h3>3.8. Reconsider the Section on Technology for Sharing and Access</h3>
<p><strong>3.8.1.</strong> While it is clear that the Section 8 on Technology for Sharing and Access is adapted from the Section 9 of the NDSAP 2012, the text in this Section seems to be not fully compatible with other statements in this draft policy. For example, the Section states that "<em>[t]his integrated repository will hold data of current and historical nature and this repository over a period of time will also encompass data generated by various State Government departments</em>." However, the draft policy states in Section 10 that "<em>data.telangana.gov.in will only have the metadata and data itself will be accessed from the portals of the departments</em>."</p>
<p><strong>3.8.2.</strong> We strongly urge the ITE&C Department to revise this Section through close discussion with the NDSAP Project Management Unit, National Informatics Centre, which is the technical team responsible for developing and managing the portal, since the present version of this Section lists the original feature set of the portal as envisioned in 2012 but does not reflect the most recent feature set that has been already implemented in the portal concerned.</p>
<h3>3.9. Current Legal Framework (Section 9) should List to Relevant Acts, Rules, Policies, and Guidelines</h3>
<p><strong>3.9.1.</strong> CIS observes that the draft policy attempts to lay out the applicable legal framework in Section 2 and 9 of the draft policy, and submits that the legal framework is incomplete and recommends that the draft policy lists all the following relevant acts, rules, policies and guidelines:</p>
<ol type="A">
<li>National Data Sharing and Accessibility Policy, 2012<br /><br /></li>
<li>Right to Information Act, 2005<br /><br /></li>
<li>Information Technology Act, 2002<br /><br /></li>
<li>Information Technology (Reasonable security practices and procedures and sensitive personal data or information) Rules, 2011.<br /></li></ol>
<p><strong>3.9.2.</strong> CIS submits that apart from the policies mentioned above, the implementation of the draft policy is intricately linked to concepts of "open standards," "open source software," "open API," and "right to information." These concepts are governed by specific acts and policies, and are applicable to government owned data, as follows:</p>
<ol type="A">
<li><strong>Adoption of Open Standards:</strong> CIS observes that the draft policy draws on the importance of building information systems for interoperability and greater information accessibility. Interoperability is achieved by appropriate implementation of open standards. Thus, CIS submits that the Policy on Open Standards for e-Governance <strong>[6]</strong> which establishes the guidelines for usage of open standards to ensure seamless interoperability, and the Implementation Guidelines of the National Data Sharing and Accessibility Policy, 2012 <strong>[7]</strong> should be mentioned in the draft policy.<br /><br /></li>
<li><strong>Adoption of Open Source Software:</strong> The Policy on Adoption of Open Source Software for Government of India states that the "<em>Government of India shall endeavour to adopt Open Source Software in all e-Governance systems implemented by various Government organizations, as a preferred option in comparison to Closed Source Software</em> <strong>[8]</strong>." As the draft policy proposed to guide the development of information systems to share open data is being developed and implemented both by the Government of Telangana and by other agencies (academic, commercial, and otherwise), it must include an explicit reference and embracing of this mandate for adoption of Open Source Software, for reasons of reducing expenses, avoiding vendor lock-ins, re-usability of software components, enabling public accountability, and greater security of software systems.<br /><br /></li>
<li><strong>Implementation of Open APIs:</strong> CIS observes that the draft policy refers to Standard compliant applications in Section 4. CIS suggests that final version of the policy refer to and operationalise the Policy on Open Application Programming Interfaces (APIs) for Government of India <strong>[9]</strong>. This will ensure that the openly available data is available to the public, as well as to all the government agencies, in a structured digital format that is easy to consume and use on one hand, and is available for various forms of value addition and innovation on the other. Refer to Official Secrets Act, 1923: The Official Secrets Act penalises a person if he/she "<em>obtains, collects, records or publishes or communicates to other person any secret official code or password, or any sketch, plan, model, article or note or other document or information which is calculated to be or might be or is intended to be, directly or indirectly, useful to an enemy for which relates to a matter the disclosure of which is likely to affect the sovereignty and integrity of India, the security of the State or friendly relations with foreign States</em> <strong>[10]</strong>." CIS submits that this Act should be referred to in this context of ensuring non-publication of the aforementioned data.<br /></li></ol>
<h3>3.10. Mandate a Participatory Process for Developing the Implementation Guidelines</h3>
<p><strong>3.10.1.</strong> We highly appreciate and welcome the fact that the draft policy emphasises rapid operationalisation of the policy by mandating that the ITE&C Department will prepare a detailed implementation guideline within 6 months of the notification of this policy, and all state government departments will publish at least 5 high value datasets within the next three months. Just as an addition to this mandate, we would like to propose that it can be suggested that the ITE&C Department undertakes a participatory process, with contributions from both government agencies and non-government actors, to develop this implementation guideline document. We believe that opening up government data in an effective and sustainable manner, for most government agencies, involves a systematic change in how the agency undertakes day-to-day data management practices. Hence, to develop productive and practical implementation guidelines, the ITE&C Department needs to gather insights from the other state government agencies regarding their existing data (and metadata) management practices <strong>[11]</strong>. Further, participation of the non-government actors in this process is crucial to ensure that the implementation guidelines appropriately identify the high value data sets, that is data sets that should be published on a priority basis.</p>
<h3>3.11. Defer the Decision about Roles of Data Owners, Generators, and Controllers</h3>
<p><strong>3.11.1.</strong> As the draft policy does not specifically define the terms “Data Owners”, “Data Generators”, and “Data Controllers”, and the Section 11 only briefly describes some of the roles of these types of actors, we suggest removal of this discussion and the decision regarding the specific roles and functions of the Data Owners / Generators / Controllers from the draft policy itself. It will be perhaps more appropriate and effective to define these terms, as well as their roles and functions, in the implementation guidelines to be prepared by the ITE&C Department after the notification of the open data policy, since these terms relate directly to the final designing of the implementation process.</p>
<p><strong>3.12.</strong> CIS is grateful to the ITE&C Department for this opportunity to provide comments, and would be honoured to provide further assistance on the matter.</p>
<h3><strong>Endnotes</strong></h3>
<p><strong>[1]</strong> See: <a href="http://cis-india.org/" target="_blank">http://cis-india.org/</a>.</p>
<p><strong>[2]</strong> See: <a href="http://data.gov.in/sites/default/files/NDSAP.pdf" target="_blank">http://data.gov.in/sites/default/files/NDSAP.pdf</a>.</p>
<p><strong>[3]</strong> See: <a href="http://rti.gov.in/webactrti.htm" target="_blank">http://rti.gov.in/webactrti.htm</a>.</p>
<p><strong>[4]</strong> See: <a href="http://meity.gov.in/sites/upload_files/dit/files/GSR313E_10511(1).pdf" target="_blank">http://meity.gov.in/sites/upload_files/dit/files/GSR313E_10511(1).pdf</a>.</p>
<p><strong>[5]</strong> See Section 2 (1) (i) of IT (Reasonable security practices and procedures and sensitive personal data or information) Rules 2011.</p>
<p><strong>[6]</strong> See: <a href="https://egovstandards.gov.in/sites/default/files/Published%20Documents/Policy_on_Open_Standards_for_e-Governance.pdf" target="_blank">https://egovstandards.gov.in/sites/default/files/Published%20Documents/Policy_on_Open_Standards_for_e-Governance.pdf</a>.</p>
<p><strong>[7]</strong> See: <a href="https://data.gov.in/sites/default/files/NDSAP_Implementation_Guidelines_2.2.pdf" target="_blank">https://data.gov.in/sites/default/files/NDSAP_Implementation_Guidelines_2.2.pdf</a>.</p>
<p><strong>[8]</strong> See: <a href="http://deity.gov.in/sites/upload_files/dit/files/policy_on_adoption_of_oss.pdf" target="_blank">http://deity.gov.in/sites/upload_files/dit/files/policy_on_adoption_of_oss.pdf</a>.</p>
<p><strong>[9]</strong> See: <a href="http://deity.gov.in/sites/upload_files/dit/files/Open_APIs_19May2015.pdf" target="_blank">http://deity.gov.in/sites/upload_files/dit/files/Open_APIs_19May2015.pdf</a>.</p>
<p><strong>[10]</strong> See: <a href="http://www.archive.india.gov.in/allimpfrms/allacts/3314.pdf" target="_blank">http://www.archive.india.gov.in/allimpfrms/allacts/3314.pdf</a>, Sections 2 (2) and 3 (1) (c).</p>
<p><strong>[11]</strong> A similar process was undertaken by the IT Department of the Government of Sikkim when developing the implementation guideline document. The ITE&C Department may consider discussing the matter with the said department to exchange relevant learnings.</p>
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For more details visit <a href='http://editors.cis-india.org/openness/comments-on-the-telangana-state-open-data-policy-2016'>http://editors.cis-india.org/openness/comments-on-the-telangana-state-open-data-policy-2016</a>
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No publishersumandroOpen DataOpen Government DataFeaturedPoliciesOpennessHomepage2016-09-01T05:49:51ZBlog EntrySmart City Policies and Standards: Overview of Projects, Data Policies, and Standards across Five International Smart Cities
http://editors.cis-india.org/internet-governance/blog/policies-and-standards-overview-of-five-international-smart-cities
<b>This blog post aims to review five Smart Cities across the globe, namely Singapore, Dubai, New York City, London and Seoul, the Data Policies and Standards adopted. Also, the research seeks to point the similarities, differences and best practices in the development of smart cities across jurisdictions.</b>
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<h4>Download the brief: <a href="http://cis-india.org/internet-governance/files/SmartCitiesPoliciesStandards-20160608/at_download/file">PDF</a>.</h4>
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<h2 style="text-align: justify;">Introduction</h2>
<p style="text-align: justify;">Smart City as a concept is evolutionary in nature, and the key elements like Information and Communication Technology (ICT), digitization of services, Internet of Things (IoT), open data, big data, social innovation, knowledge, etc., would be intrinsic to defining a Smart City <a href="#_ftn1">[1]</a>.</p>
<p style="text-align: justify;">A Smart City, as a “system of systems”, can potentially generate vast amounts of data, especially as cities install more sensors, gain access to data from sources such as mobile devices, and government and other agencies make more data accessible. Consequently, Big Data techniques and concepts are highly relevant to the future of Smart Cities. It was noted by Kenneth Cukier, Senior Editor of Digital Products at The Economist, that Big Data techniques can be used to enhance a number of processes essential to cities - for example, big data can be used to spot business trends, determine quality of research, prevent diseases, tack legal citations, combat crime, and determine real-time roadway traffic conditions <a href="#_ftn2">[2]</a>. Having said this, data is deemed to be the lifeblood of a Smart City and its availability, use, cost, quality, analysis, associated business models and governance are all areas of interest for a range of actors within a smart city <a href="#_ftn3">[3]</a></p>
<p style="text-align: justify;">This blog reviews five Smart Cities namely Singapore, Dubai, New York City, London and Seoul. In doing so, the research seeks to point the similarities, differences and best practices in the development of smart cities across jurisdictions. To achieve this, the research reviews:</p>
<ul style="text-align: justify;">
<li>The definition of a Smart City in a given context or project (if any).</li>
<li>Existing policy/regulations around data or notes the lack thereof.</li>
<li>The cities adherence to the International standards and providing an update on the current status of the Smart City programme.</li></ul>
<p> </p>
<h2 style="text-align: justify;">Singapore</h2>
<h3 style="text-align: justify;"><strong> </strong><strong>Introduction</strong></h3>
<p style="text-align: justify;"><strong> </strong>The Smart Nation programme in Singapore was launched on 24th November, 2014. The programme is being driven by the Infocomm Development Authority of Singapore, through which Singapore seeks to harness ICT, networks and data to support improved livelihoods, stronger communities and creation of new opportunities for its residents <a href="#_ftn4">[4]</a> According to the IDA, a Smart Nation is a city where <em>“people and businesses are empowered through increased access to data, more participatory through the contribution of innovative ideas and solutions, and a more anticipatory government that utilises technology to better serve citizens’ needs”</em> <a href="#_ftn5">[5]</a>. The Smart Nation programme is driven by a designated Office in the Prime Minister’s Office <a href="#_ftn6">[6]</a>. As a core component to the Smart Nation Programme, the Smart Nation Platform has been developed as the technical architecture to support the Programme. This Platform enables greater pervasive connectivity, better situational awareness through data collection, and efficient sharing and access to collected sensor data, allowing public bodies to use such data to develop policy and practical interventions <a href="#_ftn7">[7]</a> Such access would allow for anticipatory governance - a goal of the Smart Nation Programme as noted by Dr. Yaacob Ibrahim, Minister for Communications and Information stating “Insights gained from this data would enable us to better anticipate citizens’ needs and help in better delivery of services” <a href="#_ftn8">[8]</a>.</p>
<h3 style="text-align: justify;"><strong>Status of the Project</strong></h3>
<div style="text-align: justify;"><strong> </strong>The Smart Nation Programme is an ongoing initiative, being built on the past programme Intelligent Nation 2015 (iN2015 masterplan). The plan involves putting in place the infrastructure, policies, ecosystem and capabilities to enable a Smart Nation, by adopting a people-centric approach <a href="#_ftn9">[9]</a>. A number of co-creating solutions adopted by the Government include:</div>
<ul style="text-align: justify;">
<li>Development of Mobile Apps to facilitate communication between the public and the providers of public services.</li>
<li>Organization of Hackathons by government agencies or corporations in collaboration with schools and industry partners to ideate and develop solutions to tackle real-world challenges.</li>
<li>Adopt measure for smart mobility to create a more seamless transport experience and providing greater access to real-time transport information so that citizens can better plan their journeys.</li>
<li>Smart technologies are also being introduced to the housing estates <a href="#_ftn10">[10]</a>.</li></ul>
<h3 style="text-align: justify;"><strong>Policies and Regulations</strong></h3>
<p style="text-align: justify;"><strong> </strong>The Smart Nation plan derives its legitimacy from the constitution of Singapore, holding the Prime Minister responsible to take charge of the subject ‘Smart Nation’ blueprint under the Statutory body of ‘Smart Nation’ Programme Office <a href="#_ftn11">[11]</a>. Singapore has a comprehensive data protection law – the Personal Data Protection Act 2012, rules governing the collection, use, disclosure and care of personal data. The Personal Data Protection Commission of Singapore has committed to work closely with the private sector, and also to support the Smart Nation vision on data privacy and cyber security ecosystem <a href="#_ftn12">[12]</a> <a href="#_ftn13">[13]</a>.</p>
<p style="text-align: justify;">Towards achieving the Smart Nation vision the government has also promoted the use of open data. In 2015 the Department of Statistics has made a vast amount of data available (across multiple themes say transport, infocomm, population, etc.) for free to the public in order to encourage innovation and facilitate the Smart Nation <a href="#_ftn14">[14]</a>. Prior to this initiative, the government had adopted the Open Data Policy in 2011, enabling public data for analysis, research and application development <a href="#_ftn15">[15]</a>. The concept of Virtual Singapore, which is a part of the Smart Nation Initiative, has been developed to adopt and simulate solutions on a virtual platform using big data analytics <a href="#_ftn16">[16]</a>.</p>
<h3 style="text-align: justify;"><strong>Adoption of International Standards</strong></h3>
<p style="text-align: justify;"><strong> </strong>The Smart Nation initiative follows the standards laid under the purview of the Singapore Standards Council (SSC). It specifies three types of Internet of Things (IoT) Standards – sensor network standards (TR38 - for public areas & TR40 - for homes), IoT foundational standards (common set of guidelines for IoT requirements and architecture, information and service interoperability, security and data integrity) and domain-specific standards (healthcare, mobility, urban living, etc.) <a href="#_ftn17">[17]</a>.</p>
<p style="text-align: justify;">Singapore is part of ISO/IEC JTC 1/WG7 Sensor Networks and ISO/IEC JTC 1/WG10 Internet of Things (IoT) <a href="#_ftn18">[18]</a>. <a href="https://www.itsc.org.sg/standards/singapore-it-standards">Singapore IT standards</a> abides to the international standards as defined by ISO, ITU, etc.Singapore is a member of many international standards forums (see <a href="https://www.itsc.org.sg/international-participation/memberships-in-iso-iec-jtc1">Singapore International Standards Committee</a>) which includes JTC1/WG9 - Big Data; JTC1/WG10 - Internet of Things; JTC1/WG11 - Smart Cities.</p>
<p> </p>
<h2 style="text-align: justify;">Dubai, United Arab Emirates</h2>
<h3><strong> </strong><strong>Introduction</strong></h3>
