Data Security and Data Privacy
Objective
This document focuses on deciding whether Personal identification information collected in each rainmaker module is used for data security and privacy purposes.
Target Audience: This document is intended for Engineering (tech team), Product Management and Implementation team to agree on requirements for data privacy and data security.
Introduction
As a product provider to the government, we should be responsible for the data security of individuals and organizations who are using our products. The first step in data privacy and security is to identify personal identification information (PII) which will then decide our approach to data security. The personal identification information listed in this document is decided with the help of ‘WHITE PAPER OF THE COMMITTEE OF EXPERTS ON A DATA PROTECTION FRAMEWORK FOR INDIA’. The remarks and provisional views of the committee are given below:
Justice Srikrishna Committee On Personal Identification Information (PII)
All information about an individual is not personal data. As stated earlier, the protection of identity is central to informational privacy. So the information must be such that the individual is either identified or identifiable from such information. In statutes or instruments which use both these terms “identified or identifiable” such as the EU GDPR, it refers to states in which the data can exist. Data could be in a form where individuals stand identified or in other cases, it is possible that they could be identified. Whether an individual is identifiable or not is a question of context and circumstances. For instance, a car registration number, by itself, does not reveal the identity of a person. However, it is possible that with other information, an individual can be identified from this information.
Provisional views of the committee on Personal Data:
It is data about/relating to an individual that may be the subject matter of protection under the law. Data in this context ought to include any kind of information including opinions or assessments irrespective of their accuracy.
Data from which an individual is identified or identifiable/reasonably identifiable may be considered to be personal data. The identifiability can be direct or indirect.
New technologies pose considerable challenges to this distinction based on identifiability. This standard may have to be backed up by codes of practice and guidance notes indicating the boundaries of personal information having regard to the state of technology.
On the basis of the above comments potential information from rainmaker modules i.e. PGR, PT and TL were identified and the storage of information in each module was analysed as below.
Terms Used & Definitions
Primary PII: With the help of given information individual can be directly identified
Secondary PII: With the help of given information an individual can not be identified directly but an individual can be identified if this information is available with one of primary PII.
Independent PII: With the help of given information individual cannot be identified directly but this information can help the receiver to identify an individual through other means like search for property tax/ trade license or electricity connections
Sensitive info: Password, Gender, Bank account number is sensitive information which needs to be protected
Module-wise data points required to secure are given below:
PGR
Trade License
Property Tax:
Water & Sewerage
OBPAS
Fire NOC
mCollect
HRMS
Finance
Decryption Service:
Role-based decryption with the jurisdiction of employee
Service-based decryption for citizens. Example: billing and collection service
Bulk Search in every Module:
Search should not be enabled for citizen
Bulk search in any module should not show more than 10 entries at a time
PII should be masked in search results
Employees can request to view PII in this case
The declaration should be made by the employee: about ethical use and
The entry should be audited with the Name and Mobile number of the employee
Notification about audit entry to the viewer
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