For ease of reference and responding, we have extracted some key aspects of the data protection framework for your views.
1. While responding keep in view:
a. The reference slide numbers, where applicable, are mentioned against the questions below.
b. Share aspects you think are unnecessary, and are likely to put disproportionate burden on organizations while not benefitting data subjects significantly and which of them are useful and can be complied to.
c. Aspects that have possibility of creating ambiguity while implementing
d. All categories of data subjects who are associated with your business, such as employees, customers, vendors, job applicants, website visitors, shareholders etc
e. Possibility of conflict with other domestic or foreign laws that may apply to your industry
f. Potential areas of conflict with monitoring for data security & digital surveillance
g. Balance between privacy and other rights in a democratic society such as freedom of expression, right to information etc.
h. Aspects in DP law that are important to make India a data safe country to make it a suitable destination for businesses, and possibility of India being considered for adequacy status by EU and other jurisdictions
i. Data privacy need not be looked at from compliance perspective alone – it could also be used as a business differentiator
j. Effort, cost and time required for complying with the law, vis a vis the benefit to data subjects
k. Business continuity
2. If there are any provisions missing in the white paper, please list them in the last question with justifications for consideration
3. Choose one or more responses that are most appropriate in your view.
a. If your response is not part of the options listed, then tick ‘others’ and briefly enumerate your response
b. Your views are being mainly sought from your organization perspective, and to a lesser extent as an Indian citizen (data subject)
c. Before providing your response, we recommend you review the white paper.
d. Link of overview slide …………………………….
e. If certain aspects do not impact you, you may choose not to respond
A summary of the key aspects and how they are connected to the industry is provided in the overview slides, but the slides are not a substitute for white paper.
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The questions and response options do not reflect NASSCOM DSCI position on Data Protection..
The questions are on key aspects related to data protection framework. Responses will be aggregated and wherever possible will be leveraged to develop Industry response to the White paper on date protection.