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The Government’s Increased Focus on Regulating Non-Personal Data: A Look at the Draft National Data Governance Framework Policy
http://editors.cis-india.org/internet-governance/blog/national-data-governance-framework-policy
<b>Digvijay Chaudhary and Anamika Kundu wrote an article on the National Data Governance Framework Policy. It was edited by Shweta Mohandas.</b>
<h2>Introduction</h2>
<p style="text-align: justify; ">Non Personal Data (‘NPD’) can be <a href="https://www.taylorfrancis.com/chapters/edit/10.4324/9780429022241-8/regulating-non-personal-data-age-big-data-bart-van-der-sloot">understood</a> as any information not relating to an identified or identifiable natural person. The origin of such data can be both human and non-human. Human NPD would be such data which has been anonymised in such a way that the person to whom the data relates cannot be re-identified. Non-human NPD would mean any such data that did not relate to a human being in the first place, for example, weather data. There has been a gradual demonstrated interest in NPD by the government in recent times. This new focus on regulating non personal data can be owed to the economic incentive it provides. In its report, the Sri Krishna committee, released in 2018 agreed that NPD holds considerable strategic or economic interest for the nation, however, it left the questions surrounding NPD to a future committee.</p>
<h2 style="text-align: justify; ">History of NPD Regulation</h2>
<p dir="ltr" style="text-align: justify; ">In 2020, the Ministry of Electronics and Information Technology (‘MEITY’) constituted an expert committee (‘NPD Committee’) to study various issues relating to NPD and to make suggestions on the regulation of non-personal data. The NPD Committee differentiated NPD into human and non-human NPD, based on the data’s origin. Human NPD would include all information that has been stripped of any personally identifiable information and non-human NPD meant any information that did not contain any personally identifiable information in the first place (eg. weather data). The final report of the NPD Committee is awaited but the Committee came out with a <a href="https://static.mygov.in/rest/s3fs-public/mygov_160922880751553221.pdf">revised draft</a> of its recommendations in December 2020. In its December 2020 report, the NPD Committee proposed the creation of a National Data Protection Authority (‘NPDA’) as it felt this is a new and emerging area of regulation. Thereafter, the Joint Parliamentary Committee on the Personal Data Protection Bill, 2019 (‘JPC’) came out with its <a href="http://164.100.47.193/lsscommittee/Joint%20Committee%20on%20the%20Personal%20Data%20Protection%20Bill,%202019/17_Joint_Committee_on_the_Personal_Data_Protection_Bill_2019_1.pdf">version of the Data Protection Bill </a>where it amended the short title of the PDP Bill 2019 to Data Protection Bill, 2021 widening the ambit of the Bill to include all types of data. The JPC report focuses only on human NPD, noting that non-personal data is essentially derived from one of the three sets of data - personal data, sensitive personal data, critical personal data - which is either anonymized or is in some way converted into non-re-identifiable data.</p>
<p dir="ltr" style="text-align: justify; ">On February 21, 2022, the Ministry of Electronics and Information Technology (‘MEITY’) came out with the <a href="https://www.meity.gov.in/content/draft-india-data-accessibility-use-policy-2022">Draft India Data Accessibility and Use Policy, 2022</a> (‘Draft Policy’). The Draft Policy was strongly criticised mainly due to its aims to monetise data through its sale and licensing to body corporates. The Draft Policy had stated that anonymised and non-personal data collected by the State that has “<a href="https://www.medianama.com/2022/06/223-new-data-governance-policy-privacy/">undergone value addition</a>” could be sold for an “appropriate price”. During the Draft Policy’s consultation process, it had been withdrawn several times and then finally removed from the website.<a href="https://www.meity.gov.in/writereaddata/files/Draft%20India%20Data%20Accessibility%20and%20Use%20Policy_0.pdf"> The National Data Governance Framework Policy</a> (‘NDGF Policy’) is a successor to this Draft Policy. There is a change in the language put forth in the NDGF Policy from the Draft Policy, where the latter mainly focused on monetary growth. The new NDGF Policy aims to regulate anonymised non-personal data (‘NPD’) kept with governmental authorities and make it accessible for research and improving governance. It wishes to create an ‘India Datasets programme’ which will consist of the aforementioned datasets. While MEITY has opened the draft for public comments, is a need to spell out the procedure in some ways for stakeholders to draft recommendations for the NDGF policies in an informed manner. Through this piece, we discuss the NDGF Policy in terms of issues related to the absence of a comprehensive Data Protection Framework in India and the jurisdictional overlap of authorities under the NDGF Policy and DPB.</p>
<h2 dir="ltr" style="text-align: justify; ">What the National Data Governance Framework Policy Says</h2>
<p dir="ltr" style="text-align: justify; ">Presently in India, NPD is stored in a variety of governmental departments and bodies. It is difficult to access and use this stored data for governmental functions without modernising collection and management of governmental data. Through the NDGF Policy, the government aims to build an Indian data storehouse of anonymised non-personal datasets and make it accessible for both improving governance and encouraging research. It imagines the establishment of an Indian Data Office (‘IDO’) set up by MEITY , which shall be responsible for consolidating data access and sharing of non-personal data across the government. In addition, it also mandates a Data Management Unit for every Ministry/department that would work closely with the IDO. IDO will also be responsible for issuing protocols for sharing NPD. The policy further imagines an Indian Data Council (‘IDC’) whose function would be to define frameworks for important datasets, finalise data standards, and Metadata standards and also review the implementation of the policy. The NDGF Policy has provided a broad structure concerning the setting up of anonymisation standards, data retention policies, data quality, and data sharing toolkit. The NDGF Policy states that these standards shall be developed and notified by the IDO or MEITY or the Ministry in question and need to be adhered to by all entities.</p>
<h2 dir="ltr" style="text-align: justify; ">The Data Protection Framework in India</h2>
<p dir="ltr" style="text-align: justify; ">The report adopted by the JPC, felt that it is simpler to enact a single law and a single regulator to oversee all the data that originates from any data principal and is in the custody of any data fiduciary. According to the JPC, the draft Bill deals with various kinds of data at various levels of security. The JPC also recommended that since the Data Protection Bill (‘DPB’) will handle both personal and non-personal data, any further policy / legal framework on non-personal data may be made a part of the same enactment instead of any separate legislation. The draft DPB states that what is to be done with the NDP shall be decided by the government from time to time according to its policy. As such, neither the DPB, 2021 nor the NDGF Policy go into details of regulating NPD but only provide a broad structure of facilitating free-flow of NPD, without taking into account the <a href="https://cis-india.org/internet-governance/cis-comments-revised-npd-report/view">specific concerns</a> that have been raised since the NPD committee came out with its draft report on regulating NPD dated December 2020.</p>
<h2 dir="ltr" style="text-align: justify; ">Jurisdictional overlaps among authorities and other concerns</h2>
<p dir="ltr" style="text-align: justify; ">Under the NDGF policy, all guidelines and rules shall be published by a body known as the Indian Data Management Office (‘IDMO’). The IDMO is set to function under the MEITY and work with the Central government, state governments and other stakeholders to set standards. Currently, there is no sign of when the DPB will be passed as law. According to the JPC, the reason for including NPD within the DPB was because of the impossibility to differentiate between PD and NPD. There are also certain overlaps between the DPB and the NDGF which are not discussed by the NDGF. NDGF does not discuss the overlap between the IDMO and Data Protection Authority (‘DPA’) established under the DPB 2021.</p>
<p dir="ltr" style="text-align: justify; ">Under the DPB, the DPA is tasked with specifying codes of practice under clause 49. On the other hand, the NDGF has imagined the setting up of IDO, IDMO, and the IDC, which shall be responsible for issuing codes of practice such as data retention, and data anonymisation, and data quality standards. As such, there appears to be some overlap in the functions of the to-be-constituted DPA and the NDGF Policy.</p>
<p dir="ltr" style="text-align: justify; ">Furthermore, while the NDGF Policy aims to promote openness with respect to government data, there is a conflict with <a href="https://opengovdata.org/">open government data (‘OGD’) principle</a>s when there is a price attached to such data. OGD is data which is collected and processed by the government for free use, reuse and distribution. Any database created by the government must be publicly accessible to ensure compliance with the OGD principles.</p>
<h2 dir="ltr" style="text-align: justify; ">Conclusion</h2>
<p dir="ltr" style="text-align: justify; ">Streamlining datasets across different authorities is a huge challenge for the government and hence the NGDF policy in its current draft requires a lot of clarification. The government can take inspiration from the European Union which in 2018, came out with a principles-based approach coupled with self-regulation on the framework of the free flow of non-personal data. The <a href="https://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:52019DC0250&from=EN">guidance</a> on the free-flow of non-personal data defines non-personal data based on the origin of data - data which originally did not relate to any personal data (non-human NPD) and data which originated from personal data but was subsequently anonymised (human NPD). The <a href="https://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:52019DC0250&from=EN">regulation</a> further realises the reality of mixed data sets and regulates only the non-personal part of such datasets and where the datasets are inextricably linked, the GDPR would apply to such datasets. Moreover, any policy that seeks to govern the free flow of NPD ought to make it clear that in case of re-identification of anonymised data, such re-identified data would be considered personal data. The DPB, 2021 and the NGDF, both fail to take into account this difference.</p>
<p>
For more details visit <a href='http://editors.cis-india.org/internet-governance/blog/national-data-governance-framework-policy'>http://editors.cis-india.org/internet-governance/blog/national-data-governance-framework-policy</a>
</p>
No publisherDigvijay Chaudhary and Anamika KunduOpen DataOpen Government DataInternet GovernancePrivacy2022-06-30T13:24:35ZBlog EntryComments on the Statistical Disclosure Control Report
http://editors.cis-india.org/internet-governance/comments-on-the-statistical-disclosure-control-report
<b>This submission presents comments by the Centre for Internet and Society, India (“CIS”) on the Statistical Disclosure Control Report published on March 30th by Ministry of Statistics and Programme Implementation.
</b>
<p><strong id="docs-internal-guid-a12fe2b3-c746-4c1a-0287-1814414668af"><br /></strong></p>
<h3 style="text-align: justify;" dir="ltr">1. PRELIMINARY</h3>
<p style="text-align: justify;" dir="ltr">This submission presents comments by the Centre for Internet and Society, India (“CIS”) on the Statistical Disclosure Control Report published on March 30th by Ministry of Statistics and Programme Implementation.</p>
<p style="text-align: justify;" dir="ltr">CIS is thankful for the opportunity to put forth its views.<br class="kix-line-break" />This submission is divided into three main parts. The first part, ‘Preliminary’, introduces the document; the second part, ‘About CIS’, is an overview of the organization; and, the third part contains the ‘Comments’.<br class="kix-line-break" /><br class="kix-line-break" /></p>
<h3 style="text-align: justify;" dir="ltr">2. ABOUT CIS</h3>
<p style="text-align: justify;" dir="ltr">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, freedom of speech and expression, intermediary liability, digital privacy, and cybersecurity.<br class="kix-line-break" /><br /></p>
<p style="text-align: justify;" dir="ltr">CIS values the fundamental principles of justice, equality, freedom and economic development. This submission is consistent with CIS' commitment to these values, the safeguarding of general public interest and the protection of India's national interest at the international level. Accordingly, the comments in this submission aim to further these principles.</p>
<h3 style="text-align: justify;" dir="ltr">3. Comments</h3>
<h4 style="text-align: justify;" dir="ltr">3.1 General Comments</h4>
<p style="text-align: justify;" dir="ltr">As a non-profit organisation we recognize the importance of the efforts by the Ministry of Statistics and Programme Implementation (MoSPI) to make the data you collect available to the public in open formats with relevant information about reliability of statistical estimates.</p>
<p><span style="text-align: justify;">We at CIS have recently released a report titled “Information Security Practices of Aadhaar (or lack thereof): A documentation of public availability of Aadhaar Numbers with sensitive personal financial information”. We encountered several central and state government departments collecting socioeconomic data from citizens, linking it with Aadhaar and even publishing them in exportable data formats like EXCEL and MS ACCESS Databases. </span><span style="text-align: justify;">While we understand this issue primarily concerns to Unique Identification Authority of India (UIDAI), the lack of standards around information/statistical disclosure are a general threat to transparency in a democracy and privacy of individuals. </span><span style="text-align: justify;">Going through the report we understand the committee is unable to prescribe a standard for other ministries and departments until they try and pilot these standards within Ministry of Statistics and Programme Implementation. This delay in prescribing the standards can be really dangerous in the current circumstances of massive data collection by government departments and linking all the databases with a unique identifier, Aadhaar Number. </span><span style="text-align: justify;">At the same time we understand the importance of data dissemination to be carried out and we recommend the following for improving the standards around data disclosure control.</span></p>
<h4 style="text-align: justify;" dir="ltr">3.2 Integrity of Information and Data</h4>
<p style="text-align: justify;" dir="ltr">We agree with the committee that the error rates need to be kept in mind while designing practices to convert raw data. But we request the process of changes being made be actively measured and documented. In case of errors being computed, guidelines can be made to decrease the possibilities of misinterpretation of errors causing loss of integrity of information. Statistics are important for decision making in governance, errors in computations can be biased towards millions of people. Statistical biases are important to be looked into while converting data from its raw format to make sure there are no damage caused by information.</p>
<h4 style="text-align: justify;" dir="ltr">3.3 Data Security</h4>
<p style="text-align: justify;" dir="ltr">One of the important issues around storage and publication of Aadhaar information is the lack of masking standards. With the availability of data from multiple departments, it is possible to reconstruct identification details by linking data from multiple databases. It is recommended to bring masking standards while personally identifiable micro data is being published. There is an urgent need for departments to also look at auditing access to information and tracking sharing of information. It is recommended the department digitally signs all the information and documents being published or shared by them to keep track of who had accessed the information and verifying the authenticity of information.</p>
<p style="text-align: justify;" dir="ltr">We request the department to define what exactly is “usage for statistical purposes only” and recommend standards to control and restrict usage of information for this purpose. It is important they design frameworks or mechanisms to allow others to report violations around this. This process should be transparent and documented heavily.</p>
<h4 style="text-align: justify;" dir="ltr">3.4 Anonymization of microdata</h4>
<p style="text-align: justify;" dir="ltr">We recommend the data being collected be anonymized at source to evade the possibility of the accidental disclosure of personally identifiable information. While the current anonymization efforts have been helpful, with steady increase in data mining and classification algorithms and practices it is recommended to evolve the standards around this area.</p>
<h4 style="text-align: justify;" dir="ltr">3.5 Data Dissemination</h4>
<p style="text-align: justify;" dir="ltr">Data dissemination is an important aspect for district statistics officers, we recommend they actively communicate their work through monthly newsletters, quarterly workshops to help improve the conversations around statistics and at the same time engage with the users who would benefit from the data.</p>
<p style="text-align: justify;" dir="ltr">We also recommend that data when being published includes metadata of collection, modification, storage and other important information. Also the information needs to be published in open formats which does not require proprietary software to be used to open them. At the same time data should be published in multiple formats like CSV, XLS, PDF,</p>
<p style="text-align: justify;" dir="ltr">The committee also recognizes the need for having data users part of discussions around important decisions and be part of committees. We would like the department to recognize our efforts and consider us for future committee representations.</p>
<p style="text-align: justify;" dir="ltr"> </p>
<p style="text-align: justify;" dir="ltr">Thank you for this opportunity and we look forward to work with you in future.</p>
<p>
For more details visit <a href='http://editors.cis-india.org/internet-governance/comments-on-the-statistical-disclosure-control-report'>http://editors.cis-india.org/internet-governance/comments-on-the-statistical-disclosure-control-report</a>
</p>
No publisherSrinivs Kodali and Amber SinhaCall for CommentsDigital AccessOpen DataOpen Government DataData ProtectionData GovernanceAadhaarDigitisationInformation SecurityOpennessInternet GovernanceData Management2019-03-13T00:28:44ZBlog EntryMeeting on Proactive Disclosure and Personal Data (Delhi, May 13, 5:30 pm)
http://editors.cis-india.org/internet-governance/events/meeting-on-proactive-disclosure-and-personal-data-delhi-may-13
<b>CIS is organising an informal discussion on topics related to proactive disclosure and personal data thrown up by the recently published report by Amber Sinha and Srinivas Kodali titled "Information Security Practices of Aadhaar (or lack thereof)". Please join us at 5:30 pm today, May 13, at the CIS office.</b>
<p> </p>
<h4>Read the report: <a href="http://cis-india.org/internet-governance/information-security-practices-of-aadhaar-or-lack-thereof-a-documentation-of-public-availability-of-aadhaar-numbers-with-sensitive-personal-financial-information-1">PDF</a></h4>
<p> </p>
<h3><strong>Location</strong></h3>
<iframe src="https://www.google.com/maps/embed?pb=!1m18!1m12!1m3!1d876.157470894426!2d77.20553462919722!3d28.550842498903158!2m3!1f0!2f0!3f0!3m2!1i1024!2i768!4f13.1!3m3!1m2!1s0x0%3A0x834072df81ffcb39!2sCentre+for+Internet+and+Society!5e0!3m2!1sen!2sin!4v1493818109951" frameborder="0" height="450" width="600"></iframe>
<p> </p>
<p>
For more details visit <a href='http://editors.cis-india.org/internet-governance/events/meeting-on-proactive-disclosure-and-personal-data-delhi-may-13'>http://editors.cis-india.org/internet-governance/events/meeting-on-proactive-disclosure-and-personal-data-delhi-may-13</a>
</p>
No publishersumandroPrivacyOpen DataOpen Government DataInternet GovernancePublic Accountability2017-05-13T04:32:41ZEventInternational Open Data Charter, Consultation Meeting, Delhi, July 09, 5:30 pm
http://editors.cis-india.org/openness/international-open-data-charter-consultation-delhi-09072015
<b></b>
<p> </p>
<p>This is to invite you to a consultation meeting on the first public draft of the International Open Data Charter, at the CIS office in Delhi, on Thursday, July 09, 2015, at 5:30 pm.</p>
<p>The Charter is being developed by the Open Data Working Group of the Open Government Partnership in consultation with a number of international organisations. Meant for approval and implementation by national governments, the Charter has five key principles:</p>
<ul>
<li>Open by Default;</li>
<li>Quality and Quantity;</li>
<li>Useable by All;</li>
<li>Engagement and Empowerment of Citizens; and</li>
<li>Collaboration for Development and Innovation.</li></ul>
