Blog: DPDP Framework for an AI-Driven Future

Sunday, 25 October 2026

ntegrating "Algorithmic Transparency" into the DPDP Framework for an AI-Driven

Future

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Dear Shri Ashwini Vaishnaw-ji,

I am writing to you today as a concerned citizen and long-time observer of the

intersection between emerging technology and public policy. While our nation has

made commendable strides with the Digital Personal Data Protection (DPDP) Act,

the rapid, almost exponential, evolution of AI-integrated hardware—ranging from

autonomous vehicles to advanced wearable devices—demands that we act

proactively to ensure the protection of our citizens' privacy.

Recent regulatory developments, such as the U.S. National Highway Traffic Safety

Administration’s (NHTSA) proposal to use cyan-colored lights to identify

autonomous vehicles, highlight a critical, emerging global necessity:

the physical signaling of algorithmic intent.

We are transitioning into a world where everyday objects—our cars, our eyewear,

and our city infrastructure—have become hyper-connected sensor platforms

capable of mass data ingestion. Currently, our regulatory frameworks rely on

"consent" models that are functionally obsolete in the face of "zero-click" and

ambient data collection. A citizen cannot realistically "opt-in" to the observation of

a robotaxi or a smart glass device passing them on the street.

I urge the Ministry to consider the following amendments or additions to the

DPDP framework to ensure it remains robust in this new era:

Mandatory Algorithmic Signaling:
We must move beyond digital consent and toward physical, universal
transparency. Just as we mandate safety features on vehicles, we should
legislate a universal "Color Code for Surveillance."
Any device performing autonomous data collection or AI-driven monitoring in
public spaces should be equired to display a standardized, highly visible and
non-bypassable physical indicator.
This turns "ambient surveillance" into
> "socially visible interaction, "
restoring a degree of agency to the public.
Redefining "Data Controller" for Autonomous Systems:
Current laws struggle to pin down liability when the "collection" is performed
by a machine operating without human intervention. We must clarify that the
manufacturer and the deploying entity are strictly liable for any data ingested
by autonomous systems, treating the device’s "operating state" as a trigger for
strict DPDP compliance.
Transparency-by-Design Default:
Borrowing from the principles I have advocated in my writings on AI safety
(such as the need for "human-in-the-loop" constraints), the DPDP framework
should mandate that AI-integrated hardware operating in public spheres must
have "transparency" as a hard-coded, hardware-level requirement—not an
optional software toggle.

The goal is not to stifle innovation, but to ensure that the adoption of AI-driven

mobility and wearables does not come at the cost of our fundamental right to

privacy in public spaces. We have the opportunity to set a global benchmark for

"Informed Environments," where technology wears its intent on its frame.

I have extensively documented the risks of these "gateways" to privacy in my

archives and would be honored to share more detailed recommendations or draft

regulatory language with your team should you find this perspective useful.

Thank you for your time and your continued dedication to building a secure digital

future for India.

Respectfully,

Hemen Parekh

#	Title	Date	About
1	DEAR SHRI CHIEF JUSTICE OF INDIA : PL CONSIDER THESE TERMS OF REFERENCE FOR PEGASUS COMMITTEE	2023-11-22	Proposes terms of reference for Pegasus committee, emphasizing privacy risks of smart glasses.
2	Blue-green is the color of autonomy	2026-10-25	Reports on NHTSA proposal for cyan lights to signal autonomous vehicle operation.

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