<p style="text-align: justify;"><strong> </strong>The Dubai Smart City strategy was launched as part of the Dubai Plan 2021 vision, in the year 2015 <a href="#_ftn19">[19]</a>. Dubai Plan 2021 describes the future of Dubai evolving through holistic and complementary perspectives, starting with the people and the society and places the government as the custodian of the city’s development. Within the Plan, the smart city theme envisions a platform that is fully connected and integrated infrastructure that enables easy mobility for all residents and tourists, and provides easy access to all economic centers and social services, in line with the world’s best cities <a href="#_ftn20">[20]</a>. Center to the smart city platform is data and data analytics, particularly cross functional data and big data techniques to give a complete view of the city <a href="#_ftn21">[21]</a> As envisioned, the Dubai Data portal would provide a gateway to empower relevant stakeholders to understand the nuances of the city and pursue questions that will result in the greatest impact from the city’s data <a href="#_ftn22">[22]</a>. The platform will be based on current data and existing services, initiatives, and networks to identify opportunities for a smart city <a href="#_ftn23">[23]</a>. The Smart City Plan also includes a framework for aligning districts of Dubai with the Smart City vision and dimensions <a href="#_ftn24">[24]</a>.</p>
<p style="text-align: justify;">The Smart Dubai roadmap 2015 provides a consolidated report and planned smart city services, its status and the stage of its implementation, for e.g. Smart Grid, Mobile Payment, Smart Water, Health applications, Public Wi-Fi, Municipality, E-Traffic solutions, etc <a href="#_ftn25">[25]</a>.</p>
<h3 style="text-align: justify;"><strong>Status of the Project</strong></h3>
<p style="text-align: justify;"><strong> </strong>The Smart Dubai strategy is envisioned to be completed by the year 2020, and currently it’s ongoing. The first phase of Smart Dubai masterplan is expected to end by 2016. Between 2017 and 2019, the plan aims to deliver new initiatives and services. The second phase of the masterplan is expected to be completed by the year 2020 <a href="#_ftn26">[26]</a>.</p>
<h3 style="text-align: justify;"><strong>Policies and Regulations</strong></h3>
<p style="text-align: justify;">The Smart City Plan is being driven by the <strong>Dubai Smart City Office</strong> – which has been established under Law No. (29) of 2015 on the establishment of Dubai Smart City Office; Law No. (30) of 2015 on the establishment of Dubai Smart City Establishment; Decree No. (37) of 2015 on the formation of the Board of the Dubai Smart City Office; and Decree No (38) of 2015- appointing a Director General for the Office, which will develop overall policies and strategic plans, supervise the smart transformation process and approve joint initiatives, projects and services <a href="#_ftn27">[27]</a>. Also, an open data law called <strong>Dubai Open Data Law</strong> was issued to complete the legislative framework for transforming Dubai into a Smart City <a href="#_ftn28">[28]</a>. This law will enable the sharing of non-confidential data between public entities and other stakeholders.</p>
<h3 style="text-align: justify;"><strong>Adoption of International Standards</strong></h3>
<p style="text-align: justify;">In 2015 the Smart Dubai Executive Committee has collaborated through an agreement with the International Telecommunications Union (ITU) adopt the performance indicators by the ITU Focus Group on Smart Sustainable Cities to evaluate the feasibility of the indicators <a href="#_ftn29">[29]</a>. The Focus Group is working towards identifying global best practices for the development of smart cities <a href="#_ftn30">[30]</a>.</p>
<p> </p>
<h2 style="text-align: justify;">New York City, United States of America</h2>
<h3 style="text-align: justify;"><strong>Introduction</strong></h3>
<p style="text-align: justify;">The ‘One New York Plan’ announced in the year 2015 is a comprehensive plan for a sustainable and resilient city. It includes the adoption of digital technology and considers the importance of the role of data in transforming every aspect of the economy, communications, politics, and individual and family life <a href="#_ftn31">[31]</a>. Furthermore, through a publication on '<a href="http://www1.nyc.gov/site/forward/innovations/smartnyc.page">Building a Smart+Equitable City</a>', the Mayor’s Office of Technology and Innovation (MOTI) describes efforts to leverage new technologies to build Smart city.</p>
<p style="text-align: justify;">Accordingly, the plan seeks to establish better lives through establishing principles and strategic frameworks to guide connected device and Internet of Things (IoT) implementation; MOTI serving as the coordinating entity for new technology and IoT deployments across all City agencies; collaborating with academia and the private sector on innovative pilot projects, and partnering with municipal governments and organizations around the world to share best practices and leverage the impact of technological advancements <a href="#_ftn32">[32]</a>.</p>
<h3 style="text-align: justify;"><strong>Status of the Project</strong></h3>
<p style="text-align: justify;">OneNYC represents a unified vision for a sustainable, resilient, and equitable city developed with cross-cutting interagency collaboration, public engagement, and consultation with leading experts in their respective fields. The Mayor’s Office of Sustainability oversees the development of OneNYC and now shares responsibility with the Mayor’s Office of Recovery and Resiliency for ensuring its implementation <a href="#_ftn33">[33]</a>.</p>
<h3 style="text-align: justify;"><strong>Policies and Regulations</strong></h3>
<p style="text-align: justify;">As per the Local Law 11 of 2012, each City entity must identify and ultimately publish all of its digital public data for citywide aggregation and publication by 2018. In adherence to this law, there exists a NYC Open Data Plan which requires annual data updation <a href="#_ftn34">[34]</a>.</p>
<p style="text-align: justify;">The LinkNYC initiative, one of the key projects to make New York a ‘smart’ city, aims to connect everyone through a city wide wi-fi network. The LinkNYC initiative will retrofit payphones with kiosks to provide high-speed WiFi hotspots and charging stations for increased connectivity <a href="#_ftn35">[35]</a>. Data Privacy in the initiative is addressed through the customer first privacy policy, which considers user’s privacy on priority and will not sell any personal information or share with third parties for their own use. LinkNYC will use anonymized, aggregate data to make the system more efficient and to develop insights to improve your Link experience <a href="#_ftn36">[36]</a>.</p>
<h3 style="text-align: justify;"><strong>Adoption of International Standards</strong></h3>
<p style="text-align: justify;">The ANSI Network on Smart and Sustainable Cities (ANSSC) is a forum for information sharing and coordination on voluntary standards, conformity assessment and related activities for smart and sustainable cities in the US <a href="#_ftn37">[37]</a>. The US is a signatory of the ISO/ITU defined standards on smart cities <a href="#_ftn38">[38]</a>.</p>
<p> </p>
<h2 style="text-align: justify;">London, United Kingdom</h2>
<h3><strong>Introduction</strong></h3>
<p style="text-align: justify;">The Smart London Plan was unveiled in the year 2013 by the Mayor of London. The plan is being driven through the Greater London Authority, with the advice of the Smart London Board. The Smart London Plan envisions <em>‘Using the creative power of new technologies to serve London and improve Londoner’s lives</em>’ <a href="#_ftn39">[39]</a>. ‘Smart London’ is about harnessing new technology and data so that businesses, Londoners and visitors experience the city in a better way, and do not face bureaucratic hassle and congestion. Smart London seeks to improve the city as a whole and focuses on city macro functions that result from the interplay between city subsystems - such as local labour markets to financial markets, from local government to education, healthcare, transportation and utilities. According to strategy documents, a smarter London recognises and employs data as a service and will leverage data to enable informed decision making and the design of new activities.</p>
<h3 style="text-align: justify;"><strong>Status of the Project</strong></h3>
<p style="text-align: justify;">This project is currently ongoing. Since its formation in March 2013, the Smart London Board has been advising the Greater London Authority.The Plan sits within the overarching framework of the Mayor’s Vision 2020 <a href="#_ftn40">[40]</a>.</p>
<h3 style="text-align: justify;"><strong>Policies and Regulations</strong></h3>
<p style="text-align: justify;">The Smart London Plan incorporates the existing open data platform called ‘London DataStore’. The rules and guidelines for this platform are defined by the Greater London Authority, which includes working with public and private sector organisations to create, maintain and utilise it, enabling common data standards, identify and prioritise which data are needed to address London’s growth challenges, establish a Smart London Borough Partnership to encourage boroughs to free up London’s local level data. Also, privacy is protected and there is transparent use of data - to ensure data use is managed in the best interests of the public rather than private enterprise.<sup>42</sup> The Smart London Plan aims to build on this existing datastore to identify and publish data that addresses specific growth challenges, with an emphasis on working with companies and communities to create, maintain, and use this data <a href="#_ftn41">[41]</a>.</p>
<p style="text-align: justify;">The Open Data White Paper, issued by the Office of Paymaster General, seeks to build a transparent society by releasing public data through open data platforms and leveraging the potential of emerging technologies <a href="#_ftn42">[42]</a>. The Greater London Authority processes personal data in accordance with the Data Protection Act 1998 <a href="#_ftn43">[43]</a>.</p>
<h3 style="text-align: justify;"><strong>Adoption of International Standards</strong></h3>
<p style="text-align: justify;">The British Standards Institution (BSI) has already established Smart City standards and has associated with the ISO Advisory Group on smart city standards. The UK subscribes to the BSI standards for smart cities and has adopted the same <a href="#_ftn44">[44]</a>. The following standards and publications help address various issues for a city to become a smart city:</p>
<ul style="text-align: justify;">
<li>The development of a standard on <a href="http://www.bsigroup.com/en-GB/smart-cities/Smart-Cities-Standards-and-Publication/PAS-180-smart-cities-terminology/">Smart city terminology (PAS 180)</a></li>
<li>The development of a <a href="http://www.bsigroup.com/en-GB/smart-cities/Smart-Cities-Standards-and-Publication/PAS-181-smart-cities-framework/">Smart city framework standard (PAS 181)</a></li>
<li>The development of a <a href="http://www.bsigroup.com/en-GB/smart-cities/Smart-Cities-Standards-and-Publication/PAS-182-smart-cities-data-concept-model/">Data concept model for smart cities (PAS 182)</a></li>
<li>A <a href="http://www.bsigroup.com/en-GB/smart-cities/Smart-Cities-Standards-and-Publication/PD-8100-smart-cities-overview/">Smart city overview document (PD 8100)</a></li>
<li>A <a href="http://www.bsigroup.com/en-GB/smart-cities/Smart-Cities-Standards-and-Publication/PD-8101-smart-cities-planning-guidelines/">Smart city planning guidelines document (PD 8101)</a></li>
<li>BS 8904 Guidance for community sustainable development provides a decision-making framework that will help setting objectives in response to the needs and aspirations of city stakeholders</li>
<li>BS 11000 Collaborative relationship management</li>
<li>BSI BIP 2228:2013 Inclusive urban design - A guide to creating accessible public spaces.</li></ul>
<p style="text-align: justify;">Further, the Smart London Plan incorporates open data standards in accordance with London DataStore <a href="#_ftn45">[45]</a>. Various government reports – Smart Cities background paper, Open Data White Paper, etc., have suggested the use of standards related to Internet of Things (IoT), open data standards, etc <a href="#_ftn46">[46]</a>.</p>
<p> </p>
<h2 style="text-align: justify;">Seoul, Korea</h2>
<h3 style="text-align: justify;"><strong>Introduction</strong></h3>
<p style="text-align: justify;"><strong></strong>Smart Seoul 2015 was announced in June 2011 by the Seoul Metropolitan Government, which envisions integrating IT services into every field, including administration, welfare, industry and living. Through this, the Seoul Metropolitan Government plans to create a Seoul that uses smart technologies by 2015 <a href="#_ftn47">[47]</a>. Towards this, the Seoul Metropolitan Government plans to make use of Big Data in policy development, and through scientific analytics, will provide customized administrative services and reduce wasteful spending. Also, the government is utilising Big Data to analyse trends emerging from existing services <a href="#_ftn48">[48]</a>. Examples of projects that leverage big data that the government has undertaken include the Taxi Matchmaking Project – analyzes the data related to taxi stands and passengers, the Owl Bus <a href="#_ftn49">[49]</a> - maps the bus routes, etc.</p>
<h3 style="text-align: justify;"><strong>Status of the Project</strong></h3>
<p style="text-align: justify;"><strong></strong>Building on the Smart Seoul 2015, the Seoul Metropolitan Government plans to establish 'Global Digital Seoul 2020 – New Connections, Different Experiences' vision in next five-years. In this multi-objective plan, it aims to establish a ’Big Data campus’ providing win-win cooperation among public, private, industry and university <a href="#_ftn50">[50]</a>.</p>
<h3 style="text-align: justify;"><strong>Policies and Regulations </strong></h3>
<p style="text-align: justify;"><strong></strong>The Smart Seoul 2015 aims to create a ‘Seoul Data Mart’, which will be an open platform that makes public information available for data processing <a href="#_ftn51">[51]</a>. Furthermore, Seoul has opened the Seoul Open Data Plaza <a href="#_ftn52">[52]</a>, an online channel to share and provide citizens with all of Seoul’s public data, such as real-time bus operation schedules, subway schedules, non-smoking areas, locations of public Wi-Fi services, shoeshine shops, and facilities for disabled people, and the information registered in Seoul Open Data Plaza is provided in the open API format.<sup>45</sup></p>
<p style="text-align: justify;">South Korea has a comprehensive law governing data privacy – Personal Information Protection Act, 2011. The law includes data protection rules and principles, including obligations on the data controller and the consent of data subjects, rights to access personal data or object to its collection, and security requirements. It also covers cookies and spam, data processing by third parties and the international transfer of data <a href="#_ftn53">[53]</a>.</p>
<h3 style="text-align: justify;"><strong>International Standards</strong></h3>
<p style="text-align: justify;"><strong></strong>The smart city standards are adopted in the development of smart cities in Korea <a href="#_ftn54">[54]</a>. Korea has adopted the ISO/TC 268, which is focused on sustainable development in communities. Korea also has one working group developing city indicators and another working group developing metrics for smart community infrastructures <a href="#_ftn55">[55]</a>.</p>
<p> </p>
<h2>Conclusion</h2>
<p style="text-align: justify;">The smart city projects studied are at different levels of implementation and have both similarities and differences. Below is an analysis of some of the key similarities and differences between smart city projects, a comparison of these points to India’s 100 Smart City Mission, and a summary of best practices around the development of smart city frameworks.</p>
<h3><strong>Nodal Agency</strong></h3>
<p style="text-align: justify;">All cities studied have nodal agencies driving the smart city initiatives and many have policies in place backing these initiatives. For example, while the Smart Nation programme in Singapore is being driven by the Infocomm Development Authority, in London the smart city project is governed by the Great London Authority. The Smart Seoul Project in Korea is governed by the Seoul Metropolitan Government and New York has the Mayor’s Office of Technology and Innovation serving as the coordinating entity for new technology and IoT deployments across all City agencies. In India, the nodal agency driving the 100 Smart Cities Project is the Ministry of Urban Development under the Indian Government. In India, the implementation of the Mission at the City level will be done by a Special Purpose Vehicle (SPV), which will be a limited company and will plan, appraise, approve, release funds, implement, manage, operate, monitor and evaluate the Smart City development projects.</p>
<h3><strong>Policies</strong></h3>
<p style="text-align: justify;">Many of the cities had open data policies and data protection policies that pertain to the Smart City initiatives. In Dubai, an open data law called Dubai Open Data Law has been issued to complete the legislative framework for transforming Dubai into a Smart City and the Smart City Establishment will develop policies for the project. New York also has an Open Data Plan in place and LinkNYC will use anonymized, aggregate data to address data privacy of users. In London, the Smart London Plan incorporates the existing open data platform called ‘London DataStore’, the rules for which are defined by the Greater London Authority, which also ensures privacy and transparent use of data by processing personal data in accordance with the Data Protection Act 1998. For regulation of data in Seoul, a ‘Seoul Data Mart’ will be established to make public information available for data processing and the Seoul Open Data Plaza is an existing online channel to share and provide citizens with all of Seoul’s public data. South Korea has a comprehensive law governing data privacy in place as well. In Singapore, the Personal Data Protection Commission has committed to work and support the Smart Nation vision on data privacy and cyber security ecosystem. To achieve the vision of the project, the government has also promoted the use of open data. It can be said the these countries , with clearly laid out policies to support and guide the project, have well planned ecosystem for regulation and governance of systems, technologies and cities. All cities have incorporated open data into smart cities and many have developed guidelines for its use. All cities have similar goals of enhancing the lives of citizens and developing anticipatory regulation, however, there appears to be little discussion on the need to amend existing law or enable new law around privacy and data protection in light of data collection through smart cities. In India, no enabling legislation or policy has been formulated by the Government, apart from releasing “Mission Statement and Guidelines”, which provides details about the Project and vision, excluding a definition of a ‘smart city’ or the relevant applicable laws and policies. No information is publicly available regarding deployment of open data, use of specific technologies like cloud, big data, etc., the relevant policies and applicability of laws. Unlike India, all cities recognize the importance of big data techniques in enabling smart city visions, technology and policies. On the lines of these cities, India must work towards addressing the need for an open data framework in light of the 100 Smart Cities Mission to enable the sharing of non-confidential data between public entities and other stakeholders. This requires co-ordination to incorporate, enable and draw upon open data architecture in the cities by the Government with the existing open data framework in India, like the National Data Sharing and Accessibility Policy, 2012. Use of technology in the form of IoT and Big Data entails access to open data, bringing another policy area in its ambit which needs consideration. Also, identification and development of open standards for IoT must be looked at. Also, as data in smart cities will be generated, collected, used, and shared by both the public and private sector. It is essential that India’s existing data protection standards and regime must be amended to extend the data regulation beyond a body corporate and oversee the collection and use of data by the Government, and its agencies.</p>