<p>The first public draft of the International Open Data Charter was published in end of May 2015 at the International Open Data Conference in
Ottawa, and can be accessed here: <a href="http://opendatacharter.net/charter/" target="_blank">http://opendatacharter.net/charter/</a>.</p>
<p>Organisations and individuals are invited to submit comments directly on the Charter page, before July 31.</p>
<p>CIS, acting as a general steward of the Charter and a consultation lead, is organising this meeting to discuss the context, the drafting process, and the objectives of this document, and to encourage the participants to comment on the existing text of the Charter.</p>
<p>We keenly look forward to your participation in the consultation meeting on Thursday.</p>
<p>The CIS office address is G 15, Top floor, behind Hauz Khas G Block Market, Hauz Khas, New Delhi 110016.</p>
<p>If you are coming down Aurobindo Marg from AIIMS and towards IIT, then take the left turn into Chaudhary Dalip Singh Marg and come towards the Hauz Khas Police Station, stop when you see a Southy outlet on your right, and enter through the gate on your left (opposite Southy). The CIS office is on the top floor of the first house on your left. <a href="https://goo.gl/maps/kcJoq" target="_blank">Location on Google Map</a>.</p>
<p>Please share this invitation with all relevant individuals, organisations, and networks.</p>
<p> </p>
<p>
For more details visit <a href='http://editors.cis-india.org/openness/international-open-data-charter-consultation-delhi-09072015'>http://editors.cis-india.org/openness/international-open-data-charter-consultation-delhi-09072015</a>
</p>
No publishersumandroOpen DataOpen Government DataInternational Open Data CharterOpenness2015-07-07T12:12:50ZEventSoI’s Open Series Maps Fails to Implement Public Sharing of Govt Data
http://editors.cis-india.org/openness/survey-of-india-open-series-maps-fails-to-implement-public-sharing-of-govt-data
<b>Although it has made the topographic maps or the Open Series Maps available to general public, Survey of India’s (SoI) Nakshe portal will have to go through a variety of litmus test, as the initiative fails to implement the mandates of public sharing of government data using open standards and open license as put forward by the NMP 2005 and NDSAP 2012, says Sumandro Chattapadhyay, Research Director, The Centre for Internet and Society. This interview was published by Geospatial World on May 02, 2017.</b>
<p> </p>
<p>Cross-posted from <a href="https://www.geospatialworld.net/sois-open-series-maps-fails-implement-public-sharing-govt-data/">Geospatial World</a>.</p>
<hr />
<h4>What are your views on the Nakshe Portal initiative from Survey of India?</h4>
<p>It is a most welcome initiative by the Survey of India to realize the mandate of the National Map Policy (NMP) 2005 to publicly distribute “Open Series Maps of scales larger than 1:1 million”. The Survey of India has also drawn from and implemented the mandate of the National Data Sharing and Accessibility Policy (NDSAP) 2012 to make available the shareable and non-sensitive Open Series Maps documents without any necessary fees to access and use them.</p>
<p>The initiative, however, fails to achieve the goal of of public sharing of government data using open standards and open license as put forward by the NMP 2005 and NDSAP 2012. This substantively raises the barrier to access the Open Series Maps data and reduces its possibilities of reuse, especially for commercial innovation, in a very serious way. This undermining of the open data agenda is not only a concern for the Nakshe portal in particular, but also sets a dangerous precedent for future open government data initiatives in India.</p>
<h4>What is your view on the data provided and its usability?</h4>
<p>The Nakshe portal has created several barriers to access and use of the Open Series Maps data, all of which are in violation of the NMP 2005 and NDSAP 2012:</p>
<ul>
<li>
<p>NDSAP 2012 mandates that shareable and non-sensitive government data (such as Open Series Maps) are made public through the data.gov.in portal created under the guidance of the NDSAP 2012. Survey of India may of course decide to publish the Open Series Maps data on the Nakshe portal along with on the data.gov.in portal. Publishing of the data only through the Nakshe portal not only violates the mandate of NDSAP 2012, they make such data much less discoverable.</p>
</li>
<li>
<p>NDSAP 2012 allows for “registered access” to open government data. That is, it allows for data to be shared only with users who have registered with the data publishing portal. Making registration only possible via Aadhaar number, however, significantly limits the number of users who can access this data. For example, non-Indian researchers form an important potential sub-section of users of Open Series Maps but they will not be able to access the data. The website neither has a privacy policy that clarifies how these submitted Aadhaar numbers will be stored, protected, and shared (if at all) by the Survey of India.</p>
</li>
<li>
<p>NMP 2005 instructs Survey of India to “allow a user to add value to the maps obtained (either in analogue or digital formats) and prepare his own value-added maps”. The Government Open Data License has been recently notified under NDSAP 2012 to guide permitted uses of open government data in India.</p>
<p>The very restricted approach to permitted end-uses of Open Series Maps by the Survey of India neither follow the NMP instruction, nor adopt the Government Open Data License. Data available from Nakshe portal cannot be exported (which is technically an absurd demand due to globally distributed nature of servers), commercialized, or altered. This creates a most serious barrier to using the Open Series Maps data available via the Nakshe portal.</p>
</li>
<li>
<p>The Nakshe portal has published geospatial data in PDF format. This is a clear violation of open data practices globally and the NDSAP Implementation Guidelines more specifically, which states that open geospatial data standards, like GML and KML, should be used).</p>
</li></ul>
<h4>Does this fall in line with the larger government aim of having open and accessible data? If not why?</h4>
<p>In a nutshell, the Open Series Maps data being published on the Nakshe portal is neither open (as it does not use open standards to share the data and does not share the data under an open licenses) nor universally accessible (due to the requirement for registration via Aadhaar number).</p>
<h4>What improvements do you suggest in the approach of SoI about the portal?</h4>
<p>I have listed four major conflicts that the Nakshe portal has with the directives and guidelines offered by the NMP 2005 and NDSAP 2012. I sincerely hope that the Survey of India and the Department of Science and Technology will address them soon, as they significantly limit the ability of users to access and use the Open Series Maps data.</p>
<p>These changes will make the Open Series Maps data open, and ensure that the data can be accessed and innovated with by various stakeholders.</p>
<p> </p>
<p>
For more details visit <a href='http://editors.cis-india.org/openness/survey-of-india-open-series-maps-fails-to-implement-public-sharing-of-govt-data'>http://editors.cis-india.org/openness/survey-of-india-open-series-maps-fails-to-implement-public-sharing-of-govt-data</a>
</p>
No publishersumandroOpen DataOpen Government DataGeospatial DataOpenness2017-05-04T12:19:01ZBlog EntryGoogle, Apple and Microsoft may need licence for satellite mapping in India
http://editors.cis-india.org/openness/news/economic-times-aman-sharma-neha-alawadhi-may-9-2016-google-apple-and-microsoft-may-need-licence-for-satellite-mapping-in-india
<b>Cold response from MNCs like Google to India's security concerns is seen as a prime reason for the proposed legislation to regulate mapping of the country, a move that critics call "return of the Licence Raj" and "digital nationalism".</b>
<p>The article by Aman Sharma and Neha Alawadhi was published in <a class="external-link" href="http://economictimes.indiatimes.com/news/politics-and-nation/google-apple-and-microsoft-may-need-licence-for-satellite-mapping-in-india/articleshow/52180349.cms">Economic Times</a> on May 9, 2016. Sumandro Chattapadhyay was quoted.</p>
<hr />
<p style="text-align: justify; "><span>A draft of Geospatial Information Regulation Bill, released last week seeking public comments, says anyone mapping India by a satellite or aerial platform will need a licence from a government "security vetting authority". "India as a responsible power must have established guidelines," Kiren Rijiju, MoS for Home, told ET, reacting to the criticism to the move.</span></p>
<p style="text-align: justify; "><span>"We won't create hurdles for business and technological development, but national security considerations must not be compromised either," said Rijiju. Non-compliance could land you in jail for seven years. On the top of that would be a fine of up to Rs 100 crore. BJP MP Tarun Vijay, who has long been campaigning for such a law, said "patriotic Indians" should use the country's own 'Bhuvan' software application for maps.</span></p>
<p style="text-align: justify; "><span>"Why do we need Google? We should stop becoming Google's instruments," he told ET. "The patriotic government of Narendra Modi has taken a right step in a big relief to the security establishment. UPA did not take any action despite my pleas to the then Defence Minister AK Antony. I congratulate the Modi government for showing spine in face of arrogance of these IT giants," he said, adding: Google has been "behaving as if it were above Indian law".</span></p>
<p style="text-align: justify; "><span>A top government official involved in the move said maps of India's sensitive installations were available on Google Maps, increasing the security risk of those sites. Demand to mask those were never complied to. "Pathankot air base, which was recently attacked, can be seen on Google Maps. Terrorists plot strikes on sensitive targets studying Google Maps," he told ET.</span></p>
<p style="text-align: justify; "><span>"Our plea to black out sensitive installations do not yield results. This Bill is now sending a strong message that US companies cannot be running roughshod over Indian security interests." Companies such as Google, Microsoft and Apple, which have millions of Indians using their maps, would be hit directly by the legislation if it is pushed through. Firms that depend on these maps to provide their services, such as Uber, Zomato and Ola, too would be affected. Google, Apple and Microsoft didn't respond to emails seeking comment.</span></p>
<p style="text-align: justify; "><span>Mishi Choudhary, legal director at Software Freedom Law Centre, said almost all online businesses today depend on geo-location and provide maps for the use of their services, and that all of them will be forced to seek a licence under the proposed law. "This kind of digital nationalism is a way to create a government-controlled monopoly on all geographical information about the country, conveniently transforming Digital India to Licence India, digitally this time," said Choudhary, who was part<span> </span>of the successful legal fight to scrap Section 66A of the IT Act to ensure freedom of expression on the Internet. An executive at one of the big tech companies said the draft Bill raised far too many questions.</span></p>
<p style="text-align: justify; "><span>"On the face of it, the Bill will kill any and every use of the maps. It is also unclear if you get a licence for maps, only you can use it or others can use it, too," he said. "Also, whether every time you update a map, does one have to get a security clearance? Maps have to be live and dynamic, so getting it approved from government each time may not be feasible."</span></p>
<p style="text-align: justify; "><span>Those working on mapping and geospatial technology said services such as Google Maps are popular because they are faster and easier to use compared to government-prescribed process.<span> </span>"According to Indian law...if I have to buy certain data, I will have to go to the concerned department, like ISRO's National Remote Sensing Agency, or the Survey of India. In the case of NRSC (for satellite data), they will purchase the data for me, and then I will have to pay. That's a long process and hence people went to services like Google Maps, which are easier," said Devdatta Tengshe, a freelance geospatial information systems consultant.</span></p>
<p style="text-align: justify; "><span>The agency removes sensitive zones from the data and takes about two-three months or even more to respond, which is an unrealistic timeline for people working with digital data, he said. There is also apprehension that the Bill will undermine rescue and humanitarian efforts, such as during disasters like the Nepal earthquake.</span></p>
<p style="text-align: justify; "><span>"It was user-generated geospatial data that was used by the humanitarian response teams. This situation of lack of openly usable geospatial data holds true for large parts of India, and especially Himalayan India," said Sumandro Chattapadhyay, research director at Centre for Internet and Society. Also of concern is the lack of court's jurisdiction in matters related to the proposed legislation, said SFLC's Choudhary.</span></p>
<p style="text-align: justify; "><span>A senior government official, however, said companies should not have a problem to come under regulations on security considerations and that the Bill was up for public comments where the companies can lodge their apprehensions. "We are not banning anyone from mapping India — only that the mapping has to be in line with Indian security considerations regarding sensitive installations and correct boundaries being depicted like not showing PoK and Arunachal Pradesh as out of India," this official said.</span></p>
<p style="text-align: justify; "><span>A group of techies have, meanwhile, got together to create a website called savethemap.in, which aims to educate people and make them send out responses to the draft Bill. It will likely come up with a template response, along the lines as the savetheinternet. in campaign that was instrumental in taking the net neutrality debate to the people.</span></p>
<p>
For more details visit <a href='http://editors.cis-india.org/openness/news/economic-times-aman-sharma-neha-alawadhi-may-9-2016-google-apple-and-microsoft-may-need-licence-for-satellite-mapping-in-india'>http://editors.cis-india.org/openness/news/economic-times-aman-sharma-neha-alawadhi-may-9-2016-google-apple-and-microsoft-may-need-licence-for-satellite-mapping-in-india</a>
</p>
No publisherpraskrishnaOpen StandardsOpen DataOpen Government DataOpenness2016-05-10T15:20:39ZNews ItemLegal Challenges to Mapping in India #1 - Laws, Policies, and Cases
http://editors.cis-india.org/openness/legal-challenges-to-mapping-in-india-1-laws-policies-cases
<b>Responding to the draft Geospatial Information Regulation Bill and the draft National Geospatial Policy made public recently, this post provides an overview of the present configuration of laws, policies, and guidelines that provides the legal framework in India for governance of creation and sharing of geospatial data in India. The post also studies these policies in action by describing the key legal cases around the creation and use of geospatial data. The next post of this series will document the reflections and opinions of the key geospatial industry actors in India, as well as the free and open source mapping community.</b>
<p> </p>
<p><strong>1.</strong> <a href="#1">Introduction</a></p>
<p><strong>2.</strong> <a href="#2">Mapping the Legal Journey of Geospatial Data: Past to Present</a></p>
<p><strong>2.1.</strong> <a href="#2-1">National Map Policy, 2005</a></p>
<p><strong>2.2.</strong> <a href="#2-2">Guidelines issued by Survey of India</a></p>
<p><strong>2.3.</strong> <a href="#2-3">Remote Sensing Data Policy (RSDP)</a></p>
<p><strong>2.4.</strong> <a href="#2-4">Civil Aviation Rules</a></p>
<p><strong>3.</strong> <a href="#3">Incidents of Legal Actions Faced by Agencies</a></p>
<p><strong>3.1.</strong> <a href="#3-1">Google's Mapathon in Legal Trouble</a></p>
<p><strong>3.2.</strong> <a href="#3-2">One Country - Two Boundaries</a></p>
<p><strong>3.3.</strong> <a href="#3-3">J. Mohanraj v Google and Others</a></p>
<p><strong>4.</strong> <a href="#4">Conclusion</a></p>
<p><strong>5.</strong> <a href="#5">References</a></p>
<p><strong>6.</strong> <a href="#6">Author Profile</a></p>
<hr />
<h2 id="1">1. Introduction</h2>
<blockquote>“Maps, like faces, are the signature of history.” – Will Durant <strong>[1]</strong></blockquote>
<p>Throughout the course of history geospatial information has played an important role in technological, economic, political and cultural dimensions of the human society. With technological developments taking place, the field of mapping – that is collection, analysis, and representation of geospatial data – is continuously evolving. On the face of it, creation of geospatial data seems to be an exclusive scientific and technological matter. However, the political and economic facets of geospatial data are often as predominant and complex as its scientific practice. Continuing from the colonial era, the political facet of mapping emerged significantly in the public discourse from the 1990s onwards as digital technologies amplified the ability of non-governmental actors to collect, generate, and share geospatial data, in the form of maps or otherwise <strong>[2]</strong>. This 'democratisation' of the ability to map and share private/user-generated maps structurally undermined the government's ability to have an authoritative and universal voice when it comes to geospatial depiction of the nation and its various components. Similar to the other upsurges in the digitized world, which is often followed by an introduction of legal provisions in order to keep access to and use of digital data under mechanisms of monitoring and permission, mapping in India has also has subsequently been governed under policies addressing both terrestrial mapping and remote sensing. Concerns of national security, naturally, have driven much of these policies.</p>
<p>This post focuses on providing an overview of the present configuration of laws, policies, and guidelines that provides the legal framework in India for governance of creation and sharing of geospatial data in India. The post also studies these policies in action by describing the key legal cases around the creation and use of geospatial data. The next post of this series will document the reflections and opinions of the key geospatial industry actors in India, as well as the free and open source mapping community.</p>
<p> </p>
<h2 id="2">2. Mapping the Legal Journey of Geospatial Data: Past to Present</h2>
<blockquote>“We know every inch of the nation, because we map every inch of it!” – Survey of India <strong>[3]</strong></blockquote>
<p>Aforementioned slogan adopted by the primary organization responsible for mapping all geospatial data in India indicates the importance of the geospatial data and mapping the same. While it indicates the importance of having access to mapping data in order to be aware of the geospatial features of one’s country, it also cleverly reveals the vulnerability that having access to mapped data brings. The phrase can be said to imply that mapping every inch of the country leads to information about every inch of the nation which is useful if in the hands of government agency but repugnant to security if in the hands of external agencies. This conflict between access to information about the country and the security concerns arising from such an open access has led to a rich evolution of legal policies governing the same.</p>
<p>Set up in 1767, Survey of India (hereinafter “SOI”) was required to map the terrains of India to fulfill the commercial and political convenience of the East India Company <strong>[4]</strong>. During these colonial times, maps were considered to be essential for governmental purposes and thus their dissemination to unauthorized persons was barred by Clause 5 of the Official Secrets Act, 1923 <strong>[5]</strong>. Thus, till 1950s mapping was being governed by the colonial provisions which maps restricted to official use only <strong>[6]</strong>. With independence, the functions of the SOI shifted mainly towards providing information for the defense forces <strong>[7]</strong>.</p>
<p>An important change came in the form of orders and notifications by Ministry of Defence (hereinafter “MOD”) during 1960s, the major one being the 1965 order that permitted distribution of maps of scale 1:4 M <strong>[8]</strong>. The Map Restriction Policy of the MOD, however, imposed categorical restrictions on sharing of maps, aerial photos, and all geophysical data for various parts of India - with a focus on international border areas in the North-Eastern state, and the coastal zone that included several large cities like Chennai, Kochi, Kolkata, and Mumbai <strong>[9]</strong>. Dr. Manosi Lahiri notes that "[t]his had a far reaching effect on the mapping culture of independent India and perpetuated the perception among many that maps were a security threat" <strong>[10]</strong>." By 1971, however, the functions of SOI extended to catering to inter alia all development activities and was hence brought under the ambit of Department of Science and Technology <strong>[11]</strong>.</p>
<p>However, the catalytic transformation came in the form of National Map Policy, 2005 which made SOI the nodal governmental agency for dealing with all processes involving geospatial data. While harping for open access to geospatial data, the policy accompanied by corresponding guidelines have largely restricted the power to map geospatial data to SOI. The Policy and the guidelines have been discussed in detail as under.</p>
