In how many ways can you divide data ?
That is the question
Context :
Data Protection Bill talks of following “ types of data “ :
[ A ] “ Umbrella Group “ consisting of data from which a person can be
identified
[ B ] “ Sensitive Personal
Data “ consisting of
financial , health, sexual orientation,
biometric, genetic, transgender status, caste,
religious belief, passwords etc
[ C ] “ Critical Personal
Data “ such as military/national
security data [ to be defined ]
[ D ] “ Non-Personal Data “
[ E ] “ Anonymized Personal Data “
======================================================
Neat ? Hardly !
I urge the officers who
drafted this bill to label “ which data is what type “ in the following tabulation
==================================================
|
Srl
No
|
Data
|
A
|
B
|
C
|
D
|
E
|
|
1
|
Who I am ( name / gendre )
|
|
|
|
|
|
|
2
|
Where and when, I was born / who were my
parents
|
|
|
|
|
|
|
3
|
Where I grew up / where I live currently
|
|
|
|
|
|
|
4
|
Do I live in a rented place or in an owned
flat
|
|
|
|
|
|
|
5
|
What Schools / Colleges I attended ( - and
degrees I acquired )
|
|
|
|
|
|
|
6
|
What Companies I worked for and salaries I got
|
|
|
|
|
|
|
7
|
How I travel to work ( own vehicle or public
transport )
|
|
|
|
|
|
|
8
|
Where I go for my holidays / what books I read
|
|
|
|
|
|
|
9
|
Who I married and who are my children ( - and
how many )
|
|
|
|
|
|
|
10
|
If divorced , how much alimony I pay and to
whom
|
|
|
|
|
|
|
11
|
Where I invest my money ( Banks – Funds –
Equity etc )
|
|
|
|
|
|
|
12
|
How much I have borrowed from whom and for
how long
|
|
|
|
|
|
|
13
|
My Credit ranking ( including my
spending history / card wise – wallet wise )
|
|
|
|
|
|
|
14
|
What are my eating ( food ) preferences and
the restaurants I visit
|
|
|
|
|
|
|
15
|
What I do for entertainment ( Music / Movies
/ Videos ) [ life-long cultural activity history ]
|
|
|
|
|
|
|
16
|
What clothes I wear and how often do I buy
|
|
|
|
|
|
|
17
|
Who are my friends and how often I phone /
text them / meet them
|
|
|
|
|
|
|
18
|
What ailments I suffer from and what
medicines I take ( complete life-long medical history )
|
|
|
|
|
|
|
19
|
What minor offences ( traffic ) or crimes
that I have committed
|
|
|
|
|
|
|
20
|
What elections I have contested ( won and
lost )
|
|
|
|
|
|
|
21
|
Who are my doctors / lawyers / brokers /
agents
|
|
|
|
|
|
|
22
|
What web sites I visit and how often and for
how long ( Social Media engagement )
|
|
|
|
|
|
|
23
|
What do I search on the Net / What RSS feeds
I subscribe to
|
|
|
|
|
|
|
24
|
What TV channels I watch and Radio Stations
that I listen to
|
|
|
|
|
|
|
25
|
Every photo of mine ever taken ( selfie or
otherwise )
|
|
|
|
|
|
|
26
|
Every phone call that I ever made or received
|
|
|
|
|
|
|
27
|
Every Email / Text message that I ever sent or
received
|
|
|
|
|
|
|
28
|
Every blog / comment that I ever posted on
the Web
|
|
|
|
|
|
|
29
|
Ev Every
face-to-face communication that I engaged in
|
|
|
|
|
|
|
30
|
Languages Spoken
|
|
|
|
|
|
|
31
|
Every E-Com site visited and every item
ordered
|
|
|
|
|
|
|
32
|
Every banking transaction
|
|
|
|
|
|
|
33
|
Every digital payment transaction
|
|
|
|
|
|
|
34
|
Every mobile app downloaded
|
|
|
|
|
|
|
35
|
Complete
list of my online/offline Service Providers
|
|
|
|
|
|
|
36
|
List of IoT enabled / plain , gadgets in my
house
|
|
|
|
|
|
|
37
|
DBT Scheme benefits enjoyed
|
|
|
|
|
|
|
38
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
Is it possible that each of the above-listed item ( -
this list is far from being comprehensive ), may be interpreted differently { A
– B – C – D – E } , by :
Ø Citizen
involved in litigation under the proposed Data Protection Law
Ø Millions
of lawyers
Ø Thousands
of Judges
Apart from this “ Matter of Interpretation “ of DATA TYPE , there is also the question of :
Ø Nature of Content
· WHO created
· WHEN created
· WHERE created
· HOW created
· HOW transmitted / circulated
· HOW transformed ( “Speech to Text “ is so
yesterday transformation )
· To WHOM sold
· HOW used
· WHEN compiled
· WHO compiled
· WHERE stored
And also the
question of everyone ( concerned with litigation ), agreeing with the correct
definition of the
following words used in
the Data Protection Law :
# Private
# Data
# App
# Permission
# Access
# Download
# Sign
# Rights
# Own
# Personal
# Share
# Entity
# Processing
# Obligation
# Handling
# Collection
# Use
Are we about to enact a law which , on one hand, is not
implementable and on the other hand , might lead to unending litigation ?
Dear Shri
RaviShankar Prasadji,
It may not be too late to rethink the whole matter
With regards,
Hemen Parekh
======================================================
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