<h3><strong>Standards</strong></h3>
<p style="text-align: justify;">In Singapore, the Smart Nation initiative follows the standards laid under the purview of the Singapore Standards Council (SSC)and the <a href="https://www.itsc.org.sg/standards/singapore-it-standards">Singapore IT standards</a> abides to the international standards as defined by ISO, ITU, etc. The Country is also a member of many international standards forums (see <a href="https://www.itsc.org.sg/international-participation/memberships-in-iso-iec-jtc1">Singapore International Standards Committee</a>) which includes JTC1/WG9- Big Data; JTC1/WG10 - Internet of Things; JTC1/WG11 - Smart Cities. In Dubai, the Smart Dubai Executive Committee with the International Telecommunications Union (ITU) to adopt the performance indicators by the ITU Focus Group on Smart Sustainable Cities to evaluate the feasibility of the indicators. For the purpose of standards, the ANSI Network on Smart and Sustainable Cities (ANSSC) in New York is a forum smart and sustainable cities, along with US being a signatory of the ISO/ITU defined standards on smart cities. Also, The British Standards Institution (BSI) has already established Smart City standards and has associated with the ISO Advisory Group on smart city standards. The UK subscribes to the BSI standards for smart cities and has adopted the same and the Smart London Plan incorporates open data standards in accordance with London DataStore. For development of smart cities, Korea has adopted the ISO/TC 268, which is focused on sustainable development in communities and also has one working group developing city indicators and another working group developing metrics for smart community infrastructures. However, in India, the Bureau of Indian Standards (BIS) has undertaken the task to formulate standardised guidelines for central and state authorities in planning, design and construction of smart cities by setting up a technical committee under the Civil engineering department of the Bureau. However, adoption of the standards by implementing agencies would be voluntary and intends to complement internationally available documents in this area. Also, The Global Cities Institute (GCI) has undertaken a mission in the year 2015 to align with the Bureau of Indian Standards regarding development of standards of smart cities and also to forge relationships with Indian cities in light of ISO 37120. It can be said that India has currently not yet adopted international standards, but is in the process of developing national standards and adopting key international standards. Unlike other cities,which are adopting standards - national, ISO, or ITU, Indian cities are yet to adopt standards for regulation of the future smart cities.</p>
<h3><strong>Notes for India</strong></h3>
<p style="text-align: justify;">India is in the nascent stages of developing smart cities across the country. Drawing from the practices adopted by cities across the world, smart cities in India should adopt strong regulatory and governance frameworks regarding technical standards, open data and data security and data protection policies. These policies will be essential in ensuring the sustainability and efficiency of smart cities while safeguarding individual rights. Some of these policies are already in place - such as India’s Open Data Policy and India’s data protection standards under section 43A of the ITA. It will be important to see how these policies are adopted and applied to the context of smart cities.</p>
<p> </p>
<h2>References</h2>
<p><a name="_ftn1">[1]</a> Smart Cities and Transparent Evolution, <a href="http://www.posterheroes.org/Posterheroes3/_mat/PH3_eng.pdf">http://www.posterheroes.org/Posterheroes3/_mat/PH3_eng.pdf</a>.</p>
<p><a name="_ftn2">[2]</a> "Data, Data Everywhere." The Economist, February 25, 2010. Accessed March 17, 2016, <a href="http://www.economist.com/node/15557443">http://www.economist.com/node/15557443</a>.</p>
<p><a name="_ftn3">[3]</a> "Smart Cities." ISO. 2015. Accessed March 17, 2016, <a href="http://www.iso.org/iso/smart_cities_report-jtc1.pdf">http://www.iso.org/iso/smart_cities_report-jtc1.pdf</a>.</p>
<p><a name="_ftn4">[4]</a> Transcript of Prime Minister Lee Hsien Loong's speech at Smart Nation launch on 24 November, <a href="http://www.pmo.gov.sg/mediacentre/transcript-prime-minister-lee-hsien-loongs-speech-smart-nation-launch-24-november">http://www.pmo.gov.sg/mediacentre/transcript-prime-minister-lee-hsien-loongs-speech-smart-nation-launch-24-november</a>.</p>
<p><a name="_ftn5">[5]</a> Smart Nation Vision, <a href="https://www.ida.gov.sg/Tech-Scene-News/Smart-Nation-Vision">https://www.ida.gov.sg/Tech-Scene-News/Smart-Nation-Vision</a>.</p>
<p><a name="_ftn6">[6]</a> Smart Nation, <a href="http://www.pmo.gov.sg/smartnation">http://www.pmo.gov.sg/smartnation</a>.</p>
<p><a name="_ftn7">[7]</a> Smart Nation Platform, <a href="https://www.ida.gov.sg/~/media/Files/About%20Us/Newsroom/Media%20Releases/2014/0617_smartnation/AnnexA_sn.pdf">https://www.ida.gov.sg/~/media/Files/About%20Us/Newsroom/Media%20Releases/2014/0617_smartnation/AnnexA_sn.pdf</a>.</p>
<p><a name="_ftn8">[8]</a> Transcript of Prime Minister Lee Hsien Loong's speech at Smart Nation launch on 24 November, <a href="https://www.ida.gov.sg/blog/insg/featured/singapore-lays-groundwork-to-be-worlds-first-smart-nation/">https://www.ida.gov.sg/blog/insg/featured/singapore-lays-groundwork-to-be-worlds-first-smart-nation/</a>.</p>
<p><a name="_ftn9">[9]</a> Prime Ministers’ Office Singapore-Smart Nation, <a href="http://www.pmo.gov.sg/smartnation">http://www.pmo.gov.sg/smartnation</a>.</p>
<p><a name="_ftn10">[10]</a> Prime Ministers’ Office Singapore-Smart Nation, <a href="http://www.pmo.gov.sg/smartnation">http://www.pmo.gov.sg/smartnation</a>.</p>
<p><a name="_ftn11">[11]</a> Constitution of the Republic of Singapore (Responsibility of the Prime Minister) Notification 2015, <a href="http://statutes.agc.gov.sg/aol/search/display/view.w3p;page=0;query=Status%3Acurinforce%20Type%3Aact,sl%20Content%3A%22smart%22;rec=4;resUrl=http%3A%2F%2Fstatutes.agc.gov.sg%2Faol%2Fsearch%2Fsummary%2Fresults.w3p%3Bquery%3DStatus%253Acurinforce%2520Type%253Aact,sl%2520Content%253A%2522smart%2522;whole=yes">http://statutes.agc.gov.sg/aol/search/display/view.w3p;page=0;query=Status%3Acurinforce%20Type%3Aact,sl%20Content%3A%22smart%22;rec=4;resUrl=http%3A%2F%2Fstatutes.agc.gov.sg%2Faol%2Fsearch%2Fsummary%2Fresults.w3p%3Bquery%3DStatus%253Acurinforce%2520Type%253Aact,sl%2520Content%253A%2522smart%2522;whole=yes</a>.</p>
<p><a name="_ftn12">[12]</a> Personal Data Protection Singapore-Annual Report 2014-15, <a href="https://www.pdpc.gov.sg/docs/default-source/Reports/pdpc-ar-fy14---online.pdf">https://www.pdpc.gov.sg/docs/default-source/Reports/pdpc-ar-fy14---online.pdf</a>.</p>
<p><a name="_ftn13">[13]</a> Balancing Innovation and Personal Data Protection, <a href="https://www.ida.gov.sg/Tech-Scene-News/Tech-News/Digital-Government/2015/9/Balancing-innovation-and-personal-data-protection">https://www.ida.gov.sg/Tech-Scene-News/Tech-News/Digital-Government/2015/9/Balancing-innovation-and-personal-data-protection</a>.</p>
<p><a name="_ftn14">[14]</a> Department of Statistics Singapore- Free Access to More Data on the SingStat Website from 1 March 2015, <a href="http://www.singstat.gov.sg/docs/default-source/default-document-library/news/press_releases/press27022015.pdf">http://www.singstat.gov.sg/docs/default-source/default-document-library/news/press_releases/press27022015.pdf</a>.</p>
<p><a name="_ftn15">[15]</a> Singapore Marks 50th Birthday With Open Data Contest, <a href="https://blog.hootsuite.com/singapore-open-data/">https://blog.hootsuite.com/singapore-open-data/</a>.</p>
<p><a name="_ftn16">[16]</a> Virtual Singapore - a 3D city model platform for knowledge sharing and community collaboration, <a href="http://www.sla.gov.sg/News/tabid/142/articleid/572/category/Press%20Releases/parentId/97/year/2014/Default.aspx">http://www.sla.gov.sg/News/tabid/142/articleid/572/category/Press%20Releases/parentId/97/year/2014/Default.aspx</a>.</p>
<p><a name="_ftn17">[17]</a> Internet of Things (IoT) Standards Outline to Support Smart Nation Initiative Unveiled, <a href="http://www.spring.gov.sg/NewsEvents/PR/Pages/Internet-of-Things-(IoT)-Standards-Outline-to-Support-Smart-Nation-Initiative-Unveiled-20150812.aspx">http://www.spring.gov.sg/NewsEvents/PR/Pages/Internet-of-Things-(IoT)-Standards-Outline-to-Support-Smart-Nation-Initiative-Unveiled-20150812.aspx</a>.</p>
<p><a name="_ftn18">[18]</a> Information Technology Standards Committee, <a href="https://www.itsc.org.sg/technical-committees/internet-of-things-technical-committee-iottc">https://www.itsc.org.sg/technical-committees/internet-of-things-technical-committee-iottc</a> and <a href="https://www.ida.gov.sg/~/media/Files/Infocomm%20Landscape/iN2015/Reports/realisingthevisionin2015.pdf">https://www.ida.gov.sg/~/media/Files/Infocomm%20Landscape/iN2015/Reports/realisingthevisionin2015.pdf</a>.</p>
<p><a name="_ftn19">[19]</a> Government of Dubai-2021 Dubai Plan-Purpose, <a href="http://www.dubaiplan2021.ae/the-purpose/">http://www.dubaiplan2021.ae/the-purpose/</a>.</p>
<p style="text-align: justify;"><a name="_ftn20">[20]</a> Government of Dubai-2021 Dubai Plan, <a href="http://www.dubaiplan2021.ae/dubai-plan-2021/">http://www.dubaiplan2021.ae/dubai-plan-2021/</a>.</p>
<p><a name="_ftn21">[21]</a> Smart Dubai, <a href="http://www.smartdubai.ae/foundation_layers.php">http://www.smartdubai.ae/foundation_layers.php</a>.</p>
<p><a name="_ftn22">[22]</a> The Internet of Things: Connections for People’s happiness, <a href="http://www.smartdubai.ae/story021002.php">http://www.smartdubai.ae/story021002.php</a>.</p>
<p><a name="_ftn23">[23]</a> Smart Dubai - Current State, <a href="http://www.smartdubai.ae/current_state.php">http://www.smartdubai.ae/current_state.php</a>.</p>
<p><a name="_ftn24">[24]</a> Smart Dubai - District Guidelines, <a href="http://smartdubai.ae/districtguidelines/Smart_Dubai_District_Guidelines_Public_Brief.pdf">http://smartdubai.ae/districtguidelines/Smart_Dubai_District_Guidelines_Public_Brief.pdf</a>.</p>
<p><a name="_ftn25">[25]</a> See; <a href="http://roadmap.smartdubai.ae/search-services-public.php">http://roadmap.smartdubai.ae/search-services-public.php</a> and <a href="http://roadmap.smartdubai.ae/search-initiatives-public.php">http://roadmap.smartdubai.ae/search-initiatives-public.php</a>.</p>
<p><a name="_ftn26">[26]</a> Smart Dubai-Smart District Guidelines, <a href="http://smartdubai.ae/districtguidelines/Smart_Dubai_District_Guidelines_Public_Brief.pdf">http://smartdubai.ae/districtguidelines/Smart_Dubai_District_Guidelines_Public_Brief.pdf</a>.</p>
<p><a name="_ftn27">[27]</a> Dubai Ruler issues new laws to further enhance the organisational structure and legal framework of Dubai Smart City, <a href="https://www.wam.ae/en/news/emirates/1395288828473.html">https://www.wam.ae/en/news/emirates/1395288828473.html</a>.</p>
<p><a name="_ftn28">[28]</a> See: <a href="http://slc.dubai.gov.ae/en/AboutDepartment/News/Lists/NewsCentre/DispForm.aspx?ID=147&ContentTypeId=0x01001D47EB13C23E544893300E8367A23439">http://slc.dubai.gov.ae/en/AboutDepartment/News/Lists/NewsCentre/DispForm.aspx?ID=147&ContentTypeId=0x01001D47EB13C23E544893300E8367A23439</a> and <a href="http://www.smartdubai.ae/dubai_data.php">http://www.smartdubai.ae/dubai_data.php</a>.</p>
<p><a name="_ftn29">[29]</a> Dubai first city to trial ITU key performance indicators for smart sustainable cities, <a href="http://www.itu.int/net/pressoffice/press_releases/2015/12.aspx#.VtaYtlt97IU">http://www.itu.int/net/pressoffice/press_releases/2015/12.aspx#.VtaYtlt97IU</a>.</p>
<p><a name="_ftn30">[30]</a> Smart Dubai Benchmark Report 2015 Executive Summary, <a href="http://smartdubai.ae/bmr2015/methodology-public.php">http://smartdubai.ae/bmr2015/methodology-public.php</a>.</p>
<p><a name="_ftn31">[31]</a> Building a Smart + Equitable City, <a href="http://www1.nyc.gov/assets/forward/documents/NYC-Smart-Equitable-City-Final.pdf">http://www1.nyc.gov/assets/forward/documents/NYC-Smart-Equitable-City-Final.pdf</a></p>
<p><a name="_ftn32">[32]</a> Building a Smart + Equitable City, <a href="http://www1.nyc.gov/site/forward/innovations/smartnyc.page">http://www1.nyc.gov/site/forward/innovations/smartnyc.page</a>.</p>
<p><a name="_ftn33">[33]</a> One New York: The Plan for a Strong and Just City, <a href="http://www1.nyc.gov/html/onenyc/about.html">http://www1.nyc.gov/html/onenyc/about.html</a></p>
<p><a name="_ftn34">[34]</a> Open Data for All, <a href="http://www1.nyc.gov/assets/home/downloads/pdf/reports/2015/NYC-Open-Data-Plan-2015.pdf">http://www1.nyc.gov/assets/home/downloads/pdf/reports/2015/NYC-Open-Data-Plan-2015.pdf</a>.</p>
<p><a name="_ftn35">[35]</a> 7 public projects that are turning New York into a “smart city”, <a href="http://www.builtinnyc.com/2015/11/24/7-projects-are-turning-new-york-futuristic-technology-hub">http://www.builtinnyc.com/2015/11/24/7-projects-are-turning-new-york-futuristic-technology-hub</a>.</p>
<p><a name="_ftn36">[36]</a> LinkNYC, <a href="https://www.link.nyc/faq.html#privacy">https://www.link.nyc/faq.html#privacy</a>.</p>
<p><a name="_ftn37">[7]</a> ANSI Network on Smart and Sustainable Cities, <a href="http://www.ansi.org/standards_activities/standards_boards_panels/anssc/overview.aspx?menuid=3">http://www.ansi.org/standards_activities/standards_boards_panels/anssc/overview.aspx?menuid=3</a></p>
<p><a name="_ftn38">[38]</a> IoT-Enabled Smart City Framework, <a href="http://publicaa.ansi.org/sites/apdl/Documents/News%20and%20Publications/Links%20Within%20Stories/IoT-EnabledSmartCityFrameworkWP20160213.pdf">http://publicaa.ansi.org/sites/apdl/Documents/News%20and%20Publications/Links%20Within%20Stories/IoT-EnabledSmartCityFrameworkWP20160213.pdf</a>.</p>
<p><a name="_ftn39">[39]</a> Smart London (UK) Plan: Digital Technologies, London and Londoners, <a href="http://munkschool.utoronto.ca/ipl/files/2015/03/KleinmanM_Smart-London-UK-v5_30AP2015.pdf">http://munkschool.utoronto.ca/ipl/files/2015/03/KleinmanM_Smart-London-UK-v5_30AP2015.pdf</a>.</p>
<p><a name="_ftn40">[40]</a> Smart London Plan, <a href="http://www.london.gov.uk/sites/default/files/smart_london_plan.pdf">http://www.london.gov.uk/sites/default/files/smart_london_plan.pdf</a>.</p>
<p><a name="_ftn41">[41]</a> Smart London Plan, <a href="http://www.london.gov.uk/sites/default/files/smart_london_plan.pdf">http://www.london.gov.uk/sites/default/files/smart_london_plan.pdf</a>.</p>
<p><a name="_ftn42">[42]</a> Open Data White Paper, <a href="https://data.gov.uk/sites/default/files/Open_data_White_Paper.pdf">https://data.gov.uk/sites/default/files/Open_data_White_Paper.pdf</a>.</p>
<p><a name="_ftn43">[43]</a> London Datastore-Privacy, <a href="http://data.london.gov.uk/about/privacy/">http://data.london.gov.uk/about/privacy/</a>.</p>
<p><a name="_ftn44">[44]</a> Future Cities Standards Centre in London, <a href="https://eu-smartcities.eu/commitment/5937">https://eu-smartcities.eu/commitment/5937</a>.</p>
<p><a name="_ftn45">[45]</a> Smart London Plan, <a href="http://www.london.gov.uk/sites/default/files/smart_london_plan.pdf">http://www.london.gov.uk/sites/default/files/smart_london_plan.pdf</a>.</p>
<p><a name="_ftn46">[46]</a> Smart Cities background paper, October 2013, <a href="https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/246019/bis-13-1209-smart-cities-background-paper-digital.pdf">https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/246019/bis-13-1209-smart-cities-background-paper-digital.pdf</a>.</p>
<p><a name="_ftn47">[47]</a> Presentation of 2015 Blueprint of Seoul as ‘State-of-the-art Smart City’, <a href="http://english.seoul.go.kr/presentation-of-2015-blueprint-of-seoul-as-%E2%80%98state-of-the-art-smart-city%E2%80%99/">http://english.seoul.go.kr/presentation-of-2015-blueprint-of-seoul-as-%E2%80%98state-of-the-art-smart-city%E2%80%99/</a>.</p>
<p><a name="_ftn48">[48]</a> “Policy Where There is Demand,” Seoul Utilizes Big Data, <a href="http://english.seoul.go.kr/policy-demand-seoul-utilizes-big-data/">http://english.seoul.go.kr/policy-demand-seoul-utilizes-big-data/</a></p>
<p><a name="_ftn49">[49]</a> Seoul’s “Owl Bus” Based on Big Data Technology, <a href="http://www.citiesalliance.org/sites/citiesalliance.org/files/Seoul-Owl-Bus-11052014.pdf">http://www.citiesalliance.org/sites/citiesalliance.org/files/Seoul-Owl-Bus-11052014.pdf</a></p>
<p><a name="_ftn50">[50]</a> Seoul Launches “Global Digital Seoul 2020”, <a href="http://english.seoul.go.kr/seoul-launches-global-digital-seoul-2020/">http://english.seoul.go.kr/seoul-launches-global-digital-seoul-2020/</a></p>
<p><a name="_ftn51">[51]</a> Smart Seoul 2015, <a href="http://english.seoul.go.kr/wp-content/uploads/2014/02/SMART_SEOUL_2015_41.pdf">http://english.seoul.go.kr/wp-content/uploads/2014/02/SMART_SEOUL_2015_41.pdf</a></p>
<p><a name="_ftn52">[52]</a> Disclosing public data through the Seoul Open Data Plaza, <a href="http://english.seoul.go.kr/policy-information/key-policies/informatization/seoul-open-data-plaza/">http://english.seoul.go.kr/policy-information/key-policies/informatization/seoul-open-data-plaza/</a></p>
<p><a name="_ftn53">[53]</a> Data protection in South Korea: overview, <a href="http://uk.practicallaw.com/2-579-7926">http://uk.practicallaw.com/2-579-7926</a>.</p>
<p><a name="_ftn54">[54]</a>Smart Cities Seoul: a case study, <a href="https://www.itu.int/dms_pub/itu-t/oth/23/01/T23010000190001PDFE.pdf">https://www.itu.int/dms_pub/itu-t/oth/23/01/T23010000190001PDFE.pdf</a></p>
<p><a name="_ftn55">[55]</a> Smart Cities-ISO, <a href="http://www.iso.org/iso/livelinkgetfile-isocs?nodeid=16193764">http://www.iso.org/iso/livelinkgetfile-isocs?nodeid=16193764</a>.</p>
<p> </p>
<p>
For more details visit <a href='http://editors.cis-india.org/internet-governance/blog/policies-and-standards-overview-of-five-international-smart-cities'>http://editors.cis-india.org/internet-governance/blog/policies-and-standards-overview-of-five-international-smart-cities</a>
</p>
No publisherKiran A. B., Elonnai Hickok and Vanya RakeshBig DataInternet GovernanceFeaturedSmart CitiesPoliciesHomepage2016-06-11T13:29:04ZBlog EntryInternational Open Data Charter: Comments by CIS
http://editors.cis-india.org/openness/international-open-data-charter-comments-by-cis
<b>The second meeting of Stewards of the International Open Data Charter is in progress in Santiago, Chile, where the revisions made to the Charter based on the comments received during the public consultation period that ended on July 31, 2015, are being re-discussed and finalised by the Stewards. Here we are sharing the comments submitted by us on the first public draft of the Charter published during the International Open Data Conference in Ottawa, Canada, in May 2015. The comments include those submitted by Sumandro and Sharath Chandra Ram.</b>