<h3 id="2-1">2.1. National Map Policy, 2005</h3>
<p>The National Map Policy, 2005 (hereinafter, “NMP”) was announced by the Central Government on May 19, 2005 <strong>[12]</strong>. The preamble of the policy identifies the importance of high quality spatial data in various facets such as socio-economic development, conservation of natural resources, infrastructure development etc <strong>[13]</strong>. Topographic map database constitutes the foundation of all spatial data and its production, maintenance, and dissemination has been assigned as a responsibility to SOI, which is to "liberalize access" to spatial data without compromising upon security concerns. Thus, the conflict between national security and right to have access to information regarding one’s country is clearly highlighted in the policy as a need for enactment of the same. Thus, the policy objectives include access to National Topographic Database (NTDB) <strong>[14]</strong> and promotion of geospatial based intelligence, subject to confirmation to national standards of SOI.</p>
<p>In order to realize the security concerns, inter alia, a dual-classification was created amongst the maps, namely - i) <strong>Defence Series Maps (“DSM”)</strong> and ii) <strong>Open Series Maps (“OSM”)</strong>. While the former constitutes of topographical maps that mainly cater to defence and security requirements of the country, the latter supports developmental activities. Hence, DSMs whether in analogue or digital form, fall under the classified category and the power to issue guidelines pertaining to their use vests digit mainly for developmental purposes, they are not openly accessible by ipso facto and need to gain the ‘unrestricted’ tag after clearance from MOD. A table specifying the distinction between DSMs and OSMs in detail has been provided below:</p>
<hr />
<table>
<tbody>
<tr>
<th>Sub-Topic</th>
<th>Defence Series Maps (“DSM”)</th>
<th>Open Series Maps (“OSM”)</th>
</tr>
<tr>
<td>Why are these maps used?</td>
<td>The maps under this series cater to defence and security requirements of the country.</td>
<td>The maps under this series are useful in supporting various developmental activities in the country.</td>
</tr>
<tr>
<td>What are the technical classifications?</td>
<td>Everest/WGS-84 Datum and Polyconic/UTM Projection) on various scales (with heights, contours and full content without dilution of accuracy).</td>
<td>In UTM Projection on WGS-84 datum, bearing different map sheet numbers. (And as provided in Annexure B of the NMP)</td>
</tr>
<tr>
<td>Who can use these maps?</td>
<td>Maps (in analogue or digital forms) for the entire country will be classified.</td>
<td>Both hard copy and digital form will become “Unrestricted” after obtaining a one-time clearance of the Ministry of Defence.</td>
</tr>
<tr>
<td>How can the maps be used?</td>
<td>Guidelines regarding the use of DSMs will be formulated by the Ministry of Defence.</td>
<td>Guidelines regarding the use of OSMs will be formulated by SOI regarding aspects like procedure for access, further dissemination /sharing, ways and means of protecting business and commercial interests of SOI etc.</td>
</tr>
</tbody>
</table>
<hr />
<p>While the DSMs are completely classified, restrictive provisions regarding usage and dissemination of OSMs have also been incorporated in the policy. OSMs are not allowed to show any civil and military Vulnerable Areas and Vulnerable Points (VA’s/VP’s). OSMs on a scale larger than 1:1 needs to be disseminated either by sale or an agreement, which will allow the agency to add its own value to the maps obtained, and to share these maps with others.</p>
<p>The primary transaction between SOI and the agency as well as all the subsequent transactions between the agency and other users have to be registered in the Map Transaction Registry for records. While the Map Transaction Registry forms an important part of the NMP, no such registry information has been made available on the official website of SOI as indicated by the screenshot below.</p>
<img src="https://raw.githubusercontent.com/cis-india/website/master/img/SurveyOfIndia_MapTransactionRegistry.png" alt="Map Transaction Registry, Survey of India" />
<h6>Map Transaction Registry, Survey of India, URL: <a href="http://www.surveyofindia.gov.in/pages/view/48">http://www.surveyofindia.gov.in/pages/view/48</a></h6>
<p> </p>
<p>The policy allows users to publish maps on hard copy or web (with or without GIS interface) subject to a certification from SOI in case of depiction of international boundaries. The policy also upholds the validity of the previous MOD notifications pertaining to mapping subject to the modifications introduced by the policy and authorises SOI to issue further guidelines corresponding to the policy.</p>
<h3 id="2-2">2.2. Guidelines issued by Survey of India</h3>
<p>Under the powers vested by the NMP, SOI has issued detailed clarificatory guidelines in furtherance of the policy <strong>[15]</strong>. The restrictions arising on mapping of geospatial data can be attributed to two major factors namely, Security concerns and Copyright provisions <strong>[16]</strong>. Under the guidelines, copyright of both digital and analogue maps has been vested with the SOI. Penal consequences have been mentioned as a result of violation of SOI’s copyrights. In furtherance of security concerns, the guidelines uphold the Ministry of Finance (Department of Revenue) Notification No. 118-Cus./F.No.21/ 5/62-Cus. I/VIII dated 4th May 1963 which prohibits the export of all maps/digital data in 1: 250K and larger scales through any means. Digital Topographical data has been an exclusive licensing domain of only Indian individuals, organisations, firms or companies.</p>
<p>While paper maps can be accessed from SOI offices against payment of price, digitisation of maps has been strictly made forbidden by the guidelines. Ownership of digital data has been vested completely with the SOI and can only be gained against payment after application through a specified proforma.</p>
<h3 id="2-3">2.3 Remote Sensing Data Policy (RSDP)</h3>
<p>In 2011, the confusion pertaining to applicability of NMP to both territorial and satellite mapping was resolved with the release of the Remote Sensing Data Policy (RSDP). The policy recognized the importance of remote sensing data and noted that it was largely used by government and non-government users from Indian and foreign remote sensing satellites. However, again banking upon the need for security considerations, the policy was released with the purpose of “…managing and/ or permitting the acquisition/dissemination of remote sensing data in support of developmental activities" <strong>[17]</strong>. Department of Science (DOS) was made the nodal government agency for all actions pertaining to remote sensing data under the policy.</p>
<p>A basic perusal of the policy indicates a parallelism between the RSDP and the NMP. Thus, similar to NMP, RSDP assures of a government managed Indian Remote Sensing Satellites (IRS) Programme, the data produced by which will be solely owned by the government and other users could only be provided with licences if need be. Any attempt at acquiring and/or dissemination of remote sensing data within India requires permission through the nodal government agency. National Remote Sensing Centre (NRSC) of the Indian Space Research Organisation (ISRO)/ DOS is vested with the authority to acquire and disseminate all satellite remote sensing data in India, both from Indian and foreign satellites. NRSC is also supposed to maintain a systematic National Remote Sensing Data Archive, and a log of all acquisitions/ sales of data for all satellites. Thus, nodal government agencies were created for both terrestrial mapping and satellite imagery, former being SOI and latter NRSC.</p>
<h3 id="2-4">2.4 Civil Aviation Rules</h3>
<p>Aerial instruments and aircrafts act as important instruments for geophysical surveys and mapping. Thus, this area does not go ungoverned. While, till date, India doesn’t impose an explicit bar on foreign registered aircraft overflying its territory for aerial photography and geo-physical survey, the same is subject to prior clearance under rule 158 and 158A of the Aircraft Rules, 1937 on account of safety and security concerns, the procedure for which has been given under Civil Aviation Rules (CAR) <strong>[18]</strong>. CAR is applicable to inter alia agencies undertaking aerial photography, geophysical surveys etc. An application is required to be made as per Annexure E which inter alia requires confinement of photography/sensing to the exact area as applied and cleared by the Ministry of Defence. The application is forwarded by DGCA to the Ministry of Defence and other agencies responsible for issuing NOC.</p>
<p>DGCA’s restrictions extends to voluntary geographic information with prohibition of civilian drones in India. Unmanned drones are an important equipment used for the purpose of collecting geo-spatial data. The ban on flying drones in India exist from October, 2014 but is not in common knowledge <strong>[19]</strong>. While it is argued that drones could harm people and lead to chances of crashing, the major argument has always been the use of drones by anti-national elements to peruse sensitive places for plotting terror attacks <strong>[20]</strong>. While there is an ambiguity regarding using drones in India, flying drones over defence establishments and historical places is completely banned <strong>[21]</strong>. Thus, civilians using drones for clicking pictures of monuments etc. have often been confronted by the police <strong>[22]</strong>.</p>
<p>Thus, there is no single policy that acts as a deterrent for mapping in India but an accumulation of multiple policies, guidelines and legal provisions that are used by departments of government to restrict mapping in the name of security. These restrictions have also witnessed incidents in their furtherance as detailed below.</p>
<p> </p>
<h2 id="3">3. Incidents of Legal Actions Faced by Agencies</h2>
<p>Since the advent of restrictive mapping policies, numerous incidents have come forth when agencies have found themselves faced by legal actions for violating such policies. In recent times, these incidents were publicly highlighted in 1998 when the sale of the CD-Roms of Delhi Guide Maps created by Eicher were prohibited <strong>[23]</strong>. Eicher has been one of the oldest players of the private mapping market, creating city and road maps for India in the private sector for public distribution. While having faced a ban in earlier times, it is also one of the few companies been able to access the SOI data for value addition. It works in collaboration with SOI now, often launching products in ‘strategic alliance’ with them. After the implementation of NMP, we have witnessed two major legal controversies, both involving SOI on one hand and Google on the other.</p>
<h3 id="3-1">3.1. Google's Mapathon in Legal Trouble</h3>
<p>In furtherance of Google’s constant endeavour to have every nook and corner mapped, Google holds a competition called ‘Mapathon’ each year <strong>[2]</strong>. The competition invites people to map their local surroundings incentivised by lucrative prizes to winners. However, an initiative launched for purely mapping purposes had to face a large legal hurdle in the year of 2013. Google-Mapathon, 2013, held in February-March, had declared Vishal Saini as the 1st winner who had mapped the military-prone city of Pathankot. According to legal provisions governing mapping practices in India, civil and military Vital Areas (VAs) /Vital Points (VPs) cannot be shown on maps in public domain <strong>[25]</strong>. Thus, the tech-giant found itself amidst legal controversy for having held the competition without permission from Survey of India after a concern raised by BJP’s Tarun Vijay. A case was filed by SOI at the R.K. Puram Police Station. The primary contention was that the “Mapathon 2013 activity is likely to jeopardise national security interest and violates the National Map Policy. Citizens of the country, who are ignorant of the legal consequences, are likely to violate the law of the land” <strong>[26]</strong>.</p>
<p>Considering the involvement of a U.S. based company, the investigation was handed over to CBI During the probe, it was alleged by then Surveyor General of India Swarna Subba Rao that Google did not refrain from “polluting” <strong>[27]</strong> the internet with classified material despite having been asked so. Further, then Additional Surveyor-General of India R.C. Padhi wrote claimed that “The Survey of India is only mandated to undertake ‘Restricted’ category surveying and mapping, and no other government/private organisations or any individual are authorised to do so” <strong>[28]</strong>. He told Reuters that some of the information provided by locals to Google could be ‘sensitive’ and the security of the nation could not be compromised at any cost <strong>[29]</strong>.</p>
<p>Google on the other hand said that its primary motive was to map local information of daily needs such as hospitals, restaurants, markets etc. and the competition was in tandem with national laws. Further, it was heard that Google had been approached regarding Mapathon by SOI and it had replied with intimation of willingness to talk to SOI. However, SOI had not reverted back and Google was always ready and willing to talk out the matter. However, the much hyped case did not have a substantial result and CBI had to close the probe on account of lack of evidence <strong>[30]</strong>.</p>
<p>Considered a thing of past, the controversy resurfaced in the recent times of January, 2016 post the Pathankot Air Base strike <strong>[31]</strong>. Google was dragged to the court for having displayed sensitive geospatial data regarding Pathankot that made possible an airstrike at the location. An injunction was sought to refrain Google from showing sensitive military areas and defence establishments on the maps made available by it. While the injunction was refused, Delhi High Court had asked the centre and the additional solicitor to look into the same and keep the court apprised. Thus, this can be termed as an open and unfinished matter ongoing legal contemplation.</p>
<p>While it is understandable that some areas are considered as vulnerable due to security concern. The lost keeps changing often leading to transgression into security places. But the major point being the list of vulnerable areas is classified and not released to public. In absence of such a list, how is it possible for google to vet its data to comply with security concerns.</p>
<h3 id="3-2">3.2. One Country - Two Boundaries</h3>
<p>Another major legal controversies in the field of geospatial mapping has been with regards to wrong depiction of international boundaries of India by Google. A basic perusal of the official website of SOI provides a list of only three documents under the tab of ‘Public Awareness’, all dealing with the crime of depicting wrong Indian boundaries <strong>[32]</strong>. While one of them includes the certified map with correct boundaries, to be complied with, other is a gazette notification bringing the Criminal Law Amendment Act, 1961 which criminalized the act of showing wrong depiction of boundaries. Section 69A of the IT Act has also been used earlier to restrict access to links depicting incorrect maps of India <strong>[33]</strong> though it only speaks about restricting public access to data, necessary in the interest of Sovereignty and Integrity inter alia, the section per se does not deal with dissemination of geos-spatial data.</p>
<p>It was in the year of 2014, that on the directions of Department of Science and Technology, SOI filed a complaint against Google at the Dehradun Police Station for depiction of international boundaries not in a “wrong manner” i.e. not in compliance with Government of India authentication <strong>[34]</strong>. The result was that today Google shows different boundaries on Indian domain, in compliance with SOI and different on International domain.</p>
<p>Google was also involved in a controversy when in 2009, Google maps for India marked areas of Arunachal Pradesh, including its capital Itanagar and Tawang, in China <strong>[35]</strong>. It was followed by an apology from Google and an immediate rectification for Indian users. However, Google uses a different version for China and the world creating disparity in the boundary depiction <strong>[36]</strong>.</p>
<p>Google has not been the only platform having faced the anger of Indian community for wrong depiction. In 2011, copies of the Economist Magazine were seized for having depicted the map of Kashmir divided between India, Pakistan and China <strong>[37]</strong>. For similar reasons, Al-Jazeera was taken off air by the Indian government after a 5-day ban imposed under Section 69A of the IT Act <strong>[38]</strong>. Modi’s visit to Queensland University of Technology was accompanied by an “unqualified apology” from the authorities for having depicting Indian map without portions of Kashmir <strong>[39]</strong>. Urban Development Department of Bihar also ended up show-causing one of its employees for putting up wrong map on its website and substituting the same with SOI’s version after media attention <strong>[40]</strong>. India seems to be the country often having been angered due to wrong depictions of maps.</p>
<p>While India seems to be actively involved in Geo-politics, it isn’t the only country Google has fallen in legal trouble with, for wrongly depicting International Boundaries. In 2010, Google gained a lot of media attention for allegedly starting the ‘First Google Maps War’ <strong>[41]</strong>. It occurred when a Nicaraguan official led his forces to the Costa Rican territory on other side of the customary border and used Google Maps as a proof to deny trespassing. Nicaragua and Costa Rica have a long territorial dispute and Google seem to have fuelled it by depicting the Nicaraguan version of border according to which that area of Cost Rican territory came within the boundaries of Nicaragua <strong>[42]</strong>. Despite Nicaragua’s petition to Google to not accept Costa Rica’s petition to shift borders, Google voluntarily changed its borders to comply with the Costa Rican stance <strong>[43]</strong>.</p>
<p>Another such incident followed in the case of Google’s depiction of Dutch-German border with respect to Dollart Bay <strong>[44]</strong>. Germany claimed the border to be closer to Dutch land while Dutch claimed it to be more towards centre. Google, however, chose to depict a self-version that transferred the German city of Emden to the territorial control of Netherlands. This infuriated the city which resorted to expressing its displeasure and asking Google to change the depiction. Google, this time, however remained dormant and no amendment in the depiction of Dutch-German border could be witnessed.</p>
<p>At the time of Crimean referendum supporting independence, U.N. had passed a resolution condemning the same and supporting territorial integrity of Ukraine. Google, however, believed in the contrary and was quick to bring changes into its maps to depict formation of independent Crimea <strong>[45]</strong>. Rather than a mistake, this time, Google had adopted a stance against the UN resolution and used its maps to vocalize the same.</p>
<p>Similarly during the inclusion of South Sudan in the U.N.G.A., while members voted, they were unaware of the exact territorial division between North and South Sudan. It was then that Google initiated the process of collecting geo-spatial information regarding South Sudan from locals in order to better the territorial integrity <strong>[46]</strong>.</p>
<p>Thus, Google has times and again fallen into criticism for wrong depiction of international boundaries and even varied depictions of boundaries as per the perspective of the political entity. However, “Popularity does not bestow authority” <strong>[47]</strong> and Google’s maps cannot be accurately relied upon for proving sovereign territorial holds. Thus, most of the international incidents have witnessed countries resorting to peaceful petitions to Google informing it regarding the inaccuracy of the border and requesting a shift in the same. Hardly has the world witnessed penal provisions being invoked against Google for depicting versions other than the perceived ones.</p>
<h3 id="3-3">3.3. J. Mohanraj v Google and Others</h3>
<p>Apart from the above two incidents, another pertinent case is the 2008 judgment by the Madras High Court in J. Mohanraj v (1) Secretary To Government, Delhi; (2) Indian Space Research Organisation, Bangalore; (3) Google India Private Limited, Bangalore . A writ petition was filed by Mohanraj seeking a complete ban on Google Earth and ‘Bhuvan’; mapping initiatives by Google and ISRO respectively <strong>[48]</strong>.</p>
<p>The petition was allegedly filed in public interest considering the security apparatus of Indian Government along with the threat posed by the terrorists. The petitioner claimed that the initiatives such as Google Earth used high quality satellite imagery to display bird’s eye view of various establishments including minute details and were bound to cover defense establishments and sensitive areas, posing a threat to Indian security. Dr. A.P.J. Abdul Kalam’s speech was referred to indicate his views against such open creation of geospatial data. The provisions of the NMP was highlighted and it was alleged that such mapping practices violated the individual rights of a person under Article 21 of the Constitution. Further, it was claimed that such practices could only be taken up by SOI and were outside the purview of private organizations.</p>
