[India] AIC Submits Comments on India’s Personal Data Protection Bill, 2019 (25 February 2020)

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The Asia Internet Coalition (“AIC”) has submitted comments on India’s Personal Data Protection Bill, 2019 – Bill No. 373 of 2019 (“DP Bill”) to the Joint Select Committee (“JSC”), Government of India. In the backdrop of digitalization and the growth of digital services across the world, the role of data has become more and more significant. This has given rise to concerns of informational privacy and the exercise of rights over personal data. Without a framework to govern these two subjects, no digital industry can be sustainable. In this context, the Personal Data Protection Bill, 2019 (“DP Bill”) is a much-needed effort and parallels the global movement towards data protection legislation. Although we appreciate the Indian government’s efforts towards developing the DP Bill, we believe that there are concerns regarding its provisions, aspects of which contradict the draft Personal Data ProtectionBill, 2018 published by the expert committee headed by Justice Srikrishna (“2018 Bill”), the Puttaswamy judgment of the Supreme Court of India as well as other international frameworks such as the EU GDPR.