<p> </p>
<p><strong>The draft International Open Data Charter and all the submitted comments can be accessed here: <a href="http://opendatacharter.net/charter/" target="_blank">http://opendatacharter.net/charter/</a></strong></p>
<p> </p>
<h2>Comments on the Public Draft</h2>
<p><em>Note: The text below contains excerpts from the public draft of the Charter, followed by submitted comments in <strong>bold</strong>.</em></p>
<p> </p>
<p>1) The world is witnessing the growth of a global movement facilitated by technology and digital media and fuelled by information – one that contains enormous potential to create more accountable, efficient, responsive, and effective governments and businesses, and to spur economic growth.</p>
<p><strong>The word ‘movement’ can perhaps be replaced by ‘transformation.’ ‘Movement’ tends to suggest some kind of unity of purpose or objective, which is not perhaps what is meant here. Also, is it possible to add ‘transparent’ to ‘accountable, efficient, responsive, and effective’?</strong></p>
<p>Open data sit at the heart of this global movement.</p>
<p><strong>Perhaps ‘transformation’ and not ‘movement’.</strong></p>
<p>2) Building a more democratic, just, and prosperous society requires transparent, accountable governments that engage regularly and meaningfully with citizens. Accordingly, there is an ongoing effort to enable collaboration around key social challenges, to provide effective oversight of government activities, to support economic development through innovation, and to develop effective, efficient public policies and programmes.</p>
<p><strong>Perhaps insert ‘sustainable’ before ‘economic development’. In the second sentence, none of the action phrases (‘enable collaboration’ and ‘effective oversight’ and ‘innovation’ and ‘develop effective, efficient’) are speaking about either democracy or justice. The focus seems to be completely on effectiveness. Phrases like ‘transparent’, ‘accountable’, and ‘participatory’ should be introduced here.</strong></p>
<p>Open data is essential to meeting these challenges.</p>
<p><strong>The above point clarifies why ‘data is essential’ but not why ‘open data is essential’. The connection between democracy and justice on one hand, and open data on the other is not yet articulated clearly.</strong></p>
<p>3) Effective access to data allows individuals and organisations to develop new insights and innovations that can generate social and economic benefits to improve the lives of people around the world, and help to improve the flow of information within and between countries. While governments collect a wide range of data, they do not always share these data in ways that are easily discoverable, useable, or understandable by the public.</p>
<p><strong>Along with allowing ‘insights’ and ‘innovations’ to develop, can it also be highlighted that open data make decisions and processes transparent?</strong></p>
<p>This is a missed opportunity.</p>
<p><strong>I agree with above comments that it is perhaps better to articulate this not as ‘missed opportunity’ but to highlight this as the very ‘opportunity’ that the open data agenda is interested in capturing.</strong></p>
<p>4) Today, many people expect to be able to access high quality information and services, including government data, when and how they want. Others see the opportunity presented by government data as one which can provide innovative policy solutions and support economic and social benefits for all members of society. We have arrived at a point at which people can use open data to generate value, insights, ideas, and services to create a better world for all.</p>
<p><strong>This point may also mention that some people are interested in using government data to open up government decisions and processes and make them transparent, which is a necessary condition for making the government accountable.</strong></p>
<p>6) Providing access to government data can drive sustainable and inclusive growth by empowering citizens, the media, civil society, and the private sector to identify gaps, and work toward better outcomes for public services in areas such as health, education, public safety, environmental protection, and governance. Open data can do this by:</p>
<p><strong>Perhaps ‘democratic participation’ can be added after ‘sustainable and inclusive growth’. That is: ‘Providing access to government data can drive sustainable and inclusive growth, and democratic participation, by empowering citizens…’</strong></p>
<p>7) Open government data can be used in innovative ways to create useful tools and products that help to navigate modern life more easily. Used in this way, open data are a catalyst for innovation in the private sector, supporting the creation of new markets, businesses, and jobs. These benefits can multiply as more private sector and civil society organisations adopt open data practices modelled by government and share their own data with the public.</p>
<p><strong>The incentive for private sector and CSOs to open up data is not clear. Overall benefit may rise with them opening up data, but how does a private company / CSO benefit by opening up its data?</strong></p>
<p>8) We, the adherents to the International Open Data Charter, agree that open data are an under-used resource with huge potential to encourage the building of stronger, more interconnected societies that better meet the needs of our citizens and allow innovation and prosperity to flourish.</p>
<p><strong>Along with ‘stronger’ and ‘more interconnected’, please mention ‘more transparent’ and ‘more democratic’. Also it is not clear what is meant by ‘stronger’. ‘[B]etter meet the needs of our citizens’ does not necessarily suggest a more democratic or just society, but a more effective welfare distribution system. Please add ‘… and empower the citizens to ensure accountability of the government.’</strong></p>
<p>9) We therefore agree to follow a set of principles that will be the foundation for access to, and the release and use of, open government data. These principles are:</p>
<ol><li>Open Data by Default;</li>
<li>Quality and Quantity;</li>
<li>Accessible and Useable by All;</li>
<li>Engagement and Empowerment of Citizens;</li>
<li>Collaboration for Development and Innovation</li></ol>
<p><strong>Does it makes sense to remove the ‘Quantity and Quality’ point and merging it with ‘Accessible and Usable by All’? Data quantity and quality issues, along with those related to publication of data, can all logically follow under the topic of data access and use. For example, highly aggregated data published once a year without documentation is not really usable data.</strong></p>
<p>10) We will develop an action plan in support of the implementation of the Charter and its Technical Annexes, and will update and renew the action plan at a minimum of every two years. We agree to commit the necessary resources to work within our political and legal frameworks to implement these principles in accordance with the technical best practices and timeframes set out in our action plan.</p>
<p><strong>We (at CIS) strongly feel that the Charter should also prescribe that along with the national Action Plan, Open Data Citizen’s Charters are created for various levels and verticals of the government. This will clarify data publication responsibilities and targets at ministerial and sub-national (including city) governmental levels, and will allow for much more effective monitoring (national and international) of the Action Plan implementation process.</strong></p>
<p><strong>‘[A]t a minimum of every two years’ reads a bit unclear. Does it mean that the Action Plan should be renewed only after two years and not before, or that the Action Plan should be renewed every two years or before that?</strong></p>
<p>11) We recognise that free access to, and the subsequent use of, government data are of significant value to society and the economy, and that government data should, therefore, be open by default.</p>
<p><strong>Along with clarifying the scope of ‘government data,’ the idea of ‘open’ in the context of data needs a clear definition as an independent point. The document is getting into ‘open by default’ without clarifying what is ‘open’, including both necessary and sufficient conditions.</strong></p>
<p>12) We acknowledge the need to promote the global development and adoption of tools and policies for the creation, use, and exchange of open data and information.</p>
<p><strong>I agree with Mike Linksvayer. This is a great opportunity for the Charter to connect the open data agenda with the wider open agendas, especially that of free and open source softwares. It is very important that this point promotes ‘global development of free and open source tools’.</strong></p>
<p><strong>Extending the comment by Jose Subero, along with ‘tools’ and ‘policies’, it will be great to have a mention of ‘standards’ here, which is critical for ensuring ‘interoperability’ and thus ‘harmonisation’.</strong></p>
<p>13) We recognise that the term ‘government data’ is meant in the widest sense possible. This could apply to data held by national, federal, and local governments, international government bodies, and other types of institutions in the wider public sector. This could also apply to data created for governments by external organisations, and data of significant benefit to the public which is held by external organisations and related to government programmes and services (e.g. data on extractives entities, data on transportation infrastructure, etc).</p>
<p><strong>It is wonderful that the point promotes a wide understanding of ‘government data’ but at the same time it should also define a necessary core understanding of data, just to ensure that governments do not interpret this point too narrowly.</strong></p>
<p><strong>Further, a focus only on data created by public agencies can perhaps be too narrow (for the necessary/core understanding of ‘government data’). With public services delivered increasingly by private agencies and public-private-partnerships, it is crucial that ‘government data’ should explicitly include any data coming out of a process funded by public money (the process may be carried out by a public agency or not). This is an extremely important point from a developing country perspective.</strong></p>
<p>14) We recognise that there is domestic and international legislation, in particular pertaining to security, privacy, confidentiality, intellectual property, and personally-identifiable and other sensitive information, which must be observed and/or updated where necessary.</p>
<p><strong>From a developing country perspective, it is very important that the Charter does not keep this critical point dependent on domestic and international legislations. International legislation may not be very developed for all of the mentioned topics, and many countries may not have existing domestic legislations on these topics either. The Charter should mention an internationally acceptable list of concerns / criteria for not opening up data. The list may include the topics mentioned here, like privacy and national security. This need not be a list of sufficient criteria, but of necessary ones.</strong></p>
<p>15) We will:</p>
<ul><li>develop and adopt policies and practices to ensure that all government data is made open by default, as outlined in this Charter, while recognising that there are legitimate reasons why some data cannot be released;</li></ul>
<p><strong>'Administrative reforms’ are most often crucial to make government data ‘open by default, and the same should be mentioned along with ‘policies’ and ‘practices’.</strong></p>
<ul><li>provide clear justifications as to why certain data cannot be released;</li></ul>
<p><strong>This is a great point. Perhaps it can be added that all government agencies should produce a list of all data assets maintained by them, point out the ones that cannot be made open, and provide clear justification as to why those cannot be released. This comment pre-empts 19.1. Perhaps this point about providing justification for not releasing data can be merged with 19.1.</strong></p>
<ul><li>develop the leadership, management, oversight, and internal communication policies necessary to enable this transition to a culture of openness.</li></ul>
<p><strong>Along with ‘leadership, management, oversight, and internal communication’, is it possible to add ‘incentives’? This is often overlooked in implementing open data policies.</strong></p>
<p>16) We recognise that governments and other public sector organisations hold vast amounts of information that may be of interest to citizens, and that it may take time to identify data for release or publication.</p>
<p>17) We also recognise the importance of consulting with citizens, other governments, non-governmental organisations, and other open data users, to identify which data to prioritise for release and/or improvement.</p>
<p>18) We agree, however, that governments’ primary responsibility should be to release data in a timely manner, without undue delay.</p>
<p><strong>Points 16-18 seem to suggest that the ‘quantity and quality’ issue is mostly one of prioritisation. This can be misleading. This is perhaps the ‘quantity’ issue, but not at all the ‘quality’ issue.</strong></p>
<p>19) We will:</p>
<ul><li>...</li>
<li>release high-quality open data that are timely, comprehensive, and accurate in accordance with prioritisation that is informed by public requests. To the extent possible, data will be released in their original, unmodified form and at the finest level of granularity available, and will also be linked to any visualisations or analyses created based on the data, as well as any relevant guidance or documentation;</li></ul>
<p><strong>Please add ‘human- and machine-readable’ along with ‘timely, comprehensive, and accurate’.</strong></p>
<p><strong>Put ‘, and’ between ‘, and accurate’ and ‘in accordance’.</strong></p>
<p><strong>‘Relevant guidance or documentation’ should be mentioned before, and not after, ‘visualisations or analyses’.</strong></p>
<ul><li>ensure that accompanying documentation is written in clear, plain language, so that it can be easily understood by all;</li></ul>
<p><strong>Add that the documentation should be ‘comprehensive’, along with being written in plain language.</strong></p>
<ul><li>make sure that data are fully described, and that data users have sufficient information to understand their source, strengths, weaknesses, and any analytical limitations;</li></ul>
<p><strong>Regarding ‘Full description of data’ — Aggregate data must be accompanied by low level raw data along with details of analytical methods used to arrive at figures. This allows for verification as well as alternate views and detection of statistical anomalies.</strong></p>
<ul><li>ensure that open datasets include consistent core metadata, and are made available in human- and machine-readable formats under an open and unrestrictive licence;</li></ul>
<p><strong>Is this the necessary definition of ‘open data’? If so, it should be much higher up.</strong></p>
<ul><li>allow users to provide feedback, and continue to make revisions to ensure the quality of the data is improved as needed; and</li></ul>
<p><strong>This point should clarify if it is talking about making revisions of the data itself (its content), or how it is being published (its form), or both?</strong></p>
<ul><li>apply consistent information lifecycle management practices, and ensure historical copies of datasets are preserved, archived, and kept accessible as long as they retain value.</li></ul>
<p><strong>The ‘as long as they retain value’ part seems vague. Who is going to take this decision about value? Is it possible to rephrase this as ‘as long as they are demanded by data users’?</strong></p>
<p>21) We recognise that open data should be made available free of charge in order to encourage their widest possible use.</p>
<p><strong>Maybe ‘government data’ and not ‘open data’ (open data already means it is available gratis). Also, along with ‘free of charge’ maybe add ‘under open license’, as that is a critical requirement for ‘widest possible use.’</strong></p>
<p>22) We recognise that when open data are released, they should be made available without bureaucratic or administrative barriers, such as mandatory user registration, which can deter people from accessing the data.</p>
<p><strong>I strongly believe that this point should be removed. Registration of the data user can also be very useful for the government agencies to track demand and actual usage of their datasets. Instead of the government agencies doing such kind of tracking as a background process, it is much better if the data usage monitoring of all users is done transparently. Along with perhaps a public dashboard of data usages of the users of an open data portal. As long as the registration barrier does not involve an approval process by the government agency, it can be allowed.</strong></p>
<p><strong>A more general point should be added as part of this principle, regarding no-discrimination (or approval process) among data users interested in accessing and using of open government data.</strong></p>
<p>23) We will:</p>
<ul><li>release data in open formats and free of charge to ensure that the data are available to the widest range of users to find, access, and use them. In many cases, this will include providing data in multiple formats, so that they can be processed by computers and used by people; and</li></ul>
<p><strong>Please add ‘open license’ along with ‘open formats’ and ‘free of charge’.</strong></p>
<p>24) We recognise that the release of open data strengthens our public and democratic institutions, encourages better development, implementation, and assessment of policies to meet the needs of our citizens, and enables more meaningful, better informed engagement between governments and citizens.</p>
<p><strong>Perhaps add ‘, and makes them transparent’ after ‘strengthens our public and democratic institutions’. Please also add ‘monitoring’ along with ‘development, implementation, and assessment’.</strong></p>
<p>25) We will:</p>
<ul><li>implement oversight and review processes to report regularly on the progress and impact of our open data initiatives;</li></ul>
<p><strong>The functioning of these ‘oversight and review processes’ must be open and transparent themselves. The reporting should be public.</strong></p>
<ul><li>engage with community and civil society representatives working in the domain of transparency and accountability to determine what data they need to effectively hold governments to account; encourage the use of open data to develop innovative, evidence-based policy solutions that benefit all members of society, as well as empower marginalised groups; and</li></ul>
<p><strong>This must also include a point regarding the government proactively seeking data demands from citizens, CSOs, academics, and the private sector.</strong></p>
<p><strong>‘as well as empower marginalised groups’ is too vague. Perhaps it can be made into a separate point, and qualified with what kinds of empowerment is needed – from demanding data, to accessing and using data, to be aware of the data collected from such groups by the government agencies.</strong></p>