<p>However, the Court held that the petitioner was unable to produce any specific “Guidelines/Rules/Law laid down by the Central/State Governments, prohibiting the private organisations or any other individuals to Interactive Mapping Program, covering vast majority of the Planet”. Since the court could only interpret existing provisions and not lay down guidelines, passed the judgment against the petitioners.</p>
<p>From the above explained incident it seems that the NMP per se does not refrain creation of mapping data by agencies other than SOI. The centre of the conflict seems to lie with the interpretation of the policy by SOI claiming itself to be the exclusive agency entitled to map data. Hence, often though complaints and cases are filed against such activities, no concrete consequence emerges from the same. Further, the courts have also neglected the grievance of the issue and given ambiguous judgments in most cases. Thus no judicial sanction or opposition to the SOI’s guidelines exist till date often allowing SOI to continue with following its own version. While these cannot be termed as a solution, they definitely indicate towards the root of the problem.</p>
<p> </p>
<h2 id="4">4. Conclusion</h2>
<p>It can be concluded from above compilation of legal provisions and incidents that it is perhaps SOI’s interpretation to NMP that gives rise to exclusive authority to map geospatial data and not the policy per se. The objective of the policy clearly advocates for promotion of the use of geospatial knowledge and intelligence. More than one provision under the SOI guidelines indicate towards the arbitrary abuse of power. First, a provision regarding ‘Settlement of disputes’ has been included in the guidelines. Secretary, Department of Science & Technology has been vested with binding decision making powers in case of a dispute on the applicability or interpretation of the guidelines between the SOI and any other person. Thus, instead of a judicial forum, an executive authority has been vested with quasi-judicial powers. Such a dispute resolution mechanism cannot be considered as devoid of bias towards the governmental agency, hampering fair and equal justice. Second, SOI assumed the power of mapping data but under the guidelines considers itself devoid of complete responsibility for the loss caused to any person on account of failure of proper dissemination of data. Third, the SOI has reserved the right to add, delete, modify or amend every provision of the guidelines at any time without assigning any reason or notice.</p>
<p>While depiction of wrong boundaries has been specifically been criminalized and can be accepted as symbolic of sovereign hold over contentious territorial areas, it hardly fulfills a security purpose other than acting as a proof to the international community. The incident regarding Mapathon, on the other hand, though did not result in penal consequences towards Google, seem counterproductive in the first place for asking for a ban on increase of geospatial resource data. Considering the same, prudency demands that India also adopt policies and measures that are more peaceful and accommodating in nature such as resolving territorial matters by talking out with Google and other agencies. The current and proposed stringent penal provisions only act as dis-incentivising measures for geo-spatial agencies to map India, which is not the motive sought to be achieved by the bill.</p>
<p>However, the interpretation of the policy cannot be blamed alone for restrictions such as depiction of VAs and VPs have been specifically mentioned in the policy. Above mentioned policies and guidelines have often been criticized for being overly restrictive in nature and a consequence of colonial hangover. In times of crowdsourcing of mapping data, the need of the hour exist in critically analysing the existent policies and their interpretation. The same is especially so in the absence of a high quality digital version of the correct boundary of India. While a map in PDF form has been put up by Survey of India, the same cannot be converted to digital form to be complied with or used to resolve territorial disputes of detailed nature. This makes it absolutely impossible to completely comply with the Indian version of the boundaries without a proper resource acting as a comparison check. The need of the hour is for the Government to release less ambiguous and specific details as to what it considers to be outside the scope of private mapping and the correct boundaries along with a less stringent policy framework so that India can protect its security, sovereignty and integrity while promoting creation and dissemination of geo-spatial data.</p>
<p> </p>
<h2 id="5">5. References</h2>
<p><strong>[1]</strong> SV Srikantia, 'Restriction on maps: A denial of valid geographic information,' [2000] 79(4), Current Science 484.</p>
<p><strong>[2]</strong> Fatima Alam, 'Mapping the politics of cartography,' Infosys Science Foundation, 31 March 2015, <a href="http://www.infosysblogs.com/infosysprize/2015/03/mapping_the_politics_of_cartog_2.html">http://www.infosysblogs.com/infosysprize/2015/03/mapping_the_politics_of_cartog_2.html</a>, accessed 11 May 2016.</p>
<p><strong>[3]</strong> 'About Us,' Survey of India, <a href="http://www.surveyofindia.gov.in/pages/view/10-about-us">http://www.surveyofindia.gov.in/pages/view/10-about-us</a>, accessed 11 May 2016.</p>
<p><strong>[4]</strong> Ibid.</p>
<p><strong>[5]</strong> R Ramachandran, 'Public Access to Indian Geographical Data,' [2000] 79(4) Current Science 450.</p>
<p><strong>[6]</strong> Ibid.</p>
<p><strong>[7]</strong> Supra, 4.</p>
<p><strong>[8]</strong> “Scale represents the relationship of the distance on the map/data to the actual distance on the ground. Map detail is determined by the source scale of the data: the finer the scale, the more detail.” Seen at <a href="http://gif.berkeley.edu/documents/Scale_in_GIS.pdf">http://gif.berkeley.edu/documents/Scale_in_GIS.pdf</a>.</p>
<p><strong>[9]</strong> Dr. Manosi Lahiri, 'Survey & Mapping in India: The Regulatory Framework,' Directions Magazine India, <a href="https://www.mlinfomap.com/Pdf/Survey&Mapping-Lahiri%202.1.pdf">https://www.mlinfomap.com/Pdf/Survey&Mapping-Lahiri%202.1.pdf</a>, accessed 11 May 2016.</p>
<p><strong>[10]</strong> Ibid.</p>
<p><strong>[11]</strong> Supra, 2.</p>
<p><strong>[12]</strong> ‘Guidelines for implementing National Map Policy,’ Survey of India, <a href="http://surveyofindia.gov.in/files/nmp/Guidlines%20for%20Implementing%20National%20Map%20policy.pdf">http://surveyofindia.gov.in/files/nmp/Guidlines%20for%20Implementing%20National%20Map%20policy.pdf</a>.</p>
<p><strong>[13]</strong> 'National Map Policy, 2005, Preamble,' Survey of India, <a href="http://surveyofindia.gov.in/files/nmp/National%20Map%20Policy.pdf">http://surveyofindia.gov.in/files/nmp/National%20Map%20Policy.pdf</a>.</p>
<p><strong>[14]</strong> Ibid, Objectives.</p>
<p><strong>[15]</strong> Supra, 11.</p>
<p><strong>[16]</strong> Supra, 5.</p>
<p><strong>[17]</strong> 'Remote Sensing Data Policy, 2011,' National Remote Sensing Centre, Indian Space Research Organisation, <a href="http://www.nrsc.gov.in/Remote_Sensing_Data_Policy">http://www.nrsc.gov.in/Remote_Sensing_Data_Policy</a>.</p>
<p><strong>[18]</strong> Civil Aviation Requirement Section 3 Air Transport Series ‘F’ Part I Issue I, 12th October 2010.</p>
<p><strong>[19]</strong> Nandagopal Rajan, 'Why India needs rules for flying drones, soon' (The Indian Express, 9 July, 2015) <a href="http://indianexpress.com/article/technology/gadgets/why-india-needs-rules-for-flying-drones-soon/">http://indianexpress.com/article/technology/gadgets/why-india-needs-rules-for-flying-drones-soon/</a> accessed 11 May 2016.</p>
<p><strong>[20]</strong> TNN, 'Now, flying a drone can land you in prison' (The Times of India, 15 February, 2016) <a href="http://timesofindia.indiatimes.com/city/jaipur/Now-flying-a-drone-can-land-you-in-prison/articleshow/50990613.cms">http://timesofindia.indiatimes.com/city/jaipur/Now-flying-a-drone-can-land-you-in-prison/articleshow/50990613.cms</a>, accessed 11 May 2016.</p>
<p><strong>[21]</strong> Ibid.</p>
<p><strong>[22]</strong> Supra, 19; 20.</p>
<p><strong>[23]</strong> Supra, 5.</p>
<p><strong>[24]</strong> tech2 news staff, 'Why is Google’s Mapathon in hot waters in India? All you need to know' (Tech-2, 12 Aug, 2015) <a href="http://tech.firstpost.com/news-analysis/why-is-googles-mapathon-in-hot-waters-in-india-all-you-need-to-know-228810.html">http://tech.firstpost.com/news-analysis/why-is-googles-mapathon-in-hot-waters-in-india-all-you-need-to-know-228810.html</a>, accessed 6 May 2016</p>
<p><strong>[25]</strong> Supra, 12.</p>
<p><strong>[26]</strong> Supra, 24.</p>
<p><strong>[27]</strong> ‘PTI, 'Google ‘polluted Internet’ with classified material: Survey of India' (The Hindu, 10 August, 2014) <a href="http://www.thehindu.com/sci-tech/technology/internet/mapathon-2013-row-google-polluted-internet-with-classified-material-says-survey-of-india/article6300853.ece">http://www.thehindu.com/sci-tech/technology/internet/mapathon-2013-row-google-polluted-internet-with-classified-material-says-survey-of-india/article6300853.ece</a>, accessed 11 May 2016.</p>
<p><strong>[28]</strong> Sandeep Joshi, ‘Google didn’t take permission for Mapathon’ (The Hindu, 24 April, 2013) <a href="http://www.thehindu.com/news/national/google-didnt-take-permission-for-mapathon/article4648589.ece">http://www.thehindu.com/news/national/google-didnt-take-permission-for-mapathon/article4648589.ece</a>, accessed 6 May 2016.</p>
<p><strong>[29]</strong> Supra, 24.</p>
<p><strong>[30]</strong> Abhishek Sharan, 'CBI may close probe against Google in Mapathon case' (Hindustan Times, 12 February, 2015) <a href="http://www.hindustantimes.com/india/cbi-may-close-probe-against-google-in-mapathon-case/story-CgZYWoP9NgYA3xVepjr5bN.html">http://www.hindustantimes.com/india/cbi-may-close-probe-against-google-in-mapathon-case/story-CgZYWoP9NgYA3xVepjr5bN.html</a>, accessed 6 May 2016.</p>
<p><strong>[31]</strong> PTI, 'Pathankot attack: Sensitive sites on Google Maps under Delhi HC scanner' (Times of India, 15 January, 2016) <a href="http://timesofindia.indiatimes.com/tech/tech-news/Pathankot-attack-Sensitive-sites-on-Google-Maps-under-Delhi-HC-scanner/articleshow/50596143.cms">http://timesofindia.indiatimes.com/tech/tech-news/Pathankot-attack-Sensitive-sites-on-Google-Maps-under-Delhi-HC-scanner/articleshow/50596143.cms</a>, accessed 6 May 2016.</p>
<p><strong>[32]</strong> ‘Public Awareness,' Survey of India, <a href="http://www.surveyofindia.gov.in/pages/display/190-public-awareness">http://www.surveyofindia.gov.in/pages/display/190-public-awareness</a>), accessed 6 May 2016.</p>
<p><strong>[33]</strong> Aman Sharma, '7-year jail, Rs 100 crore fine soon for showing PoK, Arunachal as disputed' (The Economic Times, 05 May 2016) <a href="http://economictimes.indiatimes.com/news/politics-and-nation/7-year-jail-rs-100-crore-fine-soon-for-showing-pok-arunachal-as-disputed/articleshow/52117889.cms">http://economictimes.indiatimes.com/news/politics-and-nation/7-year-jail-rs-100-crore-fine-soon-for-showing-pok-arunachal-as-disputed/articleshow/52117889.cms</a>, accessed 6 May 2016.</p>
<p><strong>[34]</strong> Jaspreet Sahni 'Survey of India files complaint against Google maps for wrong depiction of India's boundaries' (News18, 13 December 2014) <a href="http://www.news18.com/news/india/survey-of-india-files-complaint-against-google-maps-for-wrong-depiction-of-indias-boundaries-731101.html">http://www.news18.com/news/india/survey-of-india-files-complaint-against-google-maps-for-wrong-depiction-of-indias-boundaries-731101.html</a>, accessed 6 May 2016.</p>
<p><strong>[35]</strong> Itanagar agencies, 'Arunachal fumes over wrong map on iPhone4' (Deccan Herald, 04 October, 2010) <a href="http://www.deccanherald.com/content/101784/F">http://www.deccanherald.com/content/101784/F</a>, accessed 6 May 2016.</p>
<p><strong>[36]</strong> CC, 'How Google represents disputed borders between countries' (The Economist, 04 September, 2014) <a href="http://www.economist.com/blogs/economist-explains/2014/09/economist-explains-1">http://www.economist.com/blogs/economist-explains/2014/09/economist-explains-1</a>, accessed 6 May 2016.</p>
<p><strong>[37]</strong> The Kashmir Walla, 'Ten Maps of Kashmir That Angered India' (The Kashmir Walla, 14 May, 2015) <a href="http://thekashmirwalla.com/2015/05/ten-maps-of-kashmir-that-angered-india/">http://thekashmirwalla.com/2015/05/ten-maps-of-kashmir-that-angered-india/</a>accessed 11 May 2016.</p>
<p><strong>[38]</strong> Ibid.</p>
<p><strong>[39]</strong> Ibid.</p>
<p><strong>[40]</strong> Ibid.</p>
<p><strong>[41]</strong> Frank Jacobs, 'The First Google Maps War' (The New York Times, 28 February, 2012) <a href="http://opinionator.blogs.nytimes.com/2012/02/28/the-first-google-maps-war/">http://opinionator.blogs.nytimes.com/2012/02/28/the-first-google-maps-war/</a>, accessed 11 May 2016.</p>
<p><strong>[42]</strong> Ethan Merel, 'Google’s World: The Impact of "Agnostic Cartographers" on the State-Dominated International Legal System' [2016] <em>Columbia Journal of Transnational Law</em> 442-444.</p>
<p><strong>[43]</strong> Ibid.</p>
<p><strong>[44]</strong> Europe, 'Google map gives German harbour to Netherlands' (BBC, 23 February, 2011) <a href="http://www.bbc.com/news/world-europe-12558741">http://www.bbc.com/news/world-europe-12558741</a>, accessed 11 May 2016.</p>
<p><strong>[45]</strong> Supra, 42, 448.</p>
<p><strong>[46]</strong> Ibid, 449.</p>
<p><strong>[47]</strong> Supra, 47.</p>
<p><strong>[48]</strong> <em>J. Mohanraj v (1) Secretary To Government, Delhi; (2) Indian Space Research Organisation, Bangalore; (3) Google India Private Limited, Bangalore, 2008 Indlaw MAD 3562</em>.</p>
<p> </p>
<h2 id="6">6. Author Profile</h2>
<p><strong>Adya Garg</strong> is a law student at West Bengal National University of Juridical Sciences, Kolkata and has completed her second year. An ardent *SRK fan*, and a dancer at heart, she loves reading books in her free time. Always excited about exploring new fields, she never misses an opportunity to work on areas outside her legal curriculum.</p>
<p> </p>
<p>
For more details visit <a href='http://editors.cis-india.org/openness/legal-challenges-to-mapping-in-india-1-laws-policies-cases'>http://editors.cis-india.org/openness/legal-challenges-to-mapping-in-india-1-laws-policies-cases</a>
</p>
No publisherAdya GargGeospatial Information Regulation BillOpen DataOpen Government DataGeospatial DataOpenness2016-05-11T13:43:11ZBlog EntryMonitoring Sustainable Development Goals in India: Availability and Openness of Data (Part I)
http://editors.cis-india.org/openness/monitoring-sustainable-development-goals-in-india-availability-and-openness-01
<b>The Sustainable Development Goals (SDGs) are an internationally agreed upon set of developmental targets to be achieved by 2030. There are 17 SDGs with 169 targets, and each target is mapped to one or more indicators as a measure of evaluation. In this and the next blog post, Kiran AB is documenting the availability and openness of data sets in India that are relevant for monitoring the targets under the SDGs. This post offers the findings for the first 7 Goals, while the next post will cover the last 10.</b>
<p> </p>
<p><em>The second part of the post can be accessed <a href="http://cis-india.org/openness/monitoring-sustainable-development-goals-in-india-availability-and-openness-02/">here</a>.</em></p>
<hr />
<h3>Monitoring Sustainable Development Goals</h3>
<p>The Sustainable Development Goals (SDGs) are an internationally agreed upon set of developmental targets to be achieved by 2030. These are universal goals and targets which involve the entire world, developed and developing countries alike. They aim at integrating and balancing the three dimensions of the sustainable development – economic development, social inclusion, and environmental sustainability. There are <a href="http://sustainabledevelopment.un.org/">17 SDGs with 169 targets</a>, and each target is mapped to one or more indicators as a measure of evaluation, covering a broad range of sustainable development issues <strong>[1]</strong>.</p>
<p>To initiate the visioning process for the SDGs, the United Nations established a High Level Panel in the year 2012, comprising of 27 members. The notion of "data revolution for sustainable development" has been one of the most remarkable categories of imagination and operational requirement to emerge from the final report of this High Level Panel. It identified a significant need for massive restructuring of infrastructures for generating global,
reliable, comparable, and timely data. The Independent Expert Advisory Group (IEAG) on "data revolution for sustainable development" has also raised the need for opening up development data. It proposes that open data must be considered as an instrument of ensuring transparency and accountability of the government <strong>[2]</strong>. Further, in a recent post from the World Economic Forum meeting, Stephen Walker and Jose Alonso have noted that "Not only will governments that embrace open data improve their public accountability and efficiency, they will also reap the social and economic benefits of opening up data for citizens" <strong>[3]</strong>. Opening up of government data is expected to transform the relationship between the government and the various stakeholders.</p>
<p>Currently the data is used by the governmental institutions for self-monitoring and making only a limited data available for public access and usage. But SDGs are not only for the government to monitor and realise, the
responsibility lies with various other actors as well.</p>
<p>Open data has a major role to play in transforming the vision of the SDGs into reality, by enabling the informed participation of multiple actors – private companies, non-government organisations, academic and research institutes, civic activists, etc. To plan, monitor, and actualise the path being traversed by a country, open data becomes essential. Also to facilitate public participation in the governance.</p>
<p>In this and the next blog post, I am documenting the availability and openness of data sets in India, which are relevant for the indicators identified for monitoring of targets under the 17 SDGs. This post offers the findings for the first 7 Goals, while the next post will cover the last 10. Along with questions of availability and openness, I have also documented the technical format of the available data, the level of granularity, and also the frequency of its collection, when applicable. The chart below describe the overall situation of availability and openness of data for monitoring SDGs in India.</p>
<p> </p>
<iframe src="https://cis-india.github.io/charts/2016.02.21_monitoring-SDGs-India_01/index.html" frameborder="0" height="580" width="600"></iframe>
<p> </p>
<h3>Goal #01: <em>End poverty in all its forms everywhere</em></h3>
<p>The data is available for most of the indicators either directly or need to be derived, however, data doesn't exist for one of the indicators.</p>
<p>The data exists at the national level and at the state level or both, but data availability at the district/city level would give a better picture. Though NSSO sample survey data includes representative data at the state/UT level, such data is often not made freely accessible. Not all data which have been collected, i.e., from agencies like NSSO, National Family Health Survey, etc., are open in the public domain.</p>
<p>Also, the frequency of data collected for most of the indicators are either decennial or quinquennial, rather an annual survey would facilitate better/close monitoring. Health is an important measure associated with poverty, but the data is decennially collected. There is a need for regular data updation, while considering those data which are supposed to be collected annually.</p>
<p>In this context, to derive certain indicators, say Indicator 1.3.1., there is a cross agency dependency on data, and lacks disaggregation of data. The disaggregation is a key to measure inequality, especially incidences like poverty. So to monitor poverty we need to identify the different strata of poverty and policy can be formulated accordingly.</p>
<p><strong>Data Not Available:</strong></p>
<ul><li>Indicator 1.3.1. Percentage of population covered by social protection floors /systems disaggregated by sex, and distinguishing children, unemployed, old age, people with disabilities, pregnant women/new-borns, work injury victims, poor and vulnerable</li></ul>
<p> </p>
<h3>Goal #02: <em>End hunger, achieve food security and improved nutrition and promote sustainable agriculture</em></h3>
<p>Indicators and the data corresponding to them reflects two things, what has been done and what has to be done. The data for fifteen indicators mapped to the targets in goal 2 are available for thirteen of the indicators. The data which are available are likely to match the indicator directly or the data has to be derived for most of the indicators. And for the remaining two indicators the data is not available.</p>
<p>For most of the indicators that have to be derived, there is a strong dependency on the dataset from NSSO sample survey for arriving at the requirement. This dependency comes at a cost, as NSSO sample data are not freely available in the public domain, thus making the overall monitoring dependent on closed data. There is a cross agency reliance on data, for arriving at the indicator, and the data on public platform are not up to date.</p>
<p>Also, the data for majority of the indicators are measured at the national as well as state level, but a goal like ending hunger – providing food security, would definitely require data in the order of district/village level. Though data is available for the Indicator 2.2.1: Prevalence of stunting (height for age <-2 SD from the median of the WHO Child Growth Standards) among children under five years of age, but, the data is from eight states only and the national data is derived from it, too small sample size to extrapolate as the nation's data.</p>
