The Asia Internet Coalition (“AIC”) has submitted recommendations on Pakistan Personal Data Protection Bill that was published on 9 April 2020 (the “Draft Bill“). The protection of personal data is an important component of any privacy framework and we appreciate the opportunity to provide additional feedback on the Draft Bill. We recognize the on-going efforts of the Ministry of Information Technology and Telecommunications (“MOITT”) in further fine-tuning the draft legislation since its initial release in July 2018, so as to work towards implementing a comprehensive framework for the protection of personal data in Pakistan.
However, in its current form, this draft presents significant interoperability issues and falls short of international best practices. It will adversely impact Pakistan’s digital ambitions and make it difficult for foreign companies to operate and offer services to Pakistani businesses and users.
We encourage MOITT to make a revised version of the Bill available for further public consultation so that we can provide additional recommendations based on international best practices. AIC and its members have worked closely with governments around the world in relation to the development of national personal data protection policies and legislation. In doing so, we have witnessed first-hand the potential for such policies and legislation to effectively protect the privacy interests of citizens without hindering innovation and technological advancement. We therefore request the opportunity to engage in further consultations with MOITT based on an improved Draft Bill.