<ul><li>be transparent about our own data collection, standards, and publishing processes, by documenting all of these related processes online.</li></ul>
<p><strong>This should be part of point 19.</strong></p>
<p>26) We recognise the importance of diversity in stimulating creativity and innovation. The more citizens, governments, civil society, and the private sector use open data, the greater the social and economic benefits that will be generated. This is true for government, commercial, and non-commercial uses.</p>
<p><strong>The diversity point is almost already made with points 20-21 – widest possible users lead to widest possible use.</strong></p>
<p>28) We will:</p>
<ul><li>...</li>
<li>engage with civil society, the private sector, and academic representatives to determine what data they need to generate social and economic value;</li></ul>
<p><strong>This is also covered under the Principle 3.</strong></p>
<ul><li>provide training programs, tools, and guidelines designed to ensure government employees are capable of using open data effectively in policy development processes;</li></ul>
<p><strong>This should be part of Principle 1.</strong></p>
<ul><li>encourage non-governmental organisations to open up data created and collected by them in order to move toward a richer open data ecosystem with multiple sources of open data;</li></ul>
<p><strong>I agree with ABS. Why not ‘non-governmental organisations and the private sector’?</strong></p>
<p><strong>Also the document shifts back and forth between ‘civil society organisations’ and ‘non-governmental organisations’. If both mean the same in this document, then it should use only one.</strong></p>
<p> </p>
<h2>General Comments on the Charter</h2>
<p> </p>
<p><strong>1. Why not merge the Principle 4 and 5 so as to describe an overall situation of engagement and collaboration. The ends can be commercial acts or towards democratic practices, but the existing principles do not make much a difference between the two types of acts.</strong></p>
<p><strong>2. Further, can a new principle be added at the end that would address the implementation process of the Action Plan? Specifically, it should clarify how the implementation itself be an open process, with not only the Action Plan but annual reports regarding the status of implementation. This principle may connect to the work being done by the Implementation WG.</strong></p>
<p> </p>
<p>
For more details visit <a href='http://editors.cis-india.org/openness/international-open-data-charter-comments-by-cis'>http://editors.cis-india.org/openness/international-open-data-charter-comments-by-cis</a>
</p>
No publishersumandroOpen DataOpen Government DataFeaturedPoliciesOpennessInternational Open Data Charter2015-09-08T11:01:01ZBlog EntryWorkshop on Open Data for Human Development
http://editors.cis-india.org/openness/blog-old/workshop-on-open-data-for-human-development-2015-06
<b>Sumandro Chattapadhyay and Sunil Abraham will take part in the workshop being organised for government officials from Bhutan, Maldives, Meghalaya, Sikkim, and Tripura, by the International Centre for Human Development (IC4HD) of UNDP India, during June 3-6, 2015. The workshop will be held at the National Institute of Advanced Studies Campus in Bengaluru. Sunil will be one of the panelists in the opening discussion on 'data and transparency in governance,' and Sumandro will provide input for and lead the sessions on developing the draft implementation plan for the Sikkim Open Data Acquisition and Accessibility Policy. Sumandro worked with the IC4HD team to design the objectives and the agenda of the workshop.</b>
<p> </p>
<h2>Sikkim Open Data Acquisition and Accessibility Policy</h2>
<p> </p>
<p>Government of Sikkim passed the <a href="http://www.sikkim.gov.in/stateportal/Link/SODAAP%20Policy%20Document.pdf" target="_blank">SODAA Policy</a> in 2014 so as to streamline and open up the availability of “authentic data to buttress the achievements of the Government of Sikkim and to gather data on key metrics to be able to spur growth in all the areas of human development.” The Policy mandates setting up an open data portal, hosted by the State Data Centre of Sikkim, where data contributed by all the state government agencies will reside, and from which the same data will be made openly accessible to government agencies, non-government organisations, and private individuals alike. Only data that is shareable – data that is not part of negative list prepared by any government agency – and that is non-sensitive – data that does not contain information that can be used to identify any private individual – will be made available through this Sikkim open data portal. The Department of Information Technology of the Government of Sikkim has been assigned the role of being the nodal agency for coordinating and monitoring the implementation “of policy through close collaboration with all State Government Departments and agencies.”</p>
<p> </p>
<h2>Objectives of the Workshop</h2>
<p> </p>
<p>The Government of Sikkim understands that data collection, management, and reporting processes at the different departments must go through a structural reconfiguration before systematic and sustainable publication of data through this open data portal can be possible. This work will of course involve a long duration of change, and participation of a wide range of actors. The <a href="http://www.in.undp.org/content/india/en/home/operations/projects/human-development/the-international-centre-for-human-development.html" target="_blank">International Centre for Human Development</a>, at UNDP India, is organising this workshop for Sikkim government officials to conceptualise and develop the outlines of an action strategy towards this goal of streamlining data acquisition and publication processes across government departments.</p>
<p>Discussions in this workshop will focus on the activities of four departments of the Government of Sikkim – Department of Health, Rural Management and Development Department (RMDD), Human Resource Development Department (HRDD), and Department of Agriculture. At least two officials from each of these departments would take part in the workshop. Apart from these departments, officials from Department of Information Technology (DIT), Department of Economic Statistics, Monitoring, and Evaluation (DESME), and others, will also participate.</p>
<p>Apart from government officials from Sikkim, those from Bhutan, Maldives, Meghalaya, and Tripura will also attend the workshop, so as to think ahead towards their respective open data initiatives.</p>
<p> </p>
<h2>Agenda of the Workshop</h2>
<p> </p>
<h3>Day 1: June 3, 2015</h3>
<p> </p>
<table class="plain">
<thead>
<tr>
<th>Time</th>
<th>Session</th>
</tr>
</thead>
<tbody>
<tr>
<td>0930-1000</td>
<td><strong>Welcome and Introductions</strong><br />
A.K. Shiva Kumar, Director, IC4HD<br />
P.D. Rai, Honourable Member of Parliament (LS) from Sikkim</td>
</tr>
<tr>
<td>1000-1100<br />
<strong>Session 1</strong></td>
<td><strong>Panel Discussion</strong><br />
<strong>Data and Transparency in Governance</strong><br />
Moderator: P. D. Rai<br />
Panellists:
<ul><li>Srivatsa Krishna, Secretary, Department of Information Technology, Biotechnology and Science & Technology, Government of Karnataka</li>
<li>B. Gangaiah, Additional Director General, Centre for Good Governance, Hyderabad</li>
<li>Sunil Abraham, Executive Director, The Centre for Internet and Society</li></ul>
</td>
</tr>
<tr>
<td>1100-1130<br />
<strong>Session 2</strong></td>
<td><strong>Sikkim Open Data Acquisition and Accessibility Policy</strong><br />
Moderator: P. D. Rai<br />
Presentation by: T. Samdup, Joint Director, Department of Information Technology, Sikkim</td>
</tr>
<tr>
<td>1130-1200</td>
<td><strong>Tea Break</strong></td>
</tr>
<tr>
<td>1200-1300<br />
<strong>Session 3</strong></td>
<td><strong>Implementing an Open Data Policy - Key Components</strong><br />
Moderator: A. K. Shiva Kumar<br />
Presentation by: Sumandro Chattapadhyay, The Centre for Internet and Society</td>
</tr>
<tr>
<td>1300-1400</td>
<td><strong>Lunch</strong></td>
</tr>
<tr>
<td>1400-1430<br />
<strong>Session 4</strong></td>
<td><strong>Group Exercise 1</strong><br />
<strong>Challenges of Opening up Government Data in Sikkim</strong><br />
Facilitated by: Sumandro Chattapadhyay</td>
</tr>
<tr>
<td>1430-1530<br />
<strong>Session 5</strong></td>
<td><strong>Mobile Phone-based Data Collection</strong><br />
<strong>Introduction to Akvo FLOW</strong><br />
Moderator: Meenaz Munshi, IC4HD<br />
Presentation by: Joy Ghosh and Amitangshu Acharya, AKVO</td>
</tr>
<tr>
<td>1530-1600</td>
<td>Tea Break</td>
</tr>
<tr>
<td>16:00-1730<br />
<strong>Session 6</strong></td>
<td><strong>Group Exercise 2</strong><br />
<strong>Collecting Data Using Akvo FLOW</strong><br />
Facilitated by: Joy Ghosh and Amitangshu Acharya, AKVO</td>
</tr>
</tbody>
</table>
<p> </p>
<h3>Day 2: June 4, 2015</h3>
<p> </p>
<table class="plain">
<thead>
<tr>
<th>Time</th>
<th>Session</th>
</tr>
</thead>
<tbody>
<tr>
<td>0930-1000<br />
<strong>Session 7</strong></td>
<td><strong>Analysing, Visualising, and Publishing Data</strong><br />
Moderator: Amitangshu Acharya<br />
Presentation by: Thejesh GN, DataMeet</td>
</tr>
<tr>
<td>1000-1045<br />
<strong>Session 8</strong></td>
<td><strong>Collecting, Visualising, and Publishing Geographic Data</strong><br />
Moderator: Amitangshu Acharya<br />
Presentation by: Shiv Ramachandran, MapBox</td>
</tr>
<tr>
<td>1045-1145<br />
<strong>Session 9</strong></td>
<td><strong>Group Exercise 3</strong><br />
<strong>Organising, Analysing, Visualising, and Publishing Data</strong><br />
Facilitated by: Thejesh GN and Shiv Ramachandran</td>
</tr>
<tr>
<td>1145-1200</td>
<td><strong>Tea Break</strong></td>
</tr>
<tr>
<td>1200-1300</td>
<td><strong>Group Exercise 3</strong><br />
<strong>Organising, Analysing, Visualising, and Publishing Data</strong><br />
(Continued)</td>
</tr>
<tr>
<td>1300-1400</td>
<td><strong>Lunch</strong></td>
</tr>
<tr>
<td>1400-1500<br />
<strong>Session 10</strong></td>
<td><strong>Open Data and Health Management</strong><br />
Presentation by: Dr. Shiban Ganju, Consultant, Ingalls Health, Harvey, Illinois, Chicago; Chair, Atrimed Health Consulting, Bangalore</td>
</tr>
<tr>
<td>1500-1600<br />
<strong>Session 11</strong></td>
<td><strong>Open Data and Primary Education</strong><br />
Presentation by: Gautam John, Karnataka Learning Partnership</td>
</tr>
</tbody>
</table>
<p> </p>
<h3>Day 3: June 5, 2015</h3>
<p> </p>
<table class="plain">
<thead>
<tr>
<th>Time</th>
<th>Session</th>
</tr>
</thead>
<tbody>
<tr>
<td>0930-1030<br />
<strong>Session 12</strong></td>
<td><strong>Panel Discussion</strong><br />
<strong>Regional Experiences and Reflections on Open Data</strong><br />
Panellists: representative from Bhutan, and from Meghalaya</td>
</tr>
<tr>
<td>1030-1115<br />
<strong>Session 13</strong></td>
<td><strong>Implementing National Data Sharing and Accessibility Policy</strong><br />
Presentation by: D. P. Misra, National Informatics Centre</td>
</tr>
<tr>
<td>1115-1130<br />
<strong>Session 14</strong></td>
<td><strong>Group Exercise 4</strong><br />
<strong>Drafting the SODAAP Implementation Plan</strong><br />
Facilitated by: Sumandro Chattapadhyay</td>
</tr>
<tr>
<td>1130-1200</td>
<td><strong>Tea Break</strong></td>
</tr>
<tr>
<td>1200-1300</td>
<td><strong>Group Exercise 4</strong><br />
<strong>Drafting the SODAAP Implementation Plan</strong><br />
(Continued)</td>
</tr>
<tr>
<td>1300-1400</td>
<td><strong>Lunch</strong></td>
</tr>
<tr>
<td>1400-1500<br />
<strong>Session 15</strong></td>
<td><strong>Group Presentations</strong><br />
<strong>Draft SODAAP Implementation Plan</strong><br />
Moderator: P. D. Rai<br />
Facilitated by: Sumandro Chattapadhyay</td>
</tr>
<tr>
<td>1500-1530</td>
<td><strong>Wrap-Up and Vote of Thanks</strong></td>
</tr>
</tbody>
</table>
<p> </p>
<p>
For more details visit <a href='http://editors.cis-india.org/openness/blog-old/workshop-on-open-data-for-human-development-2015-06'>http://editors.cis-india.org/openness/blog-old/workshop-on-open-data-for-human-development-2015-06</a>
</p>
No publishersumandroOpen DataFeaturedWorkshopPolicies2015-06-02T15:34:06ZBlog EntryReading the Fine Script: Service Providers, Terms and Conditions and Consumer Rights
http://editors.cis-india.org/internet-governance/blog/reading-between-the-lines-service-providers-terms-and-conditions-and-consumer-rights
<b>This year, an increasing number of incidents, related to consumer rights and service providers, have come to light. This blog illustrates the facts of the cases, and discusses the main issues at stake, namely, the role and responsibilities of providers of platforms for user-created content with regard to consumer rights.</b>
<p style="text-align: justify; "><span>On 1st July, 2014 the Federal Trade Commission (FTC) filed a complaint against T-Mobile USA,</span><a href="file:///C:/Users/jyoti/Desktop/Reading%20the%20fine%20script%20When%20terms%20and%20conditions%20apply.docx#_ftn1">[1]</a><span> accusing the service provider of 'cramming' customers bills, with millions of dollars of unauthorized charges. Recently, another service provider, received flak from regulators and users worldwide, after it published a paper, 'Experimental evidence of massive-scale emotional contagion through social networks'.</span><a href="file:///C:/Users/jyoti/Desktop/Reading%20the%20fine%20script%20When%20terms%20and%20conditions%20apply.docx#_ftn2">[2]</a><span> The paper described Facebook's experiment on more than 600,000 users, to determine whether manipulating user-generated content, would affect the emotions of its users.</span></p>
<p style="text-align: justify; ">In both incidents the terms that should ensure the protection of their user's legal rights, were used to gain consent for actions on behalf of the service providers, that were not anticipated at the time of agreeing to the terms and conditions (T&Cs) by the consumer. More precisely, both cases point to the underlying issue of how users are bound by T&Cs, and in a mediated online landscape—highlight, the need to pay attention to the regulations that govern the online engagement of users.</p>
<p style="text-align: justify; "><b>I have read and agree to the terms</b></p>
<p style="text-align: justify; ">In his statement, Chief Executive Officer, John Legere might have referred to T-Mobile as "the most pro-consumer company in the industry",<a href="file:///C:/Users/jyoti/Desktop/Reading%20the%20fine%20script%20When%20terms%20and%20conditions%20apply.docx#_ftn3">[3]</a> however the FTC investigation revelations, that many customers never authorized the charges, suggest otherwise. The FTC investigation also found that, T-Mobile received 35-40 per cent of the amount charged for subscriptions, that were made largely through innocuous services, that customers had been signed up to, without their knowledge or consent. Last month news broke, that just under 700,000 users 'unknowingly' participated in the Facebook study, and while the legality and ethics of the experiment are being debated, what is clear is that Facebook violated consumer rights by not providing the choice to opt in or out, or even the knowledge of such social or psychological experiments to its users.</p>
<p style="text-align: justify; ">Both incidents boil down to the sensitive question of consent. While binding agreements around the world work on the condition of consent, how do we define it and what are the implications of agreeing to the terms?</p>
<p style="text-align: justify; "><b>Terms of Service: Conditions are subject to change </b></p>
<p style="text-align: justify; ">A legal necessity, the existing terms of service (TOS)—as they are also known—as an acceptance mechanism are deeply broken. The policies of online service providers are often, too long, and with no shorter or multilingual versions, require substantial effort on part of the user to go through in detail. A 2008 Carnegie Mellon study estimated it would take an average user 244 hours every year to go through the policies they agree to online.<a href="file:///C:/Users/jyoti/Desktop/Reading%20the%20fine%20script%20When%20terms%20and%20conditions%20apply.docx#_ftn4">[4]</a> Based on the study, Atlantic's Alexis C. Madrigal derived that reading all of the privacy policies an average Internet user encounters in a year, would take 76 working days.<a href="file:///C:/Users/jyoti/Desktop/Reading%20the%20fine%20script%20When%20terms%20and%20conditions%20apply.docx#_ftn5">[5]</a></p>
<p style="text-align: justify; ">The costs of time are multiplied by the fact that terms of services change with technology, making it very hard for a user to keep track of all of the changes over time. Moreover, many services providers do not even commit to the obligation of notifying the users of any changes in the TOS. Microsoft, Skype, Amazon, YouTube are examples of some of the service providers that have not committed to any obligations of notification of changes and often, there are no mechanisms in place to ensure that service providers are keeping users updated.</p>
<p style="text-align: justify; ">Facebook has said that the recent social experiment is perfectly legal under its TOS,<a href="file:///C:/Users/jyoti/Desktop/Reading%20the%20fine%20script%20When%20terms%20and%20conditions%20apply.docx#_ftn6">[6]</a> the question of fairness of the conditions of users consent remain debatable. Facebook has a broad copyright license that goes beyond its operating requirements, such as the right to 'sublicense'. The copyright also does not end when users stop using the service, unless the content has been deleted by everyone else.</p>
<p style="text-align: justify; ">More importantly, since 2007, Facebook has brought major changes to their lengthy TOS about every year.<a href="file:///C:/Users/jyoti/Desktop/Reading%20the%20fine%20script%20When%20terms%20and%20conditions%20apply.docx#_ftn7">[7]</a> And while many point that Facebook is transparent, as it solicits feedback preceding changes to their terms, the accountability remains questionable, as the results are not binding unless 30% of the actual users vote. Facebook can and does, track users and shares their data across websites, and has no obligation or mechanism to inform users of the takedown requests.</p>
<p style="text-align: justify; ">Courts in different jurisdictions under different laws may come to different conclusions regarding these practices, especially about whether changing terms without notifying users is acceptable or not. Living in a society more protective of consumer rights is however, no safeguard, as TOS often include a clause of choice of law which allow companies to select jurisdictions whose laws govern the terms.</p>
<p style="text-align: justify; ">The recent experiment bypassed the need for informed user consent due to Facebook's Data Use Policy<a href="file:///C:/Users/jyoti/Desktop/Reading%20the%20fine%20script%20When%20terms%20and%20conditions%20apply.docx#_ftn8">[8]</a>, which states that once an account has been created, user data can be used for 'internal operations, including troubleshooting, data analysis, testing, research and service improvement.' While the users worldwide may be outraged, legally, Facebook acted within its rights as the decision fell within the scope of T&Cs that users consented to. The incident's most positive impact might be in taking the questions of Facebook responsibilities towards protecting users, including informing them of the usage of their data and changes in data privacy terms, to a worldwide audience.</p>