<p>On the frequency of data collection, Indicator 2.c.1: Indicator of (food) Price Anomalies (IPA), are collected monthly and some of the data are quinquennial or decennial. However, most of them are annually collected, enabling better accountability and close monitoring of the goals and to frame actionable policy steps.</p>
<p><strong>Data Not Available:</strong></p>
<ul><li>Indicator 2.5.1: Ex Situ Crop Collections Enrichment index</li>
<li>b. Indicator 2.5.2: Percentage of local crops and breeds and their wild relatives, classified as being at risk, not-at-risk or unknown level of risk of extinction</li></ul>
<p> </p>
<h3>Goal #03: <em>Ensure healthy lives and promote well-being for all at all ages</em></h3>
<p>Data is available for all the twenty-five indicators corresponding to the thirteen targets set to measure goal 3 on health and well-being. Some of the data are direct to the indicator, while some have to be derived from various data set to arrive at the indicator.</p>
<p>Data is open and accessible freely in the public domain for all the indicators, most of the data are from World Health Organisation (WHO) database. However, for finer tunings and up to date data there is dependency on National Family Health Survey (NFHS) which is collected decennially.</p>
<p>The WHO data lacks updation and ones which are available are pertaining to an year, thus making the analysis of the annual trend difficult. While the frequency of data collected for most of the data are annual.</p>
<p>The dataset available are at the national and state level, and two of the data set is measured in the order of cities. Most of the WHO dataset provides data at the national level, whereas NFHS, District Family Health Surveys and other agencies provide data at the lowest order, but such dataset are not freely accessible on the public domain. The updated data on health are not made available freely accessible in the public domain which are derived through health surveys.</p>
<p> </p>
<h3>Goal #04: <em>Ensure inclusive and equitable quality education and promote lifelong learning opportunities for all</em></h3>
<p>Education in India is a fundamental right of every citizen, therefore achieving inclusive, equitable and quality education for all becomes necessary. Said this, to monitor goal 4, data is available for nine indicators out of eleven indicators, and for the remaining two indicators, the data is not accessible or in public domain for free access, and for the sub-part of the indicator on proficiency level. Though data exists for all the indicators, however, for most of the indicators we need to derive from multiple sources. Data does not exist for subparts like psychosocial wellbeing, in the Indicator 4.2.1 and proficiency in functional literacy and numeracy skills as in the Indicator 4.6.1.</p>
<p>The data are collected annually for seven indicators and for the two indicators Indicator 4.3.1 and Indicator 4.6.1, which relies on NFHS and Census data respectively, the data is collected decennially. Also, for some of the indicators the data availability is restricted to particular years or are not up to date.</p>
<p>The data which exists are collected at the national and state level for some of them and for some data set the data exists at the national level only, whereas for the Indicator 4.6.1, the data set is of the order of city. And the disaggregation issue prevails here as well, so to sort data based on the given parameter one has to consult NSSO sample survey or derive from the existing data.</p>
<p><strong>Data Not Available:</strong></p>
<ul><li>Indicator 4.7.1: Percentage of 15-year old students enrolled in secondary school demonstrating at least a fixed level of knowledge across a selection of topics in environmental science and geo science. The exact choice/range of topics will depend on the survey or assessment in which the indicator is collected. Disaggregation: sex and location</li>
<li>Indicator 4.a.1: Percentage of schools with access to (i) electricity; (ii) Internet for pedagogical purposes; (iii) computers for pedagogical purposes; (iv) adapted infrastructure and materials for students with disabilities; (v) single-sex basic sanitation facilities; (vi) basic hand washing facilities</li></ul>
<p> </p>
<h3>Goal #05: <em>Achieve gender equality and empower all women and girls</em></h3>
<p>Gender as a social construct has been deprived of equality and equity, therefore, achieving equality and empowering women and girls lays down the path for an inclusive development. In this direction, to monitor the goal 5, data is available for eleven indicators and do not exist for three indicators out of fourteen indicators. However, the Indicator 5.3.2, is not relevant as India does not acknowledge FGM/C. Also, for most of the indicators, the data need to be derived from the given dataset.</p>
<p>For most of the data, the data is collected at the National or state level. Whereas for the Indicator 5.a.1, the data is available at the district/tehasil level and it is based on Agricultural census of India, carried out once in five years.</p>
<p>The collection of data is annual in most cases, decennial in the cases of NFHS data, quinquennial with regard to data on land ownership and rights based on gender. Also, in cases of proportion of women in parliament or number of legal framework – domestic/international, the frequency cannot be determined as its subject to change.</p>
<p>Regarding openness, though data exists, the data is not available to access freely. These data are either from NSSO sample survey and NFHS. For most of the indicators the data exists in general without disaggregation, but, as the goal demands sex based disaggregation, we need to derive from the existing data.</p>
<p><strong>Data Not Available:</strong></p>
<ul><li>Indicator 5.3.2: Percentage of girls and women aged 15-49 who have undergone female genital mutilation/cutting (FGM/C), by age group (for relevant countries only)</li>
<li>Indicator 5.6.2. Number of countries with laws and regulations that guarantee women aged 15-49 access to sexual and reproductive health care, information and education</li>
<li>Indicator 5.c.1: Percentage of countries with systems to track and make public allocations for gender equality and women’s empowerment</li></ul>
<p> </p>
<h3>Goal #06: <em>Ensure availability and sustainable management of water and sanitation for all</em></h3>
<p>Water is a life giving source, but ensuring water and sanitation in a sustainable way is a challenge indeed. Data is available for all the ten indicators to monitor the goal 6. While for most of the indicators the data has to be derived from the given data set or from other data set. The data set available are in absolute numbers, need to modify as per the indicators.</p>
<p>The data is collected annually for most of the indicators, however, for the indicators, Indicator 6.3.2: Percentage of water bodies with good ambient water quality; Indicator 6.4.1: Percentage change in water use efficiency over time, the data pertains to the specific year, without a time series.</p>
<p>Three of the data are measured at the state level, one at the district level – Indicator 6.2.1, and another at the level of cities – Indicator 6.3.1. For most of the indicators, the data are from international agencies like WHO, UNEP, FAO, etc.</p>
<p>The data for four of the indicators are not freely accessible on the public domain, though data exists. Also, for the Indicator 6.a.1, the available data is not specific to it, but gives an overview. Overall, for the close monitoring of the goal 6, the granularity of the data should be at the district/block level, and must be freely accessible.</p>
<p> </p>
<h3>Goal #07: <em>Ensure access to affordable, reliable, sustainable and modern energy for all</em></h3>
<p>Energy is considered one of the basic needs of human life, therefore, providing energy which is reliable and affordable has to ensure sustainability and the kind of energy being produced. The data exists for five of the indicators out of six indicators, however, the data does not exist for one of the indicators. The data for two of the indicators – Indicator 7.2.1, Indicator 7.3.1, have to be derived from the given data set.</p>
<p>For most of the data, the data is collected annually and the data is collected at the national level. However, as to the data availability for the Indicator 7.2.1, the data is available at the state level.</p>
<p>To arrive at the required indicator, there is a dependency over other dataset. Though most of the data are available, for three of the indicators – Indicator 7.2.1: Renewable energy share in the total final energy consumption (%); Indicator 7.3.1. Energy intensity (%) measured in terms of primary energy and GDP; Indicator 7.a.1: Mobilized amount of USD per year starting in 2020 accountable towards the US 100 billion commitment, the data is not freely accessible.</p>
<p><strong>Data Not Available:</strong></p>
<ul><li>Indicator 7.b.1. Ratio of value added to net domestic energy use, by industry</li></ul>
<p> </p>
<h3>References</h3>
<p><strong>[1]</strong> "Indicators and a Monitoring Framework for the Sustainable Development Goals." Sustainable Development Solutions Network. March 20, 2015. Accessed February 16, 2016. <a href="http://unsdsn.org/wp-content/uploads/2015/03/150320-SDSN-Indicator-Report.pdf">http://unsdsn.org/wp-content/uploads/2015/03/150320-SDSN-Indicator-Report.pdf</a>.</p>
<p><strong>[2]</strong> "A World That Counts - Mobilising the Data Revolution for Sustainable Development." Report. Independent Expert Advisory Group Secretariat, 2014. Accessed February 19, 2016.
<a href="http://www.undatarevolution.org/wp-content/uploads/2014/11/A-World-That-Counts.pdf">http://www.undatarevolution.org/wp-content/uploads/2014/11/A-World-That-Counts.pdf</a>.</p>
<p><strong>[3]</strong> Walker, Stephen, and Jose M. Alonso. "Data Will Only Get Us so Far. We Need It to Be Open." World Economic Forum. January 29, 2016. Accessed February 16, 2016. <a href="http://www.weforum.org/agenda/2016/01/data-will-only-get-us-so-far-we-need-it-to-be-open">http://www.weforum.org/agenda/2016/01/data-will-only-get-us-so-far-we-need-it-to-be-open</a>.</p>
<p> </p>
<h3>Author</h3>
<p>Kiran A B, is a student of Master of Public Policy (MPP) at the National Law School of India University, Bengaluru. Kiran has an undergraduate degree in electronics and communications engineering, and he has three years full-time work experience as a software engineer, working in different technological platforms. His research interest includes interdisciplinary linkages between policy, law and technology.</p>
<p> </p>
<p>
For more details visit <a href='http://editors.cis-india.org/openness/monitoring-sustainable-development-goals-in-india-availability-and-openness-01'>http://editors.cis-india.org/openness/monitoring-sustainable-development-goals-in-india-availability-and-openness-01</a>
</p>
No publisherKiran ABOpen DataOpen Government DataData RevolutionOpennessSustainable Development Goals2017-01-02T14:12:58ZBlog EntrySteps towards Integrated Open Water Data
http://editors.cis-india.org/openness/steps-towards-integrated-open-water-data
<b>Multiplicity of data collection agencies, formats, and disclosure practices and conditionalities make it very difficult to access interoperable and open data about water resources and systems in India. Barriers to accessing water data impede not only academic and applied research on related topics but also public consumption of information and critical decision making. DataMeet and CIS are proud to collaborate on identifying and addressing the challenges to open up and integrate data and information in the water sector. Supported by a generous grant from Arghyam, we are undertaking an initial study of open water data resources in India and taking first steps towards developing a Free and Open Source data portal for water resources information in India. Here is an initial note about the project. The key leaders and contributors of this project are Craig Dsouza, Namita Bhatawdekar, Riddhi Munde, and Jinda Sandbhor, all of whom are members of the Pune Chapter of DataMeet.</b>
<p> </p>
<h4>Project website: <a href="https://datameet-pune.github.io/open-water-data/" target="_blank">https://datameet-pune.github.io/open-water-data/</a></h4>
<h4>Contact: <a href="mailto:pune@datameet.org">pune@datameet.org</a></h4>
<hr />
<h2>The problem statement</h2>
<p>Following devastating precipitation of more than 300mm in 24 hours in early December 2015 the city of Chennai was flooded unlike anything it had seen in recent history. A combination of bad urban planning along with heavy precipitation events had made such eventualities all the more likely. But in the case of such storms what parts of the city are likely to flood? What parts will remain unaffected by the deluge. Specific answers to these questions would help city planners plan better for such emergencies.</p>
<p>Only two months after Chennai was waist deep in water, the city of Latur in 2016 ran dry. The Manjara reservoir, on the river of the same name, the city's source of municipal water supply had not a drop left. With more than 4 months left until the rains would replenish the waters of the dam, the city was now reliant on water being transported in bulk via train tankers from more than 300 kms away, news that made daily headlines. The scale of sugarcane cultivation in the region was being called into question.. Was it possible that lowering the allocation of water to irrigation could have preserved enough water for the city's domestic water needs?</p>
<p>Each of these questions call for answers relating to the exact stock of water resources, and how fast the water flows from one part of the water cycle to another. For example, knowing current soil moisture levels and daily precipitation can we estimate groundwater recharge with a high degree of accuracy? If seasonal groundwater fluctuations and river flows in a watershed or sub-basin is known can we estimate actual quantum groundwater footprint of the crop irrigated with groundwater in that river basin? If new industries are being set up in close proximity to each other what might be the effect of these industries on groundwater stocks in the vicinity.</p>
<p> </p>
<h2>Towards an (integrated and open) data solution</h2>
<p>Deriving cause-effect links between the scale of use of water in a particular region and its possible effect on the status of water resources in the vicinity is an extremely difficult exercise because water stocks and flows are affected by so many causal links which need to be studied and quantified in an integrated manner. An integral part of any water resource study is developing a water balance model to estimate water availability and water demand.</p>
<p><strong>Water availability</strong></p>
<ul><li>Precipitation in the form of rainfall and snowfall,</li>
<li>Live storage capacity in reservoirs,</li>
<li>Soil moisture,</li>
<li>Groundwater levels (and fluctuation), and</li>
<li>Surface water flows in rivers.</li></ul>
<p><strong>Water use/demand</strong></p>
<ul><li><strong>Domestic water use:</strong> Human Population x estimated per capita consumption (or prescribed norm for domestic water consumption),</li>
<li><strong>Livestock water use:</strong> Livestock population x estimated per capita requirement,</li>
<li><strong>Agriculture and Forests:</strong> Evapotranspiration data (derived from temperatures (daily/monthly), wind speeds, humidity (daily/monthly), soil moisture & type, type of Agricultural land use, stage of plant growth, and</li>
<li><strong>Industry:</strong> Nature of industry and annual production x water required per unit of production.</li></ul>
<p><strong>Overcoming the data challenge</strong></p>
<p>Unknown to many, reasonably high resolution data does exist of these variables both across space and time, as described in detail below. Much of this data though hasn't been made inter-operable. We need tools to model water data, putting together real-time data for water availability and demand onto one platform that can facilitate discussions around it. However what we have are either proprietary river basin modeling software (expensive) OR free open source tools (programming/skill intensive).</p>
<p>They demand:</p>
<ul><li>knowledge of programming or know-how of technical tools and unavoidably</li>
<li>knowledge of the various data sources (to piece together the puzzle)</li></ul>
<p>What if instead, we had access to a tool, open, free, accessible to everyone through a browser (hence no need to download software) and most importantly intuitive to use and understand to someone with little technical or programming knowledge.</p>
<p> </p>
<h2>What we propose and who is it for?</h2>
<p>To understand and take the first steps towards developing a completely free and open source data portal for water resources information in India.</p>
<p>Different groups would have different kinds of needs for water data. Researchers for instance tend to think of larger scales (river basins, sub-basins) whereas Gram Panchayat members may not think beyond the village or watershed scale. Hence this proposal aims at macro and micro scales, trying to determine needs at each level and enhancing our platform to meet these different needs.</p>
<p>The project will generate:</p>
<ul><li>A <strong>web app prototype</strong> that will collate secondary data,</li>
<li>A <strong>paper</strong> that outlines sources of data, type of data, level to which available (GP, village, etc.) and nature of the source (Paid/ unpaid/ format available etc.), and</li>
<li>A <strong>model WSP format</strong>, along with indications for what data already exists in secondary sources.</li></ul>
<p>The users of this work will be:</p>
<ul><li>Researchers/Journalists in the water sector, and</li>
<li>Gram Panchayat Members (to effectively develop water security plans, monitor and govern their local water resources).</li></ul>
<p> </p>
<h2>Project Team</h2>
<p>The project team is supported by Nisha Thompson (Director, DataMeet) and Sumandro Chattapadhyay.</p>
<h4>Craig Dsouza</h4>
<p>Craig is an independent researcher in the development sector with a keen interest in water resources and agriculture. He has a Master’s degree in Energy and Environmental Policy (2013) and has worked as a researcher with the Society for Promoting Participative Ecosystem Mgmt, undertaking river basin studies in central and eastern India. Craig believes that the democratization of data and tools to derive insights from it holds tremendous potential for addressing issues of inequity and environmental sustainability in India. He contributes to these efforts as co-ordinator of Datameet-Pune, a city chapter of datameet.org.</p>
<p><strong>GitHub:</strong> <a href="https://github.com/craigdsouza">https://github.com/craigdsouza</a><br />
<strong>Twitter:</strong> <a href="https://twitter.com/dsouza_craig">https://twitter.com/dsouza_craig</a><br />
<strong>Website:</strong> <a href="http://unravellingindia.in/">http://unravellingindia.in/</a></p>
<h4>Namita Bhatawdekar</h4>
<p>Namita is a web developer with 10 years of experience developing web applications and web-based data visualizations. She has worked on developing data Visuaizations for corporate businesses as well as in the research sector. She worked with Singapore-MIT Alliance for Research and Development (MIT's research lab in Singapore) as a Data Visualization expert where she visualized simulation outputs of autonomous vehicles to evaluate urban transport policies. Her work was showcased in many national and international conferences. She has a keen interest in solving social problems using data and is part of Datameet Pune, city chapter of datameet.org.</p>
<p><strong>GitHub:</strong> <a href="https://github.com/bnamita">https://github.com/bnamita</a><br />
LinkedIn: <a href="https://www.linkedin.com/in/namitabhatawdekar/">https://www.linkedin.com/in/namitabhatawdekar/</a><br />
<strong>Website:</strong> <a href="https://bnamita.github.io/Portfolio/">https://bnamita.github.io/Portfolio/</a></p>
<h4>Riddhi Munde</h4>
<p>Riddhi is a GIS and Remote Sensing professional with 2.5 yrs of experience. She has a Master's degree in Geoinformatics and Earth Observation from ITC, University of Twente, The Netherlands. Her project experience includes implementing GIS and remote sensing solutions across a number of industries. She is interested in location and remote sensing analytics, ML, Image processing, web based visualizations and is proficient in ArcGIS, QGIS, PostGIS, Web mapping, algorithm development in Python and R and cloud computing. At Datameet she contributes with her know how of remote sensing to further improve data access in water and agriculture.</p>
<p><strong>LinkedIn:</strong> <a href="https://www.linkedin.com/in/riddhimunde/">https://www.linkedin.com/in/riddhimunde/</a></p>
<h4>Jinda Sandbhor</h4>
<p>Jinda Sandbhor is an action researcher associated with Manthan Adhyayan Kendra, Pune, where he works to document and analyze issues related to the water and energy sectors in India. He actively supports socio-political movements in Maharashtra, Odisha and North Karnataka. In the past he has conducted research studies on water conflicts around rivers and major dams, socio-economic impacts of droughts, impacts of coal based thermal power on water and the local environment. He has been associated with the Datameet-Pune chapter since its beginning in 2015 and here seeks to improve access to data on social and environmental subjects.</p>
<p><strong>Website:</strong> <a href="http://jinda.manthan-india.org/author/jinda/">http://jinda.manthan-india.org/author/jinda/</a></p>
