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:

1. 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.

2. 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.

3. 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

1. Primary PII: With the help of given information individual can be directly identified

2. 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.

3. 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

4. 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

Segment	Data Point	Primary or Secondary PII	Identified/ identifiable	Information stored in
Citizen	Name	Primary	Identified	User Service
Citizen	Mobile Number	Primary	Identified	User Service
Citizen	City	Secondary	Identifiable	User Service
Citizen	Password	Sensitive info	Sensitive info	User Service
Citizen	Street Name/ Locality	Secondary	Identifiable	Property Module
AO	Name	Primary	Identified	User Service
AO	Mobile Number	Primary	Identified	User Service
AO	City	Secondary	Identifiable	User Service
AO	Password	Sensitive info	Sensitive info	User Service
LME	Name	Primary	Identified	User Service
LME	Mobile Number	Primary	Identified	User Service
LME	City	Secondary	Identifiable	User Service
LME	Password	Sensitive info	Sensitive info	User Service
Admin	Name	Primary	Identified	User Service
Admin	Mobile Number	Primary	Identified	User Service
Admin	City	Secondary	Identifiable	User Service
Admin	Password	Sensitive info	Sensitive info	User Service

Trade License

Segment	Data Point	Primary or Secondary PII	Identified/ identifiable	Information stored in
Trade Location Details	Property ID	Independent	Identifiable	Property Module
Trade Location Details	Electricity Connection No.	Independent	Identifiable	TL Module
Owner Information	Name	Primary	Identified	User Service
Owner Information	Mobile No.	Primary	Identified	User Service
Owner Information	Father/Husband's Name	Primary	Identified	User Service
Owner Information	Email	Primary	Identified	User Service
Owner Information	PAN No.	Independent	Identifiable	User Service
Owner Information	Correspondence Address	Primary	Identifiable	User Service
Owner Information	DOB	Secondary	Identifiable	User Service
Documents	Owner's ID Proof	Independent	Identified	Files store
Documents	Ownership Proof	Independent	Identified	Files store
Documents	Owner’s photo	Independent	Identified	Files store
Documents
Payer Information	Name	Primary	Identified	Collections
Payer Information	Mobile No.	Primary	Identified	Collections
Counter Employee	Name	Primary	Identified	User Service
Counter Employee	Mobile Number	Primary	Identified	User Service
Counter Employee	City	Secondary	Identifiable	User Service
Counter Employee	Password	Sensitive info	Sensitive info	User Service
Approver	Name	Primary	Identified	User Service
Approver	Mobile Number	Primary	Identified	User Service
Approver	City	Secondary	Identifiable	User Service
Approver	Password	Sensitive info	Sensitive info	User Service

Property Tax:

Segment	Data Point	Primary or Secondary PII	Identified/ identifiable	Information stored in
Property Address	City	Secondary	Identifiable	Property Module
Property Address	House No	Secondary	Identifiable	Property Module
Property Address	Building Name	Secondary	Identifiable	Property Module
Property Address	Door No	Primary	Identifiable	Property Module
Property Address	Street Name Locality	Secondary	Identifiable	Property Module
Property Address	Pincode	Secondary	Identifiable	Property Module
Property Address	Existing Property ID	Independent	Identifiable	Property Module
Owner Information	Name	Primary	Identified	User Service
Owner Information	Gender	Sensitive info	Sensitive info	User Service
Owner Information	Mobile Number	Primary	Identified	User Service
Owner Information	Father/Husband’s Name	Primary	Identified	User Service
Owner Information	Relationship	Secondary	Identifiable	User Service
Owner Information	Special Category	Primary	Identifiable	User Service
Owner Information	ID of Document belonging to special category	Primary	Identified	User Service
Owner Information	Email ID	Primary	Identified	User Service
Owner Information	Correspondence Address	Secondary	Identifiable	User Service
Property Tax	Property unique ID	Independent	Identifiable	Property Module
Payer Information	Name	Primary	Identified	Collections
Payer Information	Mobile No.	Primary	Identified	Collections
Counter Employee	Name	Primary	Identified	User Service
Counter Employee	Mobile Number	Primary	Identified	User Service
Counter Employee	CIty	Secondary	Identifiable	User Service
Counter Employee	Password	Sensitive info	Sensitive info	User Service

Water & Sewerage

Segment	Data Point	Primary or Secondary PII	Identified/ identifiable	Information stored in
Property Address	City	Secondary	Identifiable	Property Module
Property Address	House No	Secondary	Identifiable	Property Module
Property Address	Building Name	Secondary	Identifiable	Property Module
Property Address	Plot/House/Survey No	Secondary	Identifiable	Property Module
Property Address	Property ID	Independent	Identifiable	Property Module
Property Address	Street Name Locality	Secondary	Identifiable	Property Module
Property Address	Pincode	Secondary	Identifiable	Property Module
Owner Information	Name	Primary	Identified	User Service
Owner Information	Gender	Sensitive info	Sensitive info	User Service
Owner Information	Mobile Number	Primary	Identified	User Service
Owner Information	Guardian Information	Primary	Identified	User Service
Owner Information	Relationship	Secondary	Identifiable	User Service
Owner Information	Owner Category	Secondary	Identifiable	User Service
Owner Information	Correspondence Address	Primary	Identified	?
Owner Information	Email ID	Primary	Identified	User Service
Connection Details	Meter ID	Independent	Identifiable	W&S Module
Connection Details	Consumer Number (OId/New)	Independent	Identifiable	W&S Module