<p style="text-align: justify; "><b>My right is bigger than yours</b></p>
<p style="text-align: justify; ">Most TOS agreements, written by lawyers to protect the interests of the companies add to the complexities of privacy, in an increasingly user-generated digital world. Often, intentionally complicated agreements, conflict with existing data and user rights across jurisdictions and chip away at rights like ownership, privacy and even the ability to sue. With conditions that that allow for change in terms at anytime, existing users do not have ownership or control over their data.</p>
<p style="text-align: justify; ">In April New York Times, reported of updates to the legal policy of General Mills (GM), the multibillion-dollar food company.<a href="file:///C:/Users/jyoti/Desktop/Reading%20the%20fine%20script%20When%20terms%20and%20conditions%20apply.docx#_ftn9">[9]</a> The update broadly asserted that consumers interacting with the company in a variety of ways and venues no longer can sue GM, but must instead, submit any complaint to “informal negotiation” or arbitration. Since then, GM has backtracked and clarified that “online communities” mentioned in the policy referred only to those online communities hosted by the company on its own websites.<a href="file:///C:/Users/jyoti/Desktop/Reading%20the%20fine%20script%20When%20terms%20and%20conditions%20apply.docx#_ftn10">[10]</a> Clarification aside, as Julia Duncan, Director of Federal programs at American Association for Justice points out, the update in the terms were so broad, that they were open to wide interpretation and anything that consumers purchase from the company could have been held to this clause. <a href="file:///C:/Users/jyoti/Desktop/Reading%20the%20fine%20script%20When%20terms%20and%20conditions%20apply.docx#_ftn11">[11]</a></p>
<p style="text-align: justify; "><b>Data and whose rights?</b></p>
<p style="text-align: justify; ">Following Snowden revelations, data privacy has become a contentious issue in the EU, and TOS, that allow the service providers to unilaterally alter terms of the contract, will face many challenges in the future. In March Edward Snowden sent his testimony to the European Parliament calling for greater accountability and highlighted that in "a global, interconnected world where, when national laws fail like this, our international laws provide for another level of accountability."<a href="file:///C:/Users/jyoti/Desktop/Reading%20the%20fine%20script%20When%20terms%20and%20conditions%20apply.docx#_ftn12">[12]</a> Following the testimony came the European Parliament's vote in favor of new safeguards on the personal data of EU citizens, when it’s transferred to non-EU.<a href="file:///C:/Users/jyoti/Desktop/Reading%20the%20fine%20script%20When%20terms%20and%20conditions%20apply.docx#_ftn13">[13]</a> The new regulations seek to give users more control over their personal data including the right to ask for data from companies that control it and seek to place the burden of proof on the service providers.</p>
<p style="text-align: justify; ">The regulation places responsibility on companies, including third-parties involved in data collection, transfer and storing and greater transparency on concerned requests for information. The amendment reinforces data subject right to seek erasure of data and obliges concerned parties to communicate data rectification. Also, earlier this year, the European Court of Justice (ECJ) ruled in favor of the 'right to be forgotten'<a href="file:///C:/Users/jyoti/Desktop/Reading%20the%20fine%20script%20When%20terms%20and%20conditions%20apply.docx#_ftn14">[14]</a>. The ECJ ruling recognised data subject's rights override the interest of internet users, however, with exceptions pertaining to nature of information, its sensitivity for the data subject's private life and the role of the data subject in public life.</p>
<p style="text-align: justify; ">In May, the Norwegian Consumer Council filed a complaint with the Norwegian Consumer Ombudsman, “… based on the discrepancies between Norwegian Law and the standard terms and conditions applicable to the Apple iCloud service...”, and, “...in breach of the law regarding control of marketing and standard agreements.”<a href="file:///C:/Users/jyoti/Desktop/Reading%20the%20fine%20script%20When%20terms%20and%20conditions%20apply.docx#_ftn15">[15]</a> The council based its complaint on the results of a study, published earlier this year, that found terms were hazy and varied across services including iCloud, Drop Box, Google Drive, Jotta Cloud, and Microsoft OneDrive. The Norwegian Council study found that Google TOS, allow for users content to be used for other purposes than storage, including by partners and that it has rights of usage even after the service is cancelled. None of the providers provide a guarantee that data is safe from loss, while many, have the ability to terminate an account without notice. All of the service providers can change the terms of service but only Google and Microsoft give an advance notice.</p>
<p style="text-align: justify; ">The study also found service providers lacking with respect to European privacy standards, with many allowing for browsing of user content. Tellingly, Google had received a fine in January by the French Data Protection Authority, that stated regarding Google's TOS, "permits itself to combine all the data it collects about its users across all of its services without any legal basis."</p>
<p style="text-align: justify; "><b>To blame or not to blame</b></p>
<p style="text-align: justify; ">Facebook is facing a probe by the UK Information Commissioner's Office, to assess if the experiment conducted in 2012 was a violation of data privacy laws.<a href="file:///C:/Users/jyoti/Desktop/Reading%20the%20fine%20script%20When%20terms%20and%20conditions%20apply.docx#_ftn16">[16]</a> The FTC asked the court to order T-Mobile USA, to stop mobile cramming, provide refunds and give up any revenues from the practice. The existing mechanisms of online consent, do not simplify the task of agreeing to multiple documents and services at once, a complexity which manifolds, with the involvement of third parties.</p>
<p style="text-align: justify; ">Unsurprisingly, T-Mobile's Legere termed the FTC lawsuit misdirected and blamed the companies providing the text services for the cramming.<a href="file:///C:/Users/jyoti/Desktop/Reading%20the%20fine%20script%20When%20terms%20and%20conditions%20apply.docx#_ftn17">[17]</a> He felt those providers should be held accountable, despite allegations that T-Mobile's billing practices made it difficult for consumers to detect that they were being charged for unauthorized services and having shared revenues with third-party providers. Interestingly, this is the first action against a wireless carrier for cramming and the FTC has a precedent of going after smaller companies that provide the services.</p>
<p style="text-align: justify; ">The FTC charged T-Mobile USA with deceptive billing practices in putting the crammed charges under a total for 'use charges' and 'premium services' and failure to highlight that portion of the charge was towards third-party charges. Further, the company urged customers to take complaints to vendors and was not forthcoming with refunds. For now, T-Mobile may be able to share the blame, the incident brings to question its accountability, especially as going forward it has entered a pact along with other carriers in USA including Verizon and AT&T, agreeing to stop billing customers for third-party services. Even when practices such as cramming are deemed illegal, it does not necessarily mean that harm has been prevented. Often users bear the burden of claiming refunds and litigation comes at a cost while even after being fined companies could have succeeded in profiting from their actions.</p>
<p style="text-align: justify; "><b>Conclusion </b></p>
<p style="text-align: justify; ">Unfair terms and conditions may arise when service providers include terms that are difficult to understand or vague in their scope. TOS that prevent users from taking legal action, negate liability for service providers actions despite the companies actions that may have a direct bearing on users, are also considered unfair. More importantly, any term that is hidden till after signing the contract, or a term giving the provider the right to change the contract to their benefit including wider rights for service provider wide in comparison to users such as a term that that makes it very difficult for users to end a contract create an imbalance. These issues get further complicated when the companies control and profiting from data are doing so with user generated data provided free to the platform.</p>
<p style="text-align: justify; ">In the knowledge economy, web companies play a decisive role as even though they work for profit, the profit is derived out of the knowledge held by individuals and groups. In their function of aggregating human knowledge, they collect and provide opportunities for feedback of the outcomes of individual choices. The significance of consent becomes a critical part of the equation when harnessing individual information. In France, consent is part of the four conditions necessary to be forming a valid contract (article 1108 of the Code Civil).</p>
<p style="text-align: justify; ">The cases highlight the complexities that are inherent in the existing mechanisms of online consent. The question of consent has many underlying layers such as reasonable notice and contractual obligations related to consent such as those explored in the case in Canada, which looked at whether clauses of TOS were communicated reasonably to the user, a topic for another blog. For now, we must remember that by creating and organising social knowledge that further human activity, service providers, serve a powerful function. And as the saying goes, with great power comes great responsibility.</p>
<hr size="1" style="text-align: justify; " width="33%" />
<p style="text-align: justify; "><a href="file:///C:/Users/jyoti/Desktop/Reading%20the%20fine%20script%20When%20terms%20and%20conditions%20apply.docx#_ftnref1">[1]</a> 'FTC Alleges T-Mobile Crammed Bogus Charges onto Customers’ Phone Bills', published 1 July, 2014. See: http://www.ftc.gov/news-events/press-releases/2014/07/ftc-alleges-t-mobile-crammed-bogus-charges-customers-phone-bills</p>
<p style="text-align: justify; "><a href="file:///C:/Users/jyoti/Desktop/Reading%20the%20fine%20script%20When%20terms%20and%20conditions%20apply.docx#_ftnref2">[2]</a> 'Experimental evidence of massive-scale emotional contagion through social networks', Adam D. I. Kramera,1, Jamie E. Guilloryb, and Jeffrey T. Hancock, published March 25, 2014. See:http://www.pnas.org/content/111/24/8788.full.pdf+html?sid=2610b655-db67-453d-bcb6-da4efeebf534</p>
<p style="text-align: justify; "><a href="file:///C:/Users/jyoti/Desktop/Reading%20the%20fine%20script%20When%20terms%20and%20conditions%20apply.docx#_ftnref3">[3]</a> 'U.S. sues T-Mobile USA, alleges bogus charges on phone bills, Reuters published 1st July, 2014 See: http://www.reuters.com/article/2014/07/01/us-tmobile-ftc-idUSKBN0F656E20140701</p>
<p style="text-align: justify; "><a href="file:///C:/Users/jyoti/Desktop/Reading%20the%20fine%20script%20When%20terms%20and%20conditions%20apply.docx#_ftnref4">[4]</a> 'The Cost of Reading Privacy Policies', Aleecia M. McDonald and Lorrie Faith Cranor, published I/S: A Journal of Law and Policy for the Information Society 2008 Privacy Year in Review issue. See: http://lorrie.cranor.org/pubs/readingPolicyCost-authorDraft.pdf</p>
<p style="text-align: justify; "><a href="file:///C:/Users/jyoti/Desktop/Reading%20the%20fine%20script%20When%20terms%20and%20conditions%20apply.docx#_ftnref5">[5]</a> 'Reading the Privacy Policies You Encounter in a Year Would Take 76 Work Days', Alexis C. Madrigal, published The Atlantic, March 2012 See: http://www.theatlantic.com/technology/archive/2012/03/reading-the-privacy-policies-you-encounter-in-a-year-would-take-76-work-days/253851/</p>
<p style="text-align: justify; "><a href="file:///C:/Users/jyoti/Desktop/Reading%20the%20fine%20script%20When%20terms%20and%20conditions%20apply.docx#_ftnref6">[6]</a> Facebook Legal Terms. See: https://www.facebook.com/legal/terms</p>
<p style="text-align: justify; "><a href="file:///C:/Users/jyoti/Desktop/Reading%20the%20fine%20script%20When%20terms%20and%20conditions%20apply.docx#_ftnref7">[7]</a> 'Facebook's Eroding Privacy Policy: A Timeline', Kurt Opsahl, Published Electronic Frontier Foundation , April 28, 2010 See:https://www.eff.org/deeplinks/2010/04/facebook-timeline</p>
<p style="text-align: justify; "><a href="file:///C:/Users/jyoti/Desktop/Reading%20the%20fine%20script%20When%20terms%20and%20conditions%20apply.docx#_ftnref8">[8]</a> Facebook Data Use Policy. See: https://www.facebook.com/about/privacy/</p>
<p style="text-align: justify; "><a href="file:///C:/Users/jyoti/Desktop/Reading%20the%20fine%20script%20When%20terms%20and%20conditions%20apply.docx#_ftnref9">[9]</a> 'When ‘Liking’ a Brand Online Voids the Right to Sue', Stephanie Strom, published in New York Times on April 16, 2014 See: http://www.nytimes.com/2014/04/17/business/when-liking-a-brand-online-voids-the-right-to-sue.html?ref=business</p>
<p style="text-align: justify; "><a href="file:///C:/Users/jyoti/Desktop/Reading%20the%20fine%20script%20When%20terms%20and%20conditions%20apply.docx#_ftnref10">[10]</a> Explaining our website privacy policy and legal terms, published April 17, 2014 See:http://www.blog.generalmills.com/2014/04/explaining-our-website-privacy-policy-and-legal-terms/#sthash.B5URM3et.dpufhttp://www.blog.generalmills.com/2014/04/explaining-our-website-privacy-policy-and-legal-terms/</p>
<p style="text-align: justify; "><a href="file:///C:/Users/jyoti/Desktop/Reading%20the%20fine%20script%20When%20terms%20and%20conditions%20apply.docx#_ftnref11">[11]</a> General Mills Amends New Legal Policies, Stephanie Strom, published in New York Times on 1http://www.nytimes.com/2014/04/18/business/general-mills-amends-new-legal-policies.html?_r=0</p>
<p style="text-align: justify; "><a href="file:///C:/Users/jyoti/Desktop/Reading%20the%20fine%20script%20When%20terms%20and%20conditions%20apply.docx#_ftnref12">[12]</a> Edward Snowden Statement to European Parliament published March 7, 2014. See: http://www.europarl.europa.eu/document/activities/cont/201403/20140307ATT80674/20140307ATT80674EN.pdf</p>
<p style="text-align: justify; "><a href="file:///C:/Users/jyoti/Desktop/Reading%20the%20fine%20script%20When%20terms%20and%20conditions%20apply.docx#_ftnref13">[13]</a> Progress on EU data protection reform now irreversible following European Parliament vote, published 12 March 201 See: http://europa.eu/rapid/press-release_MEMO-14-186_en.htm</p>
<p style="text-align: justify; "><a href="file:///C:/Users/jyoti/Desktop/Reading%20the%20fine%20script%20When%20terms%20and%20conditions%20apply.docx#_ftnref14">[14]</a> European Court of Justice rules Internet Search Engine Operator responsible for Processing Personal Data Published by Third Parties, Jyoti Panday, published on CIS blog on May 14, 2014. See: http://cis-india.org/internet-governance/blog/ecj-rules-internet-search-engine-operator-responsible-for-processing-personal-data-published-by-third-parties</p>
<p style="text-align: justify; "><a href="file:///C:/Users/jyoti/Desktop/Reading%20the%20fine%20script%20When%20terms%20and%20conditions%20apply.docx#_ftnref15">[15]</a> Complaint regarding Apple iCloud’s terms and conditions , published on 13 May 2014 See:http://www.forbrukerradet.no/_attachment/1175090/binary/29927</p>
<p style="text-align: justify; "><a href="file:///C:/Users/jyoti/Desktop/Reading%20the%20fine%20script%20When%20terms%20and%20conditions%20apply.docx#_ftnref16">[16]</a> 'Facebook faces UK probe over emotion study' See: http://www.bbc.co.uk/news/technology-28102550</p>
<p style="text-align: justify; "><a href="file:///C:/Users/jyoti/Desktop/Reading%20the%20fine%20script%20When%20terms%20and%20conditions%20apply.docx#_ftnref17">[17]</a> Our Reaction to the FTC Lawsuit See: http://newsroom.t-mobile.com/news/our-reaction-to-the-ftc-lawsuit.htm</p>
<p>
For more details visit <a href='http://editors.cis-india.org/internet-governance/blog/reading-between-the-lines-service-providers-terms-and-conditions-and-consumer-rights'>http://editors.cis-india.org/internet-governance/blog/reading-between-the-lines-service-providers-terms-and-conditions-and-consumer-rights</a>
</p>
No publisherjyotiSocial MediaConsumer RightsGoogleinternet and societyPrivacyTransparency and AccountabilityIntermediary LiabilityAccountabilityFacebookData ProtectionPoliciesSafety2014-07-04T06:31:37ZBlog EntryAn Evidence based Intermediary Liability Policy Framework: Workshop at IGF
http://editors.cis-india.org/internet-governance/blog/igf-workshop-an-evidence-based-intermediary-liability-policy-framework
<b>CIS is organising a workshop at the Internet Governance Forum 2014. The workshop will be an opportunity to present and discuss ongoing research on the changing definition of intermediaries and their responsibilities across jurisdictions and technologies and contribute to a comprehensible framework for liability that is consistent with the capacity of the intermediary and with international human-rights standards.</b>
<p style="text-align: justify; ">The Centre for Internet and Society, India and Centre for Internet and Society, Stanford Law School, USA, will be organising a workshop to analyse the role of intermediary platforms in relation to freedom of expression, freedom of information and freedom of association at the Internet Governance Forum 2014. <span>The aim of the workshop is to highlight the increasing importance of digital rights and broad legal protections of stakeholders in an increasingly knowledge-based economy. The workshop will discuss public policy issues associated with Internet intermediaries, in particular their roles, legal responsibilities and related liability limitations in context of the evolving nature and role of intermediaries in the Internet ecosystem. distinct</span></p>
<p style="text-align: justify; "><b>Online Intermediaries: Setting the context</b></p>
<p style="text-align: justify; ">The Internet has facilitated unprecedented access to information and amplified avenues for expression and engagement by removing the limits of geographic boundaries and enabling diverse sources of information and online communities to coexist. Against the backdrop of a broadening base of users, the role of intermediaries that enable economic, social and political interactions between users in a global networked communication is ubiquitous. Intermediaries are essential to the functioning of the Internet as many producers and consumers of content on the internet rely on the action of some third party–the so called intermediary. Such intermediation ranges from the mere provision of connectivity, to more advanced services such as providing online storage spaces for data, acting as platforms for storage and sharing of user generated content (UGC), or platforms that provides links to other internet content.</p>
<p style="text-align: justify; ">Online intermediaries enhance economic activity by reducing costs, inducing competition by lowering the barriers for participation in the knowledge economy and fuelling innovation through their contribution to the wider ICT sector as well as through their key role in operating and maintaining Internet infrastructure to meet the network capacity demands of new applications and of an expanding base of users.</p>