<p> </p>
<p>
For more details visit <a href='http://editors.cis-india.org/openness/steps-towards-integrated-open-water-data'>http://editors.cis-india.org/openness/steps-towards-integrated-open-water-data</a>
</p>
No publishersumandroOpen Water DataOpen DataOpen Government DataEnvironmentOpenness2017-11-02T09:58:13ZBlog EntryProtecting the Territory, Killing the Map
http://editors.cis-india.org/openness/protecting-the-territory-killing-the-map
<b>The politics of making and using maps in India has taken a sudden and complex turn with the publication of the draft Geospatial Information Regulation Bill, 2016. Contrary to the expectations arising out of several government schemes that are promoting the development of the new digital economy in India – from start-ups to the ongoing expansion of connectivity network – the Bill seems to be undoing various economic and humanitarian efforts, and other opportunities involving maps. This article by Sumandro Chattapadhyay and Adya Garg was published by The Wire on May 16, 2016.</b>
<p> </p>
<p>Published by and cross-posted from <a href="http://thewire.in/2016/05/16/before-geospatial-bill-a-long-history-of-killing-the-map-in-order-to-protect-the-territory-36453/">The Wire</a>.</p>
<hr />
<p>The global history of cartography is intimately linked with political needs and economic interests, from the public depiction of sovereign territories to navigating treacherous seas to (wrongly) ‘discover’ the land of spices. In India, the politics of making and using maps has taken a sudden and complex turn with the publication of the draft Geospatial Information Regulation Bill, 2016. Contrary to the expectations arising out of several government schemes that are promoting the development of the new digital economy in India – from start-ups to the ongoing expansion of connectivity network – the Bill seems to be undoing various economic and humanitarian efforts, and other opportunities involving maps, by imposing strict guidelines and harsh penalties on the use of maps by private actors, commercial or otherwise.</p>
<p>The <a href="http://mha.nic.in/sites/upload_files/mha/files/GeospatialBill_05052016_eve.pdf">introductory note to the Bill</a> clearly states its primary objective is to ensure the protection of ‘security, sovereignty and integrity of India.’ The concern around ‘security’ is not new when it comes to regulating cartographic activities. It is prominently addressed across the current set of policies and guidelines that govern mapping in India: 1) the National Map Policy, 2005 (“NMP”) and associated guidelines issued by the Survey of India, 2) the Remote Sensing Data Policy, 2011 that regulates satellite-based mapping, and 3) the Civil Aviation Requirement, 2012, which regulates mapping and photography using flights and drones. Protection of ‘sovereignty and integrity,’ however, does not find a mention in any of these map-related policies.</p>
<p>There have of course been several incidents where the government has taken steps (including the temporary blocking of service) against companies that have represented Indian national boundaries that are not in accordance with official maps. Such companies include Google, The Economist, and Al Jazeera. Two companies that have gotten away with no consequences after publicly showing maps of India without certain border regions, interestingly, are <a href="http://www.scoopwhoop.com/news/kashmir-missing-from-india-map/">Facebook</a> and <a href="http://thewire.in/2015/05/14/chinese-state-owned-television-shows-india-map-sans-jammu-kashmir-arunachal-1698/">CCTV</a>.</p>
<p>In the absence of such provisions in the existing map-related policies, thus far, the government has pursued legal action against such ‘anti-national’ depiction of Indian territory under Section 69A of the IT Act, 2000, the Official Secrets Act, 1923 (restricting the collection and sharing of information about ‘prohibited places’), the Customs Act, 1962 (prohibiting the export and import of certain maps), and the Criminal Law (Amendment) Act, 1990.</p>
<p>Though this present Bill has come into public attention rather suddenly, the Indian State has been planning for a comprehensive legal framework for both enabling and restricting mapping, since the coming of the NMP itself. The first avatar of this effort was the Indian Survey Act that was heard about in 2007, but was never made public. More recently, the first report towards the National Geospatial Information Policy (now called the National Geospatial Policy) came out in 2012. Instead of waiting for this comprehensive policy to be discussed and notified, the Bill seems to have come in a hurry to propose a narrowly designed legal instrument. As is often the problem with such precise devices that also want to be exhaustive, the Bill promises much more collateral damage than actual solutions – it ends up killing the map in the name of protecting the territory.</p>
<p>A quick look at case law on map-related disputes informs us about the motivations of the state in enacting this Bill. A major controversy around ‘sovereignty’ in the field of mapping has been about the depiction of international boundaries of India by Google. After several incidents of conflicts between Google’s map makers and the Indian State regarding the depiction of India’s national boundary, the Survey of India filed a police complaint in 2014. As a result, Google presently shows different map tiles to users from India (according to the boundary specified by the Indian State) and different tiles to users from elsewhere. This geo-targeted solution to the depiction of international borders under dispute has been practiced by Google in the case of other countries too, most notably for Nicaragua, Costa Rica, Ukraine and (independent) Crimea.</p>
<p>The internal security concerns have also fuelled conflicts with mapping companies. In 2013, the ‘mapathon’ organised by Google faced a lawsuit for not asking for prior permission from the Survey of India for this exercise in user-contributed mapping. This was preceded by a petition filed by J. Mohanraj in the Madras High Court seeking a complete ban on the Google Earth and Bhuvan (run by ISRO) map applications on the ground that they were both providing information that could be used for planning acts of terror. The petitioner’s argument referred to the provisions of the NMP, and also alleged that such mapping practices violated the individual rights of a person under Article 21 of the Constitution. The court, however, held (2008) that the petitioner was unable to produce any specific “Guidelines/Rules/Law laid down by the Central/State Governments, prohibiting the private organisations or any other individuals to Interactive Mapping Program, covering vast majority of the Planet”.</p>
<p>The trouble with Google re-opened earlier this year as the Pathankot air base was attacked. Incidentally, Vishal Saini, the winner of the 2013 mapathon by Google, contributed to mapping the features of the very same city. Promptly after the attack in January, Lokesh Kumar Sharma filed a case in the Delhi High Court alleging that the availability of sensitive information (from an internal security point-of-view) on Google Maps created security vulnerabilities. In a rather curious manner, the court disposed of the case on February 24, claiming that it has learned from the Additional Solicitor General that ‘steps are in progress to regulate the publication of aerial/satellite geospatial data.’ In hindsight, we see that this was in reference to the draft Bill.</p>
<p>This Bill, evidently, is a product of the Indian State’s inefficient attempts at regulating the making and circulation of maps and geospatial data in digital times. The Bill ends up disregarding the actual features of digital geospatial data and how it forms a fundamental basis (and asset) for today’s digital economy, and, instead, decides to settle for a form of regulation that is much better suited (if at all) to a pre-digital and pre-liberalisation condition. The regulatory measures proposed by the Bill do not only cause worry but also bewilderment. Take for example Section 3 that states that ‘no person shall acquire geospatial imagery or data including value addition of any part of India’ without being expressly given permission for the same or being vetted by the nodal agency set up by the Bill. If implemented strictly, this may mean that you will have to ask for permission and/or security vetting before dropping a pin on the map and sharing your coordinates with your friend or a taxi service. Both involve creating/acquiring geospatial information, and potentially adding value to the map/taxi service as well.</p>
<p>Let’s take an even more bizarre hypothetical situation – the Security Vetting Agency being asked to go through the entire geospatial data chest of Google everyday (or as soon as it is updated) and it taking up to ‘ three months from the date of receipt’ of the data to complete this checking so that Google Maps can tell you how crowded a particular street was three months ago.</p>
<p>Further, a key term that the Bill does not talk about is ‘big data.’ The static or much-slowly-changing geospatial data such as national boundaries and which-military-institute-is-located-where are really the tiny minority of the global geospatial information. The much larger and crucial part is of course the fast-moving big geospatial data – from geo-referenced tweets, to GPS systems of cars, to mobile phones moving through the cities and regions. Addressing such networked data systems, where all data can quite easily be born-georeferenced, and the security and privacy concerns that are engendered by them, should be the ultimate purpose of, and challenge for, a future-looking Geospatial Information Regulation Act.</p>
<p>The present Bill imposes an undesirable bureaucratic structure of licenses and permits upon the GIS industry in the country in particular, and on all sections of the economy using networked devices in general. This will only end up restricting the size of the GIS industry to a few dominant players. For all creators and users of maps for non-commercial, developmental, and humanitarian interests, this Bill appears to be an imminent threat, even if it is never actually applied.</p>
<p> </p>
<p>
For more details visit <a href='http://editors.cis-india.org/openness/protecting-the-territory-killing-the-map'>http://editors.cis-india.org/openness/protecting-the-territory-killing-the-map</a>
</p>
No publishersumandroGeospatial Information Regulation BillOpen DataOpen Government DataGeospatial DataOpenness2016-05-17T10:37:14ZBlog EntrySurvey of Estimates of Economic Value of Open Government Data
http://editors.cis-india.org/openness/survey-of-estimates-of-economic-value-of-open-government-data
<b>This is a survey of estimates of economic value of open government data, and public sector information in general, across regions, countries, and sectors offered by several reports published during the last decade. The survey is undertaken by Ömer Faruk Sarı, a student of Business Administration at Koc University in Istanbul, Turkey, and research intern with CIS. </b>
<p> </p>
<h2>Introduction</h2>
<p>This is a survey of economic value estimates of open government data, and public sector information in general, by consultancy groups and government bodies across the world. The first part of the post lists estimates from different regions and countries, while the second part collects estimates for different sectors. Major reports surveyed in this study include the 'MEPSIR: Measuring European Public Sector Information Resources' report (2006), 'The Value of Spatial Information' report by ACIL Tasman (2008), 'Review of Recent Studies on PSI Re-Use and Related Market Developments' report by Graham Vickery (2012), 'Market Assessment of Public Sector Information' report by Deloitte (2013), 'Open Data: Unlocking Innovation and Performance with Liquid Information' by McKinsey (2013), 'Big and Open Data in Europe: A Growth Engine or a Missed Opportunity?' by Warsaw Institute for Economic Studies (2014), and 'Open for Business: How Open Data can Help Achieve the G20 Growth Target' report by Omidyar Network (2014).</p>
<p><strong>Note about Exchange Rate:</strong>The monetary values stated in these reports vary by years and currencies. The original estimates are mentioned in the currency concerned followed by the converted amount in US Dollar (using exchange rate of the same year) provided within brackets. The exchange rates concerned are mentioned at the bottom of the post.</p>
<p> </p>
<h2>Countries and Regions</h2>
<h3>Global</h3>
<p>McKinsey estimates global economic value of open data as USD 3.2 Trillion for seven sectors - Education, Transportation, Consumer Products, Electricity, Oil and Gas, Healthcare, and Consumer Finance. [1]</p>
<h3>European Union</h3>
<p>Pira International Ltd. et al, in 2000, estimated the monetary value of open data for EU countries as EUR 68 Billion (USD 76 Billion). [2]</p>
<p>Zangenberg and Company, estimated this number for EU countries as for minimum EUR 29 Billion (USD 38 Billion) and for an upper limit of EUR 143 Billion (USD 188 Billion). [3]</p>
<p>The Warsaw Institute for Economic Studies (WISE Institute) estimates the economic value of open data in EU, as increase in GDP by 2020, as EUR 206 Billion (USD 253 Billion). [4]</p>
<p>Graham Vickery estimated this number as EUR 200 Billion (USD 264 Billion) in 2012. [5]</p>
<p>In 2006, MEPSIR, in their report for European Commission, mentioned EUR 27 Billion (USD 36 Billion) could be gained by use of open data. [6]</p>
<p>McKinsey, in their report in 2013, estimated the monetary value of open data for EU countries as USD 900 Billion. [1]</p>
<iframe src="http://ajantriks.github.io/cis/charts/2015.08_open-data-value-eu/index.html" frameborder="0" height="300" width="700"></iframe>
<h3>G20</h3>
<p>For G20 countries taken together, Omidyar Network estimates the economic value of open data as USD 2.6 Trillion. [7]</p>
<h3>Australia</h3>
<p>Omidyar Network, in their study on business value of open data, estimated the potential of open data for Australia as AUD 3.4 Billion (USD 2.8 Billion). [7]</p>
<p>In 2008, ACIL Tasman estimated the potential economic value of open data for Australia as AUD 1.4 Billion (USD 938 Million). [8]</p>
<p>John Houghton's estimation for the monetary value of open data is AUD 195 Million (USD 197 Million). [9]</p>
<h3>Denmark</h3>
<p>Zangenberg and Company, in 2011, estimated the economic value of open data for Denmark as DKK 520 Million (USD 92 Million). [3]</p>
<h3>France</h3>
<p>SerdaLAB, in 2009, estimated EUR 1.57 Billion (USD 2.3 Billion) can be gained by open data in France. [10]</p>
<h3>Germany</h3>
<p>In 2011, Dr, Martin Fornefeld et al estimated the economic value of open data for Germany as EUR 1.7 Billion (USD 2.2 Billion), only for geo-information. [11]</p>
<p>The POPSIS study estimated this number as EUR 3.2 Million (USD 4.2 Million), in the same year, 2011. [12]</p>
<h3>Norway</h3>
<p>Graham Vickery's report mentions the potential value of open data as NOK 260 Million (USD 43 Million). [5]</p>
<h3>Spain</h3>
<p>The Proyecto Aporta (Spanish open data portal project) study estimated the economic value of the infomediary sector in Spain as EUR 330-550 Million (USD 452-753 Million), in 2012. [13]</p>
<h3>The Netherlands</h3>
<p>In 2011, the POPSIS study estimated the economic potential that can be gained from open data in Netherlands as EUR 78 Million (USD 102 Million). [12]</p>
<h3>United Kingdom</h3>
<p>Deloitte, in their report, estimated the value of open data as GBP 6.2-7.2 Billion (USD 10-11.8 Billion) for United Kingdom. [14]</p>
<p>Rufus Pollock, in 2011, estimated GBP 4.5-6 Billion (USD 7-9.3 Billion) that can be unlocked by use of open data. [15]</p>
<p>Dot-Econ's estimation for monetary value of open data in United Kingdom is EUR 590 Million (USD 778 Million). [16]</p>
<h3>United States</h3>
<p>McKinsey's estimation, in 2013, for the value that can be unlocked by open data in United States is quite remarkable at USD 1.1 Trillion. [1]</p>
<p>Pira International Ltd. et al, in 2000, estimated the value as EUR 750 Billion (USD 838 Billion). [2]</p>
<p> </p>
<h2>Data Types and Sectors</h2>
<h3>Consumer Finance</h3>
<p>McKinsey estimates USD 210-280 Billion, globally, for the consumer finance sector. [1]</p>
<p><strong>Based on McKinsey's Report:</strong> The estimate for G20 countries is USD 169 Billion; for Australia, the estimate is AUD 4.2 Billion (USD 4.3 Billion).</p>
<h3>Consumer Products</h3>
<p>Across the globe, with the use of open data McKinsey estimates USD 520-1470 Billion can be generated from services of consumer products. [1]</p>
<p><strong>Based on McKinsey's Report:</strong> G20 countries, in total, have a potential value of USD 419 Billion for this sector; the value is estimated at AUD 10 Billion (USD 10.2 Billion) for Australia.</p>
<h3>Education</h3>
<p>McKinsey estimates that USD 890-1180 Billion can be generated alone in education sector, across the globe. [1]</p>
<p><strong>Based on McKinsey's Report:</strong> Open data in the education sector in G20 countries can generate USD 717 Billion; for Australia, value of open data in education sector is estimated to be AUD 14 Billion (USD 14.2 Billion).</p>
<h3>Electricity</h3>
<p>McKinsey estimates USD 340-580 Billion, across the globe. [1]</p>
<p><strong>Based on McKinsey's Report:</strong> For electricity sector, USD 193 Billion is estimated for G20 countries; estimate for Australia for electricity sector depending on open data is AUD 6.7 Billion (USD 6.8 Billion).</p>
<h3>Geospatial Data</h3>
<p>Dr. Nam D. Pham estimates the potential value of Geo-spatial information in US as USD 96 Billion. [17]</p>
<p>In the report by Pira International Limited et al, the economic value of geo-spatial information in EU estimated as EUR 36 Billion (USD 40 Billion). [2]</p>
<p>Fornefeld et al estimates the value of geo-spatial information in Germany as EUR 1.7 Billion (USD 2.2 Billion). [11]</p>
<p>The POPSIS study estimates the economic value of Meteorological data re-use market in Netherlands as EUR 10 Million (USD 13 Million). [12]</p>
<p>Graham Vickery estimates (in 2012) NOK 72 Million (USD 12 Million) can be generated in Norway through geo-spatial information. [5]</p>
<p>The Proyecto Aporta study estimates potential value of geo-spatial information in Spain as EUR 183 Million (USD 240 Million). [13]</p>
<p>ACIL Tasman in their report, estimated that as a direct result of the uptake of spatial technologies New Zealand’s real GDP increased by NZD 1.2 Billion (USD 670 Million) in 2008 through productivity-related gains as a result of the increasing adoption of modern spatial information technologies since 1995. [8]</p>
<p>In the United Kingdom, a 'supply-side' assessment estimated the market size and growth potential for geographic information (GI) products and services. The market size in year 2007 was estimated to be GBP 657 Million (USD 1.32 Billion). [18]</p>
<p>Based on PwC's study in 2010, John Houghton estimates the value of spatial data in Australia as AUD 25 Million (USD 25.3 Million). [9]</p>
<p>Ordnance Survey of UK estimates the economic value of open data published by the same agency as GBP 2.9-6.1 Million (USD 4.5-9.5 Million). [19]</p>
<iframe src="http://ajantriks.github.io/cis/charts/2015.08_open-geo-data-value/index.html" frameborder="0" height="400" width="700"></iframe>
<h3>Healthcare</h3>
<p>Globally, USD 300-450 Billion is the estimate of McKinsey, depending on open data use in healthcare sector.[1]</p>
<p><strong>Based on McKinsey's Report:</strong> Open data in the healthcare sector can generate USD 242 Billion for G20 countries; estimate for Australia is AUD 5.9 Billion (USD 6 Billion).</p>
<h3>Oil and Gas</h3>
<p>McKinsey estimates USD 240-510 Billion that can be generated through open data for the oil and gas sector, across the globe. [1]</p>
<p><strong>Based on McKinsey's Report:</strong> Oil and gas sector, with the use of open data, can generate USD 169 Billion for G20 countries; the value for Australia is estimated to generate AUD 4.8 Billion (USD 4.9 Billion).</p>
<h3>Transportation</h3>
<p>McKinsey estimates the value of transportation sector with the use of open data as USD 720-920 Billion for the transportation sector, globally. [1]</p>
<p><strong>Based on McKinsey's Report:</strong> G20 countries altogether can generate USD 580 Billion in transportation sector; estimate of the value of open data in the transportation sector in Australia is AUD 18 Billion (USD 18.2 Billion).</p>
<p> </p>
<h2>Reference</h2>
<p>[1] Manyika, James, et al. 2013. Open Data: Unlocking Innovation and Performance with Liquid Information. McKinsey Global Institute. October. Accessed from <a href="http://www.mckinsey.com/insights/business_technology/open_data_unlocking_innovation_and_performance_with_liquid_information">http://www.mckinsey.com/insights/business_technology/open_data_unlocking_innovation_and_performance_with_liquid_information</a>.</p>
<p>[2] Pira International Ltd. et al. 2000. Commercial exploitation of Europe’s Public Sector Information - Executive Summary. European Commission, Brussels. Aceeseed from <a href="ftp://ftp.cordis.europa.eu/pub/econtent/docs/2000_1558_en.pdf">ftp://ftp.cordis.europa.eu/pub/econtent/docs/2000_1558_en.pdf</a>.</p>
<p>[3] Zangenberg and Company. 2011, Kvantificering af værdien af åbne offentlige data (Quantifying the Value of Open Government Data). Report Prepared for the Danish National Information Technology and Telecom Agency. Accessed from <a href="https://digitaliser.dk/resource/1021067/artefact/Kvantificering+af+den+erhvervsm%c3%a6ssige+v%c3%a6rdi+af+%c3%a5bne+offentlige+data+-+Zangenberg2011.pdf">https://digitaliser.dk/resource/1021067/artefact/Kvantificering+af+den+erhvervsm%c3%a6ssige+v%c3%a6rdi+af+%c3%a5bne+offentlige+data+-+Zangenberg2011.pdf</a>.</p>