OBPAS

Segment	Data Point	Primary or Secondary PII	Identified/ identifiable	Information stored in
Applicant info	Applicant name	Primary	Identified	User service
Applicant info	Applicant mobile number	Primary	Identified	User service
Owner Information	Name	Primary	Identified	User Service
Owner Information	Gender	Sensitive info	Sensitive info	User Service
Owner Information	Mobile Number	Primary	Identified	User Service
Owner Information	Father/Husband’s Name	Primary	Identified	User Service
Owner Information	Relationship	Secondary	Identifiable	User Service
Stakeholder registration	Name	Primary	Identified	User Service
Stakeholder registration	Gender	Sensitive info	Sensitive info	User Service
Stakeholder registration	DOB	Secondary	Identifiable	User Service
Stakeholder registration	Mobile Number	Primary	Identified	User Service
Stakeholder registration	Email ID	Primary	Identified	User Service
Stakeholder registration	PAN number	Independent	Identifiable	User Service
Stakeholder registration documents	ID Proof	Primary	Identified	File store
Stakeholder registration documents	Educational certificate	Primary	Identified	File store
Stakeholder registration documents	Experience certificate	Primary	Identified	File store
Stakeholder registration documents	Photograph	Independent	Identified	File store
Stakeholder registration documents	Income tax statement	Independent	Identified	File store
Stakeholder registration documents	License registration doc	Independent	Identified	File store
OBPS Application documents	Identity proof	Primary	Identified	File store
OBPS Application documents	Address proof	Primary	Identified	File store
OBPS Application documents	Land tax receipt	Primary	Identified	File store
OBPS Application documents	Property deed	Primary	Identified	File store

Fire NOC

Segment	Data Point	Primary or Secondary PII	Identified/ identifiable	Information stored in

mCollect

Segment	Data Point	Primary or Secondary PII	Identified/ identifiable	Information stored in
Property Address	City	Secondary	Identifiable	Property Module
Property Address	House No	Secondary	Identifiable	Property Module
Property Address	Building Name	Secondary	Identifiable	Property Module
Property Address	Door No	Secondary	Identifiable	Property Module
Property Address	Street Name Locality/Mohalla	Secondary	Identifiable	Property Module
Property Address	Pincode	Secondary	Identifiable	Property Module
Property Address	Existing Property ID	Independent	Identifiable	Property Module
Owner Information	Name	Primary	Identified	User Service
Owner Information	Mobile Number	Primary	Identified	User Service

HRMS

Segment	Data Point	Primary or Secondary PII	Identified/ identifiable	Information stored in
Employee Information	Name	Primary	Identified	User Service
Employee Information	Mobile Number	Primary	Identified	User Service
Employee Information	Gender	Sensitive info	Sensitive info	User Service
Employee Information	Guardian’s name	Primary	Identified	User Service
Employee Information	Relationship	Secondary	Identifiable	User Service
Employee Information	Date of Birth	Secondary	Identifiable	User Service
Employee Information	Email ID	Primary	Identified	User Service
Employee Information	Correspondence Address	Primary	Identified	User Service

Finance

Segment	Data Point	Primary or Secondary PII	Identified/ identifiable	Information stored in
Employee	Name	Primary	Identified	User Service
Employee	City	Secondary	Identifiable	User Service
Contractor	Code	Secondary	Identifiable	Contractor Master
Contractor	Name	Primary	Identified	Contractor Master
Contractor	Correspondence Address	Primary	Identified	Contractor Master
Contractor	Permanent Address	Primary	Identified	Contractor Master
Contractor	Contact Person	Primary	Identified	Contractor Master
Contractor	eMail	Primary	Identified	Contractor Master
Contractor	Mobile	Primary	Identified	Contractor Master
Contractor	GST/TIN No	Independent	Identifiable	Contractor Master
Contractor	Bank Account No	Secondary	Identifiable	Contractor Master
Contractor	PAN No	Independent	Identifiable	Contractor Master
Contractor	EPF No	Independent	Identifiable	Contractor Master
Contractor	ESI No kg	Independent	Identifiable	Contractor Master
Supplier	Code	Secondary	Identifiable	Supplier Master
Supplier	Name	Primary	Identified	Supplier Master
Supplier	Correspondence Address	Primary	Identified	Supplier Master
Supplier	Permanent Address	Primary	Identified	Supplier Master
Supplier	Contact Person	Primary	Identified	Supplier Master
Supplier	eMail	Primary	Identified	Supplier Master
Supplier	Mobile	Primary	Identified	Supplier Master
Supplier	GST/TIN No	Independent	Identifiable	Supplier Master
Supplier	Bank Account No	Independent	Identifiable	Supplier Master
Supplier	PAN No	Independent	Identifiable	Supplier Master
Supplier	EPF No	Independent	Identifiable	Supplier Master
Supplier	ESI No	Independent	Identifiable	Supplier Master

Decryption Service:

1. Role-based decryption with the jurisdiction of employee

2. Service-based decryption for citizens. Example: billing and collection service

Bulk Search in every Module:

1. Search should not be enabled for citizen

2. Bulk search in any module should not show more than 10 entries at a time

3. PII should be masked in search results

4. 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