<p style="text-align: justify; ">Intermediary platforms also provide social benefits, by empowering users and improving choice through social and participative networks, or web services that enable creativity and collaboration amongst individuals. By enabling platforms for self-expression and cooperation, intermediaries also play a critical role in establishing digital trust, protection of human rights such as freedom of speech and expression, privacy and upholding fundamental values such as freedom and democracy.</p>
<p style="text-align: justify; ">However, the economic and social benefits of online intermediaries are conditional to a framework for protection of intermediaries against legal liability for the communication and distribution of content which they enable.</p>
<p style="text-align: justify; "><b>Intermediary Liability</b></p>
<p style="text-align: justify; ">Over the last decade, right holders, service providers and Internet users have been locked in a debate on the potential liability of online intermediaries. The debate has raised global concerns on issues such as, the extent to which Internet intermediaries should be held responsible for content produced by third parties using their Internet infrastructure and how the resultant liability would affect online innovation and the free flow of knowledge in the information economy?</p>
<p style="text-align: justify; ">Given the impact of their services on communications, intermediaries find themselves as either directly liable for their actions, or indirectly (or “secondarily”) liable for the actions of their users. Requiring intermediaries to monitor the legality of the online content poses an insurmountable task. Even if monitoring the legality of content by intermediaries against all applicable legislations were possible, the costs of doing so would be prohibitively high. Therefore, placing liability on intermediaries can deter their willingness and ability to provide services, hindering the development of the internet itself.</p>
<p style="text-align: justify; ">Economics of intermediaries are dependent on scale and evaluating the legality of an individual post exceeds the profit from hosting the speech, and in the absence of judicial oversight can lead to a private censorship regime. Intermediaries that are liable for content or face legal exposure, have powerful incentives, to police content and limit user activity to protect themselves. The result is curtailing of legitimate expression especially where obligations related to and definition of illegal content is vague. Content policing mandates impose significant compliance costs limiting the innovation and competiveness of such platforms.</p>
<p style="text-align: justify; ">More importantly, placing liability on intermediaries has a chilling effect on freedom of expression online. Gate keeping obligations by service providers threaten democratic participation and expression of views online, limiting the potential of individuals and restricting freedoms. Imposing liability can also indirectly lead to the death of anonymity and pseudonymity, pervasive surveillance of users' activities, extensive collection of users' data and ultimately would undermine the digital trust between stakeholders.</p>
<p style="text-align: justify; ">Thus effectively, imposing liability for intermediaries creates a chilling effect on Internet activity and speech, create new barriers to innovation and stifles the Internet's potential to promote broader economic and social gains. To avoid these issues, legislators have defined 'safe harbours', limiting the liability of intermediaries under specific circumstances.</p>
<p style="text-align: justify; ">Online intermediaries do not have direct control of what information is or information are exchanged via their platform and might not be aware of illegal content per se. A key framework for online intermediaries, such limited liability regimes provide exceptions for third party intermediaries from liability rules to address this asymmetry of information that exists between content producers and intermediaries.</p>
<p style="text-align: justify; ">However, it is important to note, that significant differences exist concerning the subjects of these limitations, their scope of provisions and procedures and modes of operation. The 'notice and takedown' procedures are at the heart of the safe harbour model and can be subdivided into two approaches:</p>
<p style="text-align: justify; ">a. Vertical approach where liability regime applies to specific types of content exemplified in the US Digital Copyright Millennium Act</p>
<p style="text-align: justify; ">b. Horizontal approach based on the E-Commerce Directive (ECD) where different levels of immunity are granted depending on the type of activity at issue</p>
<p style="text-align: justify; "><b>Current framework </b></p>
<p style="text-align: justify; ">Globally, three broad but distinct models of liability for intermediaries have emerged within the Internet ecosystem:</p>
<p style="text-align: justify; ">1. Strict liability model under which intermediaries are liable for third party content used in countries such as China and Thailand</p>
<p style="text-align: justify; ">2. Safe harbour model granting intermediaries immunity, provided their compliance on certain requirements</p>
<p style="text-align: justify; ">3. Broad immunity model that grants intermediaries broad or conditional immunity from liability for third party content and exempts them from any general requirement to monitor content. <b> </b></p>
<p style="text-align: justify; ">While the models described above can provide useful guidance for the drafting or the improvement of the current legislation, they are limited in their scope and application as they fail to account for the different roles and functions of intermediaries. Legislators and courts are facing increasing difficulties, in interpreting these regulations and adapting them to a new economic and technical landscape that involves unprecedented levels user generated content and new kinds of and online intermediaries.</p>
<p style="text-align: justify; ">The nature and role of intermediaries change considerably across jurisdictions, and in relation to the social, economic and technical contexts. In addition to the dynamic nature of intermediaries the different categories of Internet intermediaries‘ are frequently not clear-cut, with actors often playing more than one intermediation role. Several of these intermediaries offer a variety of products and services and may have number of roles, and conversely, several of these intermediaries perform the same function. For example , blogs, video services and social media platforms are considered to be 'hosts'. Search engine providers have been treated as 'hosts' and 'technical providers'.</p>
<p style="text-align: justify; ">This limitations of existing models in recognising that different types of intermediaries perform different functions or roles and therefore should have different liability, poses an interesting area for research and global deliberation. Establishing classification of intermediaries, will also help analyse existing patterns of influence in relation to content for example when the removal of content by upstream intermediaries results in undue over-blocking.</p>
<p style="text-align: justify; ">Distinguishing intermediaries on the basis of their roles and functions in the Internet ecosystem is critical to ensuring a balanced system of liability and addressing concerns for freedom of expression. Rather than the highly abstracted view of intermediaries as providing a single unified service of connecting third parties, the definition of intermediaries must expand to include the specific role and function they have in relation to users' rights. A successful intermediary liability regime must balance the needs of producers, consumers, affected parties and law enforcement, address the risk of abuses for political or commercial purposes, safeguard human rights and contribute to the evolution of uniform principles and safeguards.</p>
<p style="text-align: justify; "><b>Towards an evidence based intermediary liability policy framework</b></p>
<p style="text-align: justify; ">This workshop aims to bring together leading representatives from a broad spectrum of stakeholder groups to discuss liability related issues and ways to enhance Internet users’ trust.</p>
<p style="text-align: justify; ">Questions to address at the panel include:</p>
<p style="text-align: justify; ">1. What are the varying definitions of intermediaries across jurisdictions?</p>
<p style="text-align: justify; ">2. What are the specific roles and functions that allow for classification of intermediaries?</p>
<p style="text-align: justify; ">3. How can we ensure the legal framework keeps pace with technological advances and the changing roles of intermediaries?</p>
<p style="text-align: justify; ">4. What are the gaps in existing models in balancing innovation, economic growth and human rights?</p>
<p style="text-align: justify; ">5. What could be the respective role of law and industry self-regulation in enhancing trust?</p>
<p style="text-align: justify; ">6. How can we enhance multi-stakeholder cooperation in this space?</p>
<p style="text-align: justify; ">Confirmed Panel:</p>
<p style="text-align: justify; ">Technical Community: Malcolm Hutty: Internet Service Providers Association (ISPA)<br />Civil Society: Gabrielle Guillemin: Article19<br />Academic: Nicolo Zingales: Assistant Professor of Law at Tilburg University<br />Intergovernmental: Rebecca Mackinnon: Consent of the Networked, UNESCO project<br />Civil Society: Anriette Esterhuysen: Association for Progressive Communication (APC)<br />Civil Society: Francisco Vera: Advocacy Director: Derechos Digitale<br />Private Sector: Titi Akinsanmi: Policy and Government Relations Manager, Google Sub-Saharan Africa<br />Legal: Martin Husovec: MaxPlanck Institute</p>
<p style="text-align: justify; "><b> </b></p>
<p style="text-align: justify; "><span>Moderator(s): </span><span>Giancarlo Frosio, Centre for Internet and Society (CIS) and </span><span>Jeremy Malcolm, Electronic Frontier Foundation </span></p>
<p style="text-align: justify; "><span><span>Remote Moderator: </span><span>Anubha Sinha, New Delhi</span></span></p>
<p>
For more details visit <a href='http://editors.cis-india.org/internet-governance/blog/igf-workshop-an-evidence-based-intermediary-liability-policy-framework'>http://editors.cis-india.org/internet-governance/blog/igf-workshop-an-evidence-based-intermediary-liability-policy-framework</a>
</p>
No publisherjyotihuman rightsDigital Governanceinternet governanceFreedom of Speech and ExpressionInternet Governance ForumHuman Rights OnlineIntermediary LiabilityPoliciesMulti-stakeholder2014-07-04T06:41:10ZBlog EntryTravel Insurance Policy
http://editors.cis-india.org/about/policies/travel-insurance-policy
<b></b>
<p> </p>
<ol>
<li style="text-align: justify;">The Centre for Internet and Society will offer overseas travel insurance policies only for people of Indian origin or those having Residential visas/ permits, OCI, or PIO cards.<br /><br /></li>
<li style="text-align: justify;">The Centre for Internet and Society will provide overseas travel insurance from “Travel Companion”.<br /><br /></li>
<li style="text-align: justify;">“Travel Companion” will provide complete medical and health coverage to the Indian nationals traveling overseas.<br /><br /></li>
<li style="text-align: justify;">The Centre for Internet and Society will not provide travel insurance for domestic travel.</li></ol>
<p> </p>
<p>
For more details visit <a href='http://editors.cis-india.org/about/policies/travel-insurance-policy'>http://editors.cis-india.org/about/policies/travel-insurance-policy</a>
</p>
No publisherpraskrishnaPolicies2018-10-13T12:29:42ZPageTerms of Website Use
http://editors.cis-india.org/about/policies/website-use
<b></b>
<h2>Parties and Ownership</h2>
<ol>
<li style="text-align: justify; ">These Terms of Website Use (<b>"Terms"</b>) is made between the Centre for Internet & Society (<b>"CIS"</b>) and you.</li>
<li style="text-align: justify; ">In these Terms, all references to "<b>you</b>" or "<b>user</b>" shall mean the end-user accessing the Website, its contents and using the services offered through the Website. "<b>Service providers</b>" mean independent third party service providers. All references to "<b>we</b>", "<b>us</b>" and "<b>our</b>" shall mean CIS.</li>
<li style="text-align: justify; ">The domain name www.cis-india.org ("<b>Website</b>") is owned by CIS. CIS offers this web site, including all information, tools and services available from this site, to you, the user, conditioned upon your acceptance of all the terms, conditions, policies and notices stated here. Your use of this site indicates that you have read, acknowledged and agreed to these Terms.</li>
</ol>
<h2>Due Diligence</h2>
<ol>
<li style="text-align: justify; ">These Terms are published in compliance with Rule 3(1) of the Information Technology (Intermediaries Guidelines) Rules, 2011 notified by the Central Government in the Gazette of India Extraordinary vide Notification GSR 314(E) on 11 April 2011 ("<b>Intermediaries Rules</b>"). These Terms constitute an electronic record for the purposes of the Information Technology Act, 2000 ("<b>IT Act</b>").</li>
<li style="text-align: justify; ">You agree that you will <span style="text-decoration: underline;">not</span> host, display, upload, modify, publish, transmit, update or share any information that:<br />
<ul>
<li>belongs to another person and to which you do not have any right to;</li>
<li>is grossly harmful, harassing, blasphemous defamatory, obscene, pornographic, paedophilic, libellous, invasive of another's privacy, hateful, racially or ethnically objectionable, disparaging, relating or encouraging money laundering or gambling, or otherwise unlawful in any manner whatever;</li>
<li>harms minors in any way;</li>
<li>infringes any patent, trademark, copyright or other proprietary rights;</li>
<li>violates any law for the time being in force;</li>
<li>deceives or misleads the addressee about the origin of such messages or communicates any information which is grossly offensive or menacing in nature;</li>
<li>impersonates another person;</li>
<li>contains software viruses or any other computer code, files or programs designed to interrupt, destroy or limit the functionality of any computer resource; or,</li>
<li>threatens the unity, integrity, defence, security or sovereignty of India, friendly relations with foreign states, or public order or causes incitement to the commission of any cognisable offence or prevents investigation of any offence or is insulting to any other nation.</li>
</ul>
</li>
<li style="text-align: justify; ">You agree that in the event of any non-compliance with these Terms, we have the right to immediately terminate your access or usage rights to this Website and our services and/or remove any information that is, or is deemed by us to be, non-compliant.</li>
</ol>
<h2>Use of this Website</h2>
<ol>
<li style="text-align: justify; ">Unauthorised use of this Website, any information contained therein and unauthorised entry into our systems is strictly prohibited. You may not use contact information provided on this Website for unauthorized purposes, including marketing. You may not use any hardware or software intended to damage or interfere with the proper working of this Website or to surreptitiously intercept any system, data or personal information from this Website. You agree not to interrupt or attempt to interrupt the operation of this Website in any way.</li>
<li style="text-align: justify; ">We reserve the right, in our sole discretion, to limit or terminate your access to or use of this Website at any time without notice. Termination of your access or use will not waive or affect any other right or relief to which we may be entitled at law or in equity.</li>
<li style="text-align: justify; ">You represent and warrant that you own or otherwise control all the rights to the content you supply; that the content is accurate; that use of the content you supply does not violate any provision herein and will not cause injury to any person or entity; and that you will indemnify us for all claims resulting from content you supply.</li>
<li style="text-align: justify; ">You shall comply, and cause compliance, with all applicable provisions of any law, statute, ordinance, order, rule, regulation, bye-law, notification, custom, circular, press note, policy or other usage or mandatory requirement having, in the territory of India, the force of law.</li>
</ol>
<h2>Information on this Website</h2>
<ol>
<li style="text-align: justify; ">We are not responsible if information made available on this Website is not accurate, complete or current. The material on this Website is provided for general information only and should not be relied upon or used as the sole basis for making decisions without consulting primary, more accurate, more complete or timelier sources of information. Any reliance on the material on this Website is at your own risk. This Website may contain information that has typographical errors or inaccuracies. This Website may contain certain historical information. Historical information is provided for your reference only. We reserve the right to modify the contents of this Website at any time, but we have no obligation to update any information on this Website. You agree that it is your responsibility to monitor changes to this Website. Your use of this Website constitutes agreement to all such changes. We may discontinue or change any product or service described or offered on this Website at any time.</li>
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<h2>Trademarks, Copyright and Other Proprietary Rights</h2>
<ol>
<li style="text-align: justify; ">You or third parties acting on your behalf are not allowed to frame this site or use our proprietary marks as meta tags, without our written consent. These marks include, but are not limited to:<br />
<table class="invisible">
<tbody>
<tr>
<th><img src="http://editors.cis-india.org/home-images/copy2_of_logo.jpg/@@images/6aeb5910-e761-415d-9df0-efe1d60a3c94.jpeg" alt="CIS Logo" class="image-inline" title="CIS Logo" /></th>
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</table>
You may not use frames or utilize framing techniques or technology to enclose any content included on the site without our express written consent. Further, you may not utilize any site content in any meta tags or any other "hidden text" techniques or technologies without our express written consent.</li>
<li style="text-align: justify; ">Trademarks, logos and service marks displayed on this site are registered and unregistered trademarks of ours and our partners, sponsors, content providers, or other third parties. All of these trademarks, logos and service marks are the property of their respective owners. Nothing on this site shall be construed as granting, by implication, estoppel, or otherwise, any license or right to use any trademark, logo or service mark displayed on the site without the owner's prior written permission, except as otherwise described herein. We reserve all rights not expressly granted in and to the site and its content.</li>