<p>[4] Buchholtz, Sonia, et al. 2014. Big and Open Data in Europe: A Growth Engine or a Missed Opportunity? demosEUROPA – Centre for European Strategy and Warsaw Institute for Economic Studies. Accessed from <a href="http://www.bigopendata.eu/wp-content/uploads/2014/01/bod_europe_2020_full_report_singlepage.pdf">http://www.bigopendata.eu/wp-content/uploads/2014/01/bod_europe_2020_full_report_singlepage.pdf</a>.</p>
<p>[5] Vickery, Graham. 2012. Review of Recent Studies on PSI Re-Use and Related Market Developments. European Commission, Brussels. Accessed form <a href="http://ec.europa.eu/information_society/newsroom/cf//document.cfm?doc_id=1093">http://ec.europa.eu/information_society/newsroom/cf//document.cfm?doc_id=1093</a>.</p>
<p>[6] Dekkers, Makx, et al. 2006. MEPSIR: Measuring European Public Sector Information Resources - Final Report of Study on Exploitation of Public Sector Information – Benchmarking of EU Framework Conditions. European Commission, Brussels. Accessed from <a href="http://ec.europa.eu/information_society/newsroom/cf/document.cfm?doc_id=1198">http://ec.europa.eu/information_society/newsroom/cf/document.cfm?doc_id=1198</a>.</p>
<p>[7] Lateral Economics. 2014. Open for Business: How Open Data can Help Achieve the G20 Growth Target. Omidyar Network. June. Accessed from <a href="https://www.omidyar.com/sites/default/files/file_archive/insights/ON%20Report_061114_FNL.pdf">https://www.omidyar.com/sites/default/files/file_archive/insights/ON%20Report_061114_FNL.pdf</a>.</p>
<p>[8] ACIL Tasman. 2008. The Value of Spatial Information: The Impact of Modern Spatial Information
Technologies on the Australian Economy. March. Accessed from <a href="http://www.crcsi.com.au/assets/Resources/7d60411d-0ab9-45be-8d48-ef8dab5abd4a.pdf">http://www.crcsi.com.au/assets/Resources/7d60411d-0ab9-45be-8d48-ef8dab5abd4a.pdf</a>.</p>
<p>[9] Houghton, John. 2011. Costs and Benefits of Data Provision. Report to the Australian National Data Service. September. Accessed from <a href="http://www.ands.org.au/resource/houghton-cost-benefit-study.pdf">http://www.ands.org.au/resource/houghton-cost-benefit-study.pdf</a>.</p>
<p>[10] Guerre, Louise, et al. 2009. Le marché de l’information électronique professionnelle en France. SerdaLAB. Presentation at CCIP on January 27. Accessed from <a href="http://www.fnps.fr/Public/Article/File/DOCUMENTS/Presentation_ET_IEP09_270109.pdf">http://www.fnps.fr/Public/Article/File/DOCUMENTS/Presentation_ET_IEP09_270109.pdf</a>.</p>
<p>[11] Fornefeld, Martin, et al. 2011. Die europäische Gesetzgebung als Motor für das deutsche GeoBusiness (European Legislation as a Driver for German GeoBusiness). Accessed from <a href="http://www.micus.de/pdf/MICUS_GeoBusiness-BMWi.pdf">http://www.micus.de/pdf/MICUS_GeoBusiness-BMWi.pdf</a>.</p>
<p>[12] Citadel Consulting et al. 2011. POPSIS: Pricing Of Public Sector Information Study - Models of Supply and Charging for Public Sector Information (ABC) - Final Report. European Commission. October. Accessed from <a href="http://ec.europa.eu/newsroom/dae/document.cfm?doc_id=1158">http://ec.europa.eu/newsroom/dae/document.cfm?doc_id=1158</a>.</p>
<p>[13] Ministry of Finance and Public Administration et al. 2012. Characterization Study of the Infomediary Sector. Proyecto Aporta. Accessed from <a href="http://datos.gob.es/sites/default/files/files/Estudio_infomediario/121001%20RED%20007%20Final%20Report_2012%20Edition_vF_en.pdf">http://datos.gob.es/sites/default/files/files/Estudio_infomediario/121001%20RED%20007%20Final%20Report_2012%20Edition_vF_en.pdf</a>.</p>
<p>[14] Deloitte. 2013. Market Assessment of Public Sector Information. Report to the Department for Business, Innovation and Skills, Government of UK. Accessed from <a href="https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/198905/bis-13-743-market-assessment-of-public-sector-information.pdf">https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/198905/bis-13-743-market-assessment-of-public-sector-information.pdf</a>.</p>
<p>[15] Pollock, Rufus. 2010. Welfare Gains from Opening up Public Sector Information in the UK. University of Cambridge. Accessed from <a href="http://rufuspollock.org/economics/papers/psi_openness_gains.pdf">http://rufuspollock.org/economics/papers/psi_openness_gains.pdf</a>.</p>
<p>[16] DotEcon. 2006. The Commercial Use of Public Information (CUPI). Report OFT861. Office of Fair Trading, Government of UK. Accessed from <a href="http://www.opsi.gov.uk/advice/poi/oft-cupi.pdf">http://www.opsi.gov.uk/advice/poi/oft-cupi.pdf</a>.</p>
<p>[17] Pham, Nam D. 2011. The Economic Benefits of Commercial GPS Use in the U.S. and the Costs of Potential Disruption. June. Accessed from <a href="http://www.gpsalliance.org/docs/GPS_Report_June_21_2011.pdf">http://www.gpsalliance.org/docs/GPS_Report_June_21_2011.pdf</a>.</p>
<p>[18] Coote, Andrew, and Les Rackham. 2008. An Assessment of the Size and Prospects for Growth of the UK Market for Geographic Information Products and Services. ConsultingWhere. Accessed from <a href="http://www.consultingwhere.com/wp-content/uploads/resources/UK_Market_Assessment_v11_Final.pdf">http://www.consultingwhere.com/wp-content/uploads/resources/UK_Market_Assessment_v11_Final.pdf</a>.</p>
<p>[19] Carpenter, John, and Phil Watts. 2013. Assessing the Value of OS OpenData™ to the Economy of Great Britain - Synopsis. Ordnance Survey. June. Accessed from <a href="https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/207692/bis-13-950-assessing-value-of-opendata-to-economy-of-great-britain.pdf">https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/207692/bis-13-950-assessing-value-of-opendata-to-economy-of-great-britain.pdf</a>.</p>
<p> </p>
<h2>Exchange Rates</h2>
<p>Note: Exchange rates are taken for December of the year concerned.</p>
<table>
<tbody>
<tr>
<th>Euro per 1 US Dollar</th>
</tr>
<tr>
<td>2000</td>
<td>0.8947</td>
</tr>
<tr>
<td>2006</td>
<td>0.7580</td>
</tr>
<tr>
<td>2009</td>
<td>0.6868</td>
</tr>
<tr>
<td>2010</td>
<td>0.7562</td>
</tr>
<tr>
<td>2011</td>
<td>0.7599</td>
</tr>
<tr>
<td>2013</td>
<td>0.7296</td>
</tr>
<tr>
<td>2014</td>
<td>0.8123</td>
</tr>
<tr>
<th>British Pound per 1 US Dollar</th>
</tr>
<tr>
<td>2006</td>
<td>0.5095</td>
</tr>
<tr>
<td>2011</td>
<td>0.6415</td>
</tr>
<tr>
<td>2013</td>
<td>0.6106</td>
</tr>
<tr>
<td>2014</td>
<td>0.6397</td>
</tr>
<tr>
<th>Australian Dollar per 1 US Dollar</th>
</tr>
<tr>
<td>2008</td>
<td>1.4919</td>
</tr>
<tr>
<td>2011</td>
<td>0.9874</td>
</tr>
<tr>
<td>2014</td>
<td>1.2144</td>
</tr>
<tr>
<th>New Zealand Dollar per 1 US Dollar</th>
</tr>
<tr>
<td>2008</td>
<td>1.7923</td>
</tr>
<tr>
<th>Norwegian Krone per 1 US Dollar</th>
</tr>
<tr>
<td>2010</td>
<td>5.9774</td>
</tr>
<tr>
<th>Danish Krone per 1 US Dollar</th>
</tr>
<tr>
<td>2011</td>
<td>5.6495</td>
</tr>
</tbody>
</table>
<p> </p>
<p>
For more details visit <a href='http://editors.cis-india.org/openness/survey-of-estimates-of-economic-value-of-open-government-data'>http://editors.cis-india.org/openness/survey-of-estimates-of-economic-value-of-open-government-data</a>
</p>
No publisherÖmer Faruk SarıOpen Government DataDigital EconomyOpen DataEconomicsOpenness2015-08-22T08:42:30ZBlog EntryWorkshop on Open Data for Human Development - Sessions Report
http://editors.cis-india.org/openness/workshop-on-open-data-for-human-development-2015-06-report
<b>CIS facilitated a workshop on open data policy and tools for government officials from Sikkim, Meghalaya, and Tripura, and those from Bhutan and Maldives, in June 2015. The workshop was co-facilitated with Akvo, DataMeet, and Mapbox, and was supported by International Centre for Human Development of UNDP India. Here we share the workshop report and other related documents. The report is written by Sumandro, along with Amitangshu Acharya of Akvo.</b>
<p> </p>
<h2>Day 01, June 03, 2015</h2>
<p>The first day of the workshop began with <a href="https://en.wikipedia.org/wiki/Prem_Das_Rai"><strong>Mr. Prem Das Rai</strong></a>, Honourable MP, Loksabha, Sikkim, briefly addressing the participants. He contextualised the workshop against the background of technological changes and emerging opportunities of governance through effective usages of data. <a href="https://en.wikipedia.org/wiki/A._K._Shiva_Kumar"><strong>Dr. A.K. Shiva Kumar</strong></a>, Director of the <a href="http://www.undp.org/content/india/en/home/operations/projects/human-development/the-international-centre-for-human-development.html">International Centre for Human Development (IC4HD)</a>, UNDP India, welcomed the participants and initiated a panel discussion on data, ICTs and governance. The panel had three speakers: <a href="https://twitter.com/SrivatsaKrishna"><strong>Mr. Srivatsa Krishna</strong></a>, IAS and Secretary, <a href="https://www.bangaloreitbt.in/">Department of Information Technology, Biotechnology, and Science and Technology</a>, Government of Karnataka; <a href="http://www.cgg.gov.in/adg_profile.html"><strong>Dr. B. Gangaiah</strong></a>, Additional Director General, <a href="http://www.cgg.gov.in/">Centre for Good Governance</a>, Hyderabad; and <a href="https://twitter.com/sunil_abraham"><strong>Sunil Abraham</strong></a>, Executive Director, <a href="http://cis-india.org/">the Centre for Internet and Society</a>, Bengaluru and Delhi.</p>
<p><strong>Mr. Krishna</strong> spoke about the strategies adopted in setting up IT and ITES clusters in Cyberabad, Andhra Pradesh and in Bengaluru, Karnataka. He noted that tax cuts and accelerated land allocation are key to incentivising the private sector to set up IT and ITES units. Another major concern is that of ensuring supply of good quality IT workers. He also emphasised on the need for governments to build effective public facing electronic services - either in the form of Nemmadi Kendras, where people can physically go to access various government services, or in the form of mobile applications that bring different civic services into one digital interface, like <a href="https://www.bangaloreone.gov.in/public/default.aspx">Bangalore One</a> and <a href="https://www.mobile.karnataka.gov.in/goken/login.aspx">Karnataka Mobile One</a>.</p>
<p><strong>Dr. Gangaiah</strong> gave an extensive overview of the idea and applications of open data in the contexts of governance and development. He noted that government data (in India) often suffers from criticisms related to quality, as well as the lack of availability of the same in public domain. The key problems, he identified, for opening up government data in India are that most often the data is collected by a government agency for a very specific purpose, and the steps required to ensure wider circulation and use of the same is not taken (such as lack of documentation and interoperability of data); and that the government agencies most often consider the collected data as a source of power, and hence as something to be retained and not disclosed in full details. The slides from Dr. Gangaiah’s presentation can be accessed <a href="https://drive.google.com/file/d/0B7xi0bhhq-OxcGs3UndvWDZJMlk/view?usp=sharing">here</a>.</p>
<p><strong>Mr. Abraham</strong>’s presentation highlighted several areas of concern when deploying data-driven techniques and solutions for human development challenges. He described how the current phase of open data discussions by central and state governments in India represent the third phase of ‘openness’ in governance in India. While the first phase focused on usage of Free/Libre Open Source Softwares in building electronic governance applications and information systems, the second phase involved embracing of open software standards and formats across government information systems and IT solutions. It is very important to note that with the third phase of openness focusing on opening up of data and information, both of these earlier foci of free and open source softwares, and open standards and interoperability are returning as complementary components to ensure seamless publication of open government data. However, he argued, when deploying data-driven techniques and solutions for human development challenges, it is imperative to remember three things: 1) collection of data is a time- and effort-consuming task, and hence must be optimised so as to not to take away time and effort from actual developmental interventions, 2) bad quality of development data is a structural problem, often emanating from the data being not useful to the person actually collecting it, and 3) availability of data does not automatically change or open up the process of decision-making.</p>
<p>The second session of the day started with a detailed presentation by <strong>Mr. T. Samdup</strong>, Joint Director, Department of Information Technology, Government of Sikkim, on the context, the making, and the salient features of the <a href="http://www.sikkim.gov.in/stateportal/Link/SODAAP%20Policy%20Document.pdf">Sikkim Open Data Acquisition and Accessibility Policy (SODAAP)</a>, 2014. He explained that the Policy mandates setting up of an online state data portal that will host all data sets generated by various agencies of the Government of Sikkim, and making such data available, subject to concerns of privacy and security, across all state government agencies and the citizens in general. The key needs driving this Policy have been that for availability of accurate and timely data on various aspects of human development in the state, as well as for reducing expenses and confusions due to duplication of data collection efforts. The slides from Mr. Samdup’s presentation can be accessed <a href="https://drive.google.com/file/d/0B7xi0bhhq-OxcktuMm0tTGFMWHc/view?usp=sharing">here</a>.</p>
<p>The presentation by <strong>Mr. Samdup</strong> was followed by one by <a href="https://twitter.com/ajantriks"><strong>Mr. Sumandro Chattapadhyay</strong></a> of the Centre for Internet and Society on an initial set of questions and concerns that should be addressed by the implementation plan of the SODAAP. He took a detailed look at the four objectives mentioned in the Policy document, and discussed what tasks, decisions, and deliberations are needed to achieve each of those. In conclusion, he listed a set of core components of the implementation process that must also be discussed in the implementation plan document, namely: 1) governance and oversight structure for implementation, 2) incentivising government personnel for opening up data across departments, including financial support for the same, 3) metadata, documentation of data collection process, and implementing unique identifiers, and 4) developing processes of sharing of data between the Union and the state government, especially in reference to national Management Information Systems. The slides from Mr. Chattapadhyay’s presentation can be accessed <a href="https://drive.google.com/file/d/0B7xi0bhhq-OxNUVGM1ZqcGhiUUU/view?usp=sharing">here.</a></p>
<p>These presentations were followed by a general discussion on various aspects of the SODAAP and the challenges to be overcome during its implementation. This session provided a general introduction to the SODAAP, especially for workshop participants who are not from Sikkim, and also set up the key questions to be discussed and answered while preparing the first draft of the SODAAP implementation plan.</p>
<p>After the second session ended, the participants were asked to individually write down the key challenges they identify for the implementation process of SODAAP. These responses were compiled by Sumandro and made available as a reference document for the implementation plan. The chart below summarises these responses.</p>
<p><iframe src="http://ajantriks.github.io/cis/charts/2015.08_sodaap-challenges/index.html" frameborder="0" height="400" width="700"></iframe></p>
<p> </p>
<p>In the third session of the day, <a href="https://twitter.com/joycarpediem"><strong>Joy Ghosh</strong></a> and <a href="https://twitter.com/amitangshu"><strong>Amitangshu Acharya</strong></a> of <a href="http://akvo.org/">Akvo</a> talked about the challenges of collecting structured born-digital data from the grassroots level, and how using mobile-based applications, like <a href="http://akvo.org/products/akvoflow/">Akvo FLOW</a>, can address such challenges. Akvo FLOW runs on all Android-based smartphones, and allows ground level development workers to directly feed data into the phone, as well as collect related materials like GPS location and photographs, based upon a form that is centrally designed and downloaded into their phones by the development workers. The data is then kept in the phone till it is sent back to the main server, where data coming from all different surveyors using the same form is shown on a map-based interface for easy navigation of the data across space and time. In this session, Mr. Acharya first introduced the participants to the issues around digital data collection, touching upon issues of ethics, capacity, prioritisation of data collection process along with tools. Mr. Ghosh then took over to describe the functioning of the tool, and then distributed several smartphones, pre-loaded with Akvo FLOW, among the participants for an applied data collection exercise where the participants walked around the NIAS campus and collected data using the FLOW interface. They returned to see their data mapped and analysed on the online dashboard. Their presentation can be accessed <a href="https://drive.google.com/file/d/0B0kFsiLLpy0XdDM2TE5tckE5Zlk/view?usp=sharing">here</a>.</p>
<p> </p>
<h2>Day 02, June 04, 2015</h2>
<p>The second day started with two consecutive presentations by <a href="https://twitter.com/thej"><strong>Mr. Thejesh GN</strong></a> of <a href="http://datameet.org/">DataMeet</a>, and <a href="https://twitter.com/Sramach9"><strong>Mr. Sivaram Ramachandran</strong></a> of <a href="http://mapbox.com/">Mapbox</a> on the tools and techniques for working with statistical data and with geospatial data, respectively. The former presentation took the participants through the stages of working with statistical data: from collecting and finding data, to cleaning and validating, and finally analysing the data. Various free and open source tools for each of these stages were also discussed in brief, such as <a href="https://pdftables.com/">PDF Tables</a><a> and </a><a href="http://tabula.technology/">Tabula</a> for converting PDF tables to spreadsheets, <a href="http://openrefine.org/">Open Refine</a> for cleaning data, and <a href="http://app.raw.densitydesign.org/">RAW</a> and <a href="https://datawrapper.de/">DataWrapper</a> for generating web-based dynamic charts. The latter presentation explored the various ways in which geospatial data can be used to inform and support decision-making, and the tools that can be used to render and present geospatial data in forms that are accessible for decision-makers within government and also for individual users. Mr. Ramachandran presented the various free and open source tools available for working with geospatial data, such as <a href="https://www.mapbox.com/mapbox-studio/">Mapbox Studio</a>, <a href="http://qgis.org/en/site/">Quantum GIS</a>, and <a href="http://leafletjs.com/">Leaflet JS</a>. He also gave a brief introduction to <a href="http://openstreetmap.org/">OpenStreetMap</a>, the wiki-like user-contributed global map data platform. Both the presentations can be accessed <a href="http://thejeshgn.com/presentations/Data_Journalism_Workshop.html">here</a> and <a href="https://drive.google.com/file/d/0B7xi0bhhq-OxQTB3eVpjNmtTUDg/view?usp=sharing">here</a>, respectively. After this session, the participants were divided into two groups. One group engaged further with tools and techniques of working with statistical and geospatial data. The second group took part in a series of exercises to identify and document the current data flows and bottlenecks thereof across several key departments of Government of Sikkim.</p>
<p>The group engaging in applications of various software tools for working with statistical and geospatial data was facilitated by <strong>Mr. Thejesh</strong> and <strong>Mr. Ramachandran</strong>. This group worked with a sample statistical data set, taking it across the stages of finding, cleaning, analysing, and visualising as discussed earlier. The participants used the online version of <a href="http://www.tableau.com/">Tableau</a> to create dynamic charts. Afterwards, they were introduced to various methods of contributing and downloading data from the OpenStreetMap, including directly adding data points through the online editor named <a href="http://wiki.openstreetmap.org/wiki/ID">iD</a>. The participants went out in the NIAS campus to collect geospatial data about various natural and human-made features of the campus, such as trees, pathways, etc.</p>
<p>The second group working on documenting data flows and identifying bottlenecks was facilitated by <strong>Mr. Chattapadhyay</strong>, <strong>Mr. Acharya</strong>, and <strong>Ms. Rajashi Mukherjee</strong> from Akvo. The group was further divided into department-wise teams, one each for the Department of Health, the Department of Economic Statistics, Monitoring, and Evaluation (DESME), the Human Resource Development Department (HRDD), and representatives from Gram Panchayat Units. The exercise began with each of the teams discussing and drawing the flow of data for one of the major data set maintained by the agency concerned. The data flows were drawn by identifying key moments of its processing (such as primary collection, verification, digitisation, analysis, storage, reporting, etc.), the actors involved in that moment, the tools and data formats relevant for each moment, and which agency finally stores and uses the data. Once these processes were described on paper, the next part of the exercise focused on identifying which challenges exist at which part of these data flows. This was followed up by a ranking of all these challenges, in terms of how critically they affect the ability of the agency concerned to use and share the final data. All the teams worked separately, and conversed with the facilitators as needed, to develop the data flow diagrams and identify the key challenges.</p>
<p>The major common challenges noted by these teams were: <strong>1)</strong> delays in collection, verification, and digitisation of data, <strong>2)</strong> inability of state government agencies to access data collected as part of centrally-funded welfare schemes, and <strong>3)</strong> parallel systems of data collection employed by different departments leading to duplication of efforts and data.</p>
<p>Several interesting insights came through in this exercise. For example, data related to education is collected both by the HRDD, and the Sarva Shiksha Abhiyaan (SSA). However, SSA data is not shared with the HRDD. Also, the HRDD publishes all its data, including the name of students, on their <a href="http://sikkimhrdd.org/Home.aspx">website</a>, making it publicly available. One of the data challenges identified by the HRDD was their difficulty in tracking if scholarship money is reaching the suitable students. When a student moves from one school to another, the records do not get updated easily. This leads to different schools continuing to receive funds for the same scholarship. Aligning school records is important to prevent such leakages.</p>
<p>After these two grouped exercises, all the participants gathered back so that the data flows diagrams and identification of key challenges documented by departmental teams could be presented to the entire group. Each team presented their data flow diagram, and discussed challenges and opportunities. This created a context for different departments to discuss what kind of data they often needed from each other, and how there was neither a platform for inter-departmental discussion on such issues, nor systems that facilitate the same. There was an agreement that an open data platform could address this issue to a great extent. The discussion also highlighted that the most significant data collecting government agency in Sikkim is DESME, however, it does not publish any data in machine-readable formats, and does not even have a website.</p>
<p>This data flow and bottleneck exercise made it very clear that there are several data production and collection processes in place in Sikkim, and also systems that are digesting, processing, and reporting data. Hence, implementing the open data policy will need to negotiate with such complexity.</p>
<p>In the final session of the day, <strong>Dr. Shiban Ganju</strong> made a presentation on applications of open data in healthcare. His talk focused on how converting medical information about a patient being stored at various locations to a combined and shareable Electronic Health Record can save the patient as well as the medical practitioners from duplication of medical tests, easier mobility from one medical institute to another, and a clearer macro-level understanding of key public health indicators. Dr. Ganju discussed the open health data initiatives in the United States, in the United Kingdom, and in Sweden, before discussing the challenges faced in implementing interoperable standards for open health data in India. The slides from Dr. Ganju’s presentation can be accessed <a href="https://drive.google.com/file/d/0B7xi0bhhq-OxTTczUTY3MWZFbG8/view?usp=sharing">here</a>.</p>
<p> </p>
<h2>Day 03, June 05, 2015</h2>
<p>The final day started with a set of presentations from <strong>Mr. Garab Dorji</strong>, Deputy Chief IT Officer, Office of the Prime Minister, Thimphu, Bhutan of the Government of Bhutan, <strong>Mr. Birendra Tiwari</strong>, Senior Informatic Officer, Department of Information Technology, Government of Meghalaya, and <strong>Mr. Milan Chhetri</strong> of Melli Dara Paiyong Gram Panchayat Unit, Sikkim, on various technological solutions being explored, implemented, and practiced by the respective governments and administrative units.</p>
<p><strong>Mr. Milan Chhetri</strong>’s presentation was on the operationalisation of Cyber Villages in Sikkim, which had been initiated in 2013 with support from the Honourable Chief Minister of Sikkim, <strong>Pawan Kumar Chamling</strong>. Cyber Villages aim to address digital divide, by empowering local village units with handheld data devices to collect data from every household and connect the same to a real time dashboard. All village related data is expected to be available in one place. At the same time as part of e-governance initiative, SMS based updates on Government programmes and services will be sent to all villagers. Mr. Chhetri ended his presentation with a short promotional video of the concept, which is embedded below.</p>
<iframe src="https://www.youtube-nocookie.com/embed/ZOqAl8kDwKY?rel=0" frameborder="0" height="360" width="640"></iframe>
<p> </p>
<p>The second session of the day started with a presentation from <a href="https://twitter.com/DurgaPrMisra"><strong>Mr. D. P. Misra</strong></a>, National Data Sharing and Accessibility Policy - Programme Management Unit (NDSAP-PMU), National Informatics Centre, Government of India. The presentation focused on the process of implementation of the <a href="http://data.gov.in/sites/default/files/NDSAP.pdf">National Data Sharing and Accessibility Policy</a> approved by the Government of India in 2012. Mr. Misra has played a key role in the NDSAP-PMU that was trusted with development of the national open government data platform of India and in setting up the procedures and standards for publication of government data by various central and state government agencies through that Platform. His talk described the technical solutions designed by the NDSAP-PMU to make data accessible for the end-users in various file formats, to make visualisation of available data easy, and to make it possible for users to comment upon existing data and to request for data that is unavailable at the moment. Further, he emphasised the need for outreach initiatives by the government so as to build awareness and activities around the available open government data. The slides from Mr. Misra’s presentation can be accessed <a href="https://drive.google.com/file/d/0B7xi0bhhq-OxZjZrc0c4cmxpZFk/view?usp=sharing">here</a>.</p>
<p>The presentation by Mr. Misra was followed by a group exercise where various teams, self-selected by the participants, worked on different sections of the SODAAP implementation plan to put together ideas and plans for the first draft of the document. Five groups were formed and each of them worked on a separate section of the implementation plan: <strong>1)</strong> Governance Framework and Budgetary Support, <strong>2)</strong> Data Inventory and Negative List, <strong>3)</strong> Data Acquisition and Open Standards, <strong>4)</strong> Data Publication Process, Licenses, and Timeframes, and <strong>5)</strong> Awareness, Capacity, and Demand of Data. The initial section titled ‘Introduction to the Policy and its Principles’ was put together by Vashistha Iyer on the basis of the SODAAP document. The technical section on the ‘Sikkim Open Data Portal’ was left out of this drafting exercise, as it was decided that the representatives of the Department of Information Technology will prepare this section on the basis of their interactions with the NDSAP-PMU later in June.</p>
<p>The drafting session was followed by presentations by each team working on a separate section, and quick feedbacks from all the participants. These drafts, along with the feedbacks, have been compiled together by Mr. Chattapadhyay, and is shared with the officials from the Government of Sikkim for their further discussion and eventual finalisation of the SODAAP implementation plan document.</p>
<p>The workshop ended with a round of final words and sharing of learning by the participants, and a vote of thanks on the behalf of the organisers.</p>
<p> </p>
<p>
For more details visit <a href='http://editors.cis-india.org/openness/workshop-on-open-data-for-human-development-2015-06-report'>http://editors.cis-india.org/openness/workshop-on-open-data-for-human-development-2015-06-report</a>
</p>
No publishersumandroOpen DataOpen Government DataFeaturedSikkim Open Data Acquisition and Accessibility PolicyOpenness2015-08-28T08:16:09ZBlog EntryOpen Data Hackathons are Great, but Address Privacy and License Concerns
http://editors.cis-india.org/openness/open-data-hackathons-are-great-but-address-privacy-and-license-concerns
<b>This is to cross-publish a blog post from DataMeet website regarding a letter shared with the organisers of Urban Hack 2015, Bangalore, in response to a set of privacy and license concerns identified and voiced during the hackathon by DataMeet members. Sumandro Chattapadhyay co-authored and co-signed the letter. The blog post is written by Nisha Thompson.</b>
<p> </p>
<p>Hackathons are a source of confusion and frustration for us. DataMeet actively does not do them unless there is a very specific outcome the community wants like<a href="https://github.com/datameet/maps/tree/master/parliamentary-constituencies"> freeing a whole dataset </a>or introducing <a href="http://datameet.org/2015/05/13/mumbai-meet-6-data-science-hackathon/">open data to a new audience</a>. We feel that they cause burn out, are not productive, and in general don't help create a healthy community of civic tech and open data enthusiasts.</p>
<p>That is not to say we feel others shouldn't do them, they are very good opportunities to spark discussion and introduce new audiences to problems in the social sector. <a href="http://www.datakind.org/chapters/datakind-blr">DataKind</a> and <a href="https://rhokbangalore.wordpress.com/">RHOK</a> and numerous others host hackathons or variations of them regularly to stir the pot, bring new people into civic tech and they can be successful starts to long term connections and experiments. A lot of people in the DataMeet community participate and enjoy hackathons.</p>
<p>However, with great data access comes great responsibility. We always want to make sure that even if no output is achieved when a dataset is opened at least no harm should be done.</p>
<p>Last October an open data hackathon,<a href="https://www.hackerearth.com/sprints/urban-hack/"> Urban Hack</a>, run by Hacker Earth, <a href="http://www.nasscom.in/">NASSCOM</a>, <a href="http://www.xrci.xerox.com/">XEROX</a>, <a href="https://console.ng.bluemix.net/?cm_mmc=EcoDISA-_-Bluemix_day-_-11-15-14::12-31-15-_-UrbanHack">IBM </a>and <a href="http://wri-india.org/">World Resource Institute India</a> wanted to bring out open data and spark innovation in the transport and crime space by making datasets from <a href="http://mybmtc.com/">Bangalore Metropolitan Transport Corporation (BMTC)</a> and the Bangalore City Police available to work with. A DataMeet member (<a href="http://www.lostprogrammer.com/">Srinivas Kodali</a>) was participating, he is a huge transport data enthusiast and wanted to take a look at what is being made available.</p>
<p>In the morning shortly after it started I received a call from him that there is a dataset that was made available that seems to be violating privacy and data security. We contacted the organizers and they took it down, later we realized it was quite a sensitive dataset and a few hundred people had already downloaded it. We were also distressed that they had not clarified ownership of data, license of data, and had linked to sources like <a href="http://openbangalore.org/">Open Bangalore</a> without specifying licensing, which violated the license.</p>
<p>The organizers were quite noted and had been involved with hackathons before so it was a little distressing to see these mistakes being made. We were concerned that the government partners (who had not participated in these types of events before) were also being exposed to poor practices. As smart cities initiatives take over the Indian urban space, we began to realize that this is a mistake that shouldn't happen again.</p>
<p>Along with <a href="http://cis-india.org/">Centre for Internet and Society</a> and Random Hacks of Kindness we sent the organizers, Bangalore City Police and BMTC a letter about the breach in protocol. We wanted to make sure everyone was aware of the issues and that measures were taken to not repeat these mistakes.</p>
<p>You can see the letter here:</p>
<p><iframe src="https://www.documentcloud.org/documents/2702333-Appropriate-and-Responsible-Practices-for.html" height="500" width="600"></iframe></p>
<p>We are very proud of the DataMeet community and Srinivas for bringing this violation to the attention of the organizers. As people who participate in hackathons and other data events it is imperative that privacy and security are kept in mind at all times. In a space like India where a lot of these concepts are new to institutions, like the Government, it is essential that we are always using opportunities not only to showcase the power of open data but also good practices for protecting privacy and ensuring security.</p>
<p> </p>
<p><em>Originally posted on DataMeet website: <a href="http://datameet.org/2016/02/02/to-hack-or-not-to-hack/">http://datameet.org/2016/02/02/to-hack-or-not-to-hack/</a>.</em></p>
<p> </p>
<p>
For more details visit <a href='http://editors.cis-india.org/openness/open-data-hackathons-are-great-but-address-privacy-and-license-concerns'>http://editors.cis-india.org/openness/open-data-hackathons-are-great-but-address-privacy-and-license-concerns</a>
</p>
No publishersumandroPrivacyOpen DataOpen Government DataFeaturedHackathonOpenness2016-02-05T20:37:18ZBlog EntrySubmitted Comments on the 'Government Open Data Use License - India'
http://editors.cis-india.org/openness/submitted-comments-on-the-government-open-data-use-license-india
<b>The public consultation process of the draft open data license to be used by Government of India has ended yesterday. Here we share the text of the submission by CIS. It was drafted by Anubha Sinha, Pranesh Prakash, and Sumandro Chattapadhyay.</b>
<p> </p>
<p><em>The following comments on the 'Government Open Data Use License - India' was drafted by Anubha Sinha, Pranesh Prakash, and Sumandro Chattapadhyay, and submitted through the <a href="https://www.mygov.in/group-issue/public-consultation-government-open-data-use-license-india/">MyGov portal</a> on July 25, 2016. The original submission can be found <a href="https://www.mygov.in/sites/default/files/mygov_146946521043358971.pdfh">here</a>.</em></p>
<hr />
<h2>I. Preliminary</h2>
<ol>
<li>This submission presents comments by the Centre for Internet and Society (“<strong>CIS</strong>”) <strong>[1]</strong> on the draft Government Open Data Use License - India (“<strong>the draft licence</strong>”) <strong>[2]</strong> by the Department of Legal Affairs.<br /><br /></li>
<li>This submission is based on the draft licence released on the MyGov portal on June 27, 2016 <strong>[3]</strong>.<br /><br /></li>
<li>CIS commends the Department of Ministry of Law and Justice, Government of India for its efforts at seeking inputs from various stakeholders prior to finalising its open data licence. CIS is thankful for the opportunity to have been a part of the discussion during the framing of the licence; and to provide this submission, in furtherance of the feedback process continuing from the draft licence.</li></ol>
<h2>II. Overview</h2>
<ol start="4">
<li>The Centre for Internet and Society is a non-governmental organisation engaged in research and policy work in the areas of, inter alia, access to knowledge and openness. This clause-by-clause submission is consistent with CIS’ commitment to safeguarding general public interest, and the interests and rights of various stakeholders involved. Accordingly, the comments in this submission aim to further these principles and are limited to those clauses that most directly have an impact on them.</li></ol>
<h2>III. Comments and Recommendations</h2>
<ol start="5">
<li><strong>Name of the Licence:</strong> CIS recommends naming the licence “Open Data Licence - India” to reflect the nomenclature already established for similar licences in other nations like the UK and Canada. More importantly, the inclusion of the word ‘use’ in the original name “Government Open Data Use License” is misleading, since the licence permits use, sharing, modification and redistribution of open data.<br /><br /></li>
<li><strong>Change Language on Permissible Use of Data:</strong> The draft licence uses the terms “Access, use, adapt, and redistribute,” which are used in UNESCO’s definition of open educational resources, whereas, under the Indian Copyright Act <strong>[4]</strong>, it should cover “reproduction, issuing of copies,” etc. To resolve this difference, we suggest the following language be used: “Subject to the provisions of section 7, all users are provided a worldwide, royalty-free, non-exclusive licence to all rights covered by copyright and allied rights, for the duration of existence of such copyright and allied rights over the data or information.”<br /><br /></li>
<li><strong>Add Section on the Scope of Applicability of the Licence:</strong> It will be useful to inform the user of the licence on its applicability. The section may be drafted as: “This licence is meant for public use, and especially by all Ministries, Departments, Organizations, Agencies, and autonomous bodies of Government of India, when publicly disclosing, either proactively or reactively, data and information created, generated, collected, and managed using public funds provided by Government of India directly or through authorized agencies.”<br /><br /></li>
<li><strong>Add Sub-Clause Specifying that the Licence is Agnostic of Mode of Access:</strong> As part of the section 4 of the draft licence, titled ‘Terms and Conditions of Use of Data,’ a sub-clause should be added that specifies that users may enjoy all the freedom granted under this licence irrespective of their preferred mode of access of the data concerned, say manually downloaded from the website, automatically accessed via an API, collected from a third party involved in re-sharing of this data, accessed in physical/printed form, etc.<br /><br /></li>
<li><strong>Add Sub-Clause on Non-Repudiability and Integrity of the Published Data:</strong> To complement the sub-clause 6.e. that notes that data published under this licence should be published permanently and with appropriate versioning (in case of the published data being updated and/or modified), another sub-clause should be added that states that non-repudiability and integrity of published data must be ensured through application of real/digital signature, as applicable, and checksum, as applicable. This is to ensure that an user who has obtained the data, either in physical or digital form, can effectively identify and verify the the agency that has published the data, and if any parts of the data have been lost/modified in the process of distribution and/or transmission (through technological corruption of data, or otherwise).<br /><br /></li>
<li><strong>Combine Section 6 on Exemptions and Section 7 on Termination:</strong> Given that the licence cannot reasonably proscribe access to data that has already been published online, it is suggested that it would be better to simply terminate the application of the licence to that data or information that ought not to have been published for grounds provided under section 8 of the RTI Act, or have been inadvertently published. It should also be noted that section 8 of the RTI Act cannot be “violated” (as stated in Section 6.g. of the draft licence), since it only provides permission for the public authority to withhold information, and does not impose an obligation on them (or anyone else) to do so. The combined clause can read: “Upon determination by the data provider that specific data or information should not have been publicly disclosed for the grounds provided under Section 8 of the Right to Information Act, 2005, the data provider may terminate the applicability of the licence for that data or information, and this termination will have the effect of revocation of all rights provided under Section 3 of this licence.”<br /><br /></li>
<li>It will be our pleasure to discuss these submissions with the Department of Legal Affairs in greater detail, supplement these with further submissions if necessary, and offer any other assistance towards the efforts at developing a national open data licence.</li></ol>
<hr />
<p><strong>[1]</strong> See: <a href="http://cis-india.org/">http://cis-india.org/</a>.</p>
<p><strong>[2]</strong> See: <a href="https://www.mygov.in/sites/default/files/mygov_1466767582190667.pdf">https://www.mygov.in/sites/default/files/mygov_1466767582190667.pdf</a>.</p>
<p><strong>[3]</strong> See: <a href="https://www.mygov.in/group-issue/public-consultation-government-open-data-use-license-india/">https://www.mygov.in/group-issue/public-consultation-government-open-data-use-license-india/</a>.</p>
<p><strong>[4]</strong> See: <a href="http://www.copyright.gov.in/Documents/CopyrightRules1957.pdf">http://www.copyright.gov.in/Documents/CopyrightRules1957.pdf</a>.</p>
<p> </p>
<p>
For more details visit <a href='http://editors.cis-india.org/openness/submitted-comments-on-the-government-open-data-use-license-india'>http://editors.cis-india.org/openness/submitted-comments-on-the-government-open-data-use-license-india</a>
</p>
No publishersinhaOpen Government DataOpen LicenseOpen DataNDSAPFeaturedOpennessHomepage2016-07-26T09:23:48ZBlog EntrySubmitted 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>
<hr />
<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>
<p> </p>
<p>
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>
</p>
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