</ol>
<h2>Disclaimer of Warranties</h2>
<ol>
<li style="text-align: justify; ">Your use of this Website is at your sole risk. This Website is provided on an "as is" basis. We reserve the right to restrict or terminate your access to this Website or any feature or part thereof at any time. We expressly disclaim all warranties of any kind, whether express or implied, including but not limited to the implied warranties of merchantability and fitness for a particular purpose and any warranties that materials on this Website are non-infringing, as well as warranties implied from a course of performance or course of dealing; that access to this Website will be uninterrupted or error-free; that this Website will be secure; that the site or the server that makes this Website available will be virus-free; or that information on this Website will be complete, accurate or timely. If you download any materials from this Website, you do so at your own discretion and risk. You will be solely responsible for any damage to your computer system or loss of data that results from the download of any such materials. No advice or information, whether oral or written, obtained by you from us shall create any warranty of any kind. We do not make any warranties or representations regarding the use of the materials on this Website in terms of their completeness, correctness, accuracy, adequacy, usefulness, timeliness, reliability or otherwise.</li>
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<h2>Limitation of Liability</h2>
<ol>
<li style="text-align: justify; ">You acknowledge and agree that you assume full responsibility for your use of this Website. You acknowledge and agree that any information you send or receive during your use of this Website may not be secure and may be intercepted by unauthorized parties. You acknowledge and agree that your use of this Website is at your own risk. Recognizing such, you acknowledge and agree that, to the fullest extent permitted by applicable law, neither we, our partners, sponsors or content providers will be liable for any direct, indirect, punitive, exemplary, incidental, special, consequential or other damages arising out of or in any way related to this Website, or any other site you access through a link from this Website or from any actions we take or fail to take as a result of communications you send to us, or the delay or inability to use this Website, or for any information, products or services advertised in or obtained through this Website, removal or deletion of any materials submitted or posted on this Website, or otherwise arising out of the use of this Website, whether based on contract, tort, strict liability or otherwise, even if we, our affiliates or any of our suppliers have been advised of the possibility of damages.</li>
<li style="text-align: justify; ">This disclaimer applies, without limitation, to any damages or injury arising from any failure of performance, error, omission, interruption, deletion, defects, delay in operation or transmission, computer viruses, file corruption, communication-line failure, network or system outage, your loss of profits, or theft, destruction, unauthorized access to, alteration of, loss or use of any record or data, and any other tangible or intangible loss. You specifically acknowledge and agree that neither we nor our suppliers shall be liable for any defamatory, offensive or illegal conduct of any user of this Website. Your sole and exclusive remedy for any of the above claims or any dispute with us is to discontinue your use of this Website. Subject to the terms of the Limitation Act, 1963, you agree that any cause of action arising out of or related to the site must commence within one (1) year after the cause of action accrues otherwise the cause of action is permanently barred.</li>
</ol>
<h2>Indemnification</h2>
<ol>
<li style="text-align: justify; ">You agree to indemnify us, defend us and hold us harmless, including our affiliates and our officers, members, directors, employees, consultants, contractors, agents, licensors, service providers, subcontractors and suppliers from and against any and all losses, liabilities, expenses, damages and costs, including reasonable attorneys' fees and court costs, arising or resulting from your use of this Website and any violation of these Terms. If you cause a technical disruption to this Website or the systems transmitting this Website to you or others, you agree to be responsible for any and all losses, liabilities, expenses, damages and costs, including reasonable attorneys' fees and court costs, arising or resulting from that disruption. We reserve the right to assume exclusive defence and control of any matter otherwise subject to indemnification by you and, in such an event, you agree to cooperate with us in the defence of such matter.</li>
</ol>
<h2>Governing Law, Jurisdiction and Definitive Agreement</h2>
<ol>
<li style="text-align: justify; ">This Website is controlled, operated and administered within India. We do not make any representation that materials on this Website are appropriate or available for use at other locations outside India and access to them from territories where their contents are illegal is prohibited. You may not use this Website in violation of Indian laws. If you access this Website from locations outside India, you are responsible for compliance with all local laws. These Terms shall be governed by the laws of India, without giving effect to its conflict of laws provisions. You agree that the courts at Bangalore shall have exclusive jurisdiction to settle any dispute or claim that arises out of or in connection with your use of this Website and these Terms.</li>
<li style="text-align: justify; ">These Terms constitute the entire and definitive agreement between you and us with respect to your use of this Website. If for any reason a court of competent jurisdiction finds any provision of these Terms, or portion thereof, to be unenforceable, that provision shall be enforced to the maximum extent permissible so as to give effect to the intent of these Terms, and the remainder of these Terms shall continue in full force and effect.</li>
</ol><ol> </ol>
<div id="_mcePaste"></div>
<p>
For more details visit <a href='http://editors.cis-india.org/about/policies/website-use'>http://editors.cis-india.org/about/policies/website-use</a>
</p>
No publisherpraskrishnaPoliciesInternet Governance2013-07-01T07:16:15ZPagePrivacy Policy
http://editors.cis-india.org/about/policies/privacy-policy
<b></b>
<h2>Preliminary</h2>
<ol>
<li style="text-align: justify; ">This Privacy Policy ("Policy") states the internal policy of the Centre for Internet & Society ("CIS") with regard to the collection, storage, security, processing and disclosure of personal data.</li>
<li style="text-align: justify; ">This Policy constitutes compliance with the Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011 that were notified by the Central Government in the Gazette of India vide Notification GSR 313(E) on 11 April 2011.</li>
</ol>
<h2>Collection of Personal Data</h2>
<ol>
<li style="text-align: justify; ">CIS will not collect any personal data that is not necessary for the achievement of a purpose that is connected to a stated CIS function.</li>
<li style="text-align: justify; ">CIS will not collect any personal data without obtaining the prior consent of the person to whom it pertains. CIS may obtain such consent in any manner, and through any medium, but will not employ threats, duress or coercion to obtain such consent.</li>
<li style="text-align: justify; ">Personal data collected in respect of a grant of consent by the person to whom it pertains will, if that consent is subsequently withdrawn for any reason, be destroyed or anonymised.</li>
</ol>
<h2>Storage of Personal Data</h2>
<ol>
<li style="text-align: justify; ">CIS will not store any personal data for a period longer than is necessary to achieve the purpose for which it was collected, or, if that purpose is achieved or ceases to exist for any reason, for any period following such achievement or cessation.</li>
<li style="text-align: justify; ">Any personal data collected in relation to the achievement of a purpose will, if that purpose is achieved or ceases to exist for any reason, be destroyed or anonymised.</li>
<li style="text-align: justify; ">CIS may store personal data for a period longer than is necessary to achieve the purpose for which it was collected, or, if that purpose has been achieved or ceases to exist for any reason, for any period following such achievement or cessation, if – <br />
<ul>
<li>the person to whom it pertains grants consent to such storage;</li>
<li>it is required to be stored under the provisions of applicable law; or</li>
<li>it is the subject of a pending legal proceeding.</li>
</ul>
</li>
</ol>
<h2>Processing of Personal Data</h2>
<ol>
<li style="text-align: justify; ">
<p>CIS will not process any personal data that is not necessary for the achievement of the purpose for which it was collected unless the person to whom it pertains grants consent to such processing.</p>
</li>
</ol>
<h2>Security of Personal Data</h2>
<ol>
<li style="text-align: justify; ">
<p>CIS will not collect, store or process any personal data in the absence of measures, including, but not restricted to, technological, physical and administrative measures, adequate to secure the confidentiality, secrecy, sanctity and safety of the personal data, including from theft, loss, damage or destruction.</p>
</li>
<li style="text-align: justify; ">
<p>Any person who collects, stores or processes any personal data on behalf of CIS will be subject to a duty of confidentiality and secrecy in respect of it.</p>
</li>
<li style="text-align: justify; ">
<p>CIS will, if the confidentiality, secrecy, sanctity or safety of any personal data collected, stored or processed by CIS is violated by theft, loss, damage or destruction, or as a result of any disclosure contrary to the provisions of this Policy, notify, to the extent possible, the person to whom the personal data pertains.</p>
</li>
</ol>
<h2>Disclosure of Personal Data</h2>
<ol>
<li style="text-align: justify; ">
<p>CIS will not disclose to any person to whom any personal data does not pertain, or otherwise cause any such a person to receive, the content or nature of that personal data, including any other details in respect thereof, unless the person to whom it pertains grants consent to such disclosure. CIS may obtain such consent in any manner, and through any medium, but will not employ threats, duress or coercion to obtain such consent.</p>
</li>
<li style="text-align: justify; ">
<p>CIS may disclose personal data with a person to whom it does not pertain, whether located in India or otherwise, for the purpose only of processing it to achieve the purpose for which it was collected, if such a disclosure is pursuant to an agreement that binds the person receiving it to same or stronger measures in respect of its storage, processing and disclosure as are contained in this Policy.</p>
</li>
<li style="text-align: justify; ">
<p>If the disclosure of any personal data is necessary to –</p>
<ul>
<li>prevent a reasonable threat to national security, defence or public order; or</li>
<li>prevent, investigate or prosecute a cognisable offence;</li>
</ul>
CIS may, upon receiving an order in writing from a judicial authority or law enforcement officer, disclose the personal data that is the subject of the order without seeking the consent of the person to whom it pertains.</li>
<li style="text-align: justify; ">CIS may, to the extent possible, notify the person to whom any personal data pertains of its disclosure and the identity of the person it was disclosed to, and any other details in respect thereof.</li>
</ol>
<h2>Accuracy of Personal Data</h2>
<ol>
<li style="text-align: justify; ">CIS will reasonably afford any person whose personal data is collected, stored or processed by CIS the opportunity to review it and, where necessary, rectify anything that is inaccurate or not up to date.</li>
</ol><ol> </ol>
<p>
For more details visit <a href='http://editors.cis-india.org/about/policies/privacy-policy'>http://editors.cis-india.org/about/policies/privacy-policy</a>
</p>
No publisherpraskrishnaPoliciesInternet GovernancePrivacy2013-07-01T06:25:37ZPageNon-Discrimination and Equal Opportunities Policy
http://editors.cis-india.org/about/policies/non-discrimination-equal-opportunities-policy
<b></b>
<h2>Preliminary</h2>
<ol>
<li style="text-align: justify;">This Non-Discrimination and Equal Opportunities Policy ("Policy") states the internal policy of the Centre for Internet & Society ("CIS") with regard to non-discrimination at the workplace and equal opportunities during recruitment.</li>
<li style="text-align: justify;">This Policy is internal to CIS and is meant to provide a safe, diverse and comfortable workplace at CIS. This Policy is not legally mandated and, therefore, is not judicially enforceable in India. This Policy is without prejudice to any anti-discrimination provisions of applicable law including, but not restricted to, the provisions of:<br />
<ul>
<li>Article 17 of the Constitution of India;</li>
<li>the Protection of Civil Rights Act, 1955,</li>
<li>the Scheduled Castes and Scheduled Tribes (Prevention of Atrocities) Act, 1989;</li>
<li>the Sexual Harassment of Women at the Workplace (Prevention, Prohibition and Redressal) Act, 2013;</li>
<li>Sections 354 and 509 of the Indian Penal Code, 1860; and,</li>
<li>the Persons with Disabilities (Equal Opportunities, Protection of Rights and Full Participation) Act, 1995.</li></ul>
</li></ol>
<h2>Non-discrimination</h2>
<ol>
<li style="text-align: justify;">CIS will not adversely discriminate, and prohibits other adverse discrimination at the workplace, on the basis of religion, race, caste, sex, place of birth, descent, sexual orientation, gender identity, disability, age or any of them (<strong>"Discrimination Characteristics"</strong>). CIS will not condone any adverse discrimination against any person on its premises, whether that person is in its employment or otherwise.</li>
<li style="text-align: justify;">Any person who believes himself or herself to have been subjected to adverse discrimination on the basis of the Discrimination Characteristics is encouraged to bring the matter to the attention of the Diversity Committee of CIS at the earliest practical opportunity. No person will be punished, retaliated against, or limited in employment or other opportunity for exercising anything set out in this Policy, or for filing a complaint, furnishing information for, or participating in an investigation, or any other activity related to the administration of this Policy.</li>
<li style="text-align: justify;">Any adverse discrimination or other action or behaviour that constitutes a violation of law will be reported to the police.</li></ol>
<h2>Equal Opportunities</h2>
<ol>
<li style="text-align: justify;">CIS provides equal opportunities to its employment, consultancy or otherwise without regard for the Discrimination Characteristics. All actions of CIS with regard to its employees, consultants, advisors, interns and staff, including but not limited to those relating to compensation, benefits, transfers, leave, layoffs, training, education, and assistance, will be made without regard for the Discrimination Characteristics.</li>
<li style="text-align: justify;">Notwithstanding anything contained in the previous paragraph, if CIS reasonably believes that its employment, workplace or premises do not adequately represent the balance of diversity of persons who share one or more of the Discrimination Characteristics, it may, with the aim only of redressing that imbalance, take positive discriminatory action in respect of persons who share that aspect, or those aspects, of the Discrimination Characteristics that are sought to be adequately represented.</li>
<li style="text-align: justify;">Any person who believes himself or herself to have been subjected to adverse discrimination, or impermissible positive discrimination, on the basis of the Discrimination Characteristics is encouraged to bring the matter to the attention of the Diversity Committee of CIS at the earliest practical opportunity.</li></ol>
<h2>Diversity Committee</h2>
<p>The Interim Diversity Committee of CIS is comprised of:</p>
<ol>
<li>Pallavi Bedi<br /></li>
<li>Torsha Sarkar</li><li>Gurshabad Grover<br /></li></ol>
<p> </p>
<p>
For more details visit <a href='http://editors.cis-india.org/about/policies/non-discrimination-equal-opportunities-policy'>http://editors.cis-india.org/about/policies/non-discrimination-equal-opportunities-policy</a>
</p>
No publisherpraskrishnaPoliciesInternet Governance2020-07-29T06:59:09ZPageEthical Research Guidelines
http://editors.cis-india.org/about/policies/ethical-research-guidelines
<b>The Centre for Internet and Society will endeavour to protect the physical, social and psychological well-being of those who participate in their research. The guidelines below state the necessary steps to follow while doing research.</b>
<p> </p>
<p>The ethical research guideline requires CIS staff and consultants to consider and take the following steps while engaging in research.</p>
<ol>
<li style="text-align: justify;">Providing notice to the individual of the: Aims, methods, his/her right to abstain from participation in the research and his/her right to terminate at any time his/her participation; the confidential nature of his/her replies and any limits on such confidentiality.<br /><br /></li>
<li style="text-align: justify;">Providing informants and other participants the right to remain anonymous.<br /><br /></li>
<li style="text-align: justify;">Taking informed consent from the individual that he/she agrees to participate. If children are involved in the research, informed consent will be taken from the parents. Informed consent will entail communicating :<br />
<ul>
<li>Purpose(s) of the study, and the anticipated consequences of the research;</li>
<li>Identity of funders and sponsors</li>
<li>Anticipated uses of the data</li>
<li>The degree of anonymity and confidentiality which may be afforded to informants and subjects.<br /><br /></li></ul>
</li>
<li style="text-align: justify;">Ensuring that when audio/visual-recorders and photographic records are being used, participants that are being recorded will be made aware of the use of the devices, and have the option to request that they not be used.<br /><br /></li>
<li>Ensuring that the identity and identifying information of the participant (if not already in the public domain) is destroyed at the end of project, unless the individual has consented to otherwise.<br /><br /></li>
<li>At public events organized by CIS, it will be announced and publicly posted that the event is being recorded. Individuals will be given the choice object to being recorded or their name and organization shared in conference reports, blogs, articles etc. If the individual does not object, it will be considered that they have given their consent.<br /><br /></li>
<li>The Centre for Internet and Society strictly follows a policy of <strong>No Plagiarism</strong>.</li></ol>
<p>
For more details visit <a href='http://editors.cis-india.org/about/policies/ethical-research-guidelines'>http://editors.cis-india.org/about/policies/ethical-research-guidelines</a>
</p>
No publisherpraskrishnaResearchPoliciesInternet GovernancePrivacy2018-10-13T12:21:48ZPage