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BSA Submits Comments on Non-Personal Data Governance Framework

NEW DELHI – September 10, 2020 – BSA | The Software Alliance today submitted comments on the Report by the Committee of Experts on the Non-Personal Data Governance Framework. BSA appreciates the opportunity to share its recommendations and help enact a framework that can unlock the immense potential for the social, public, and economic value of data.

Today, data is an important asset and serves as a powerful engine for creating new jobs, providing responses to global challenges, promoting economic growth, and enabling innovation. BSA welcomes the Committee’s proposal to promote the effective sharing of government-generated data and foster greater industry collaborations. However, the Committee's proposal for a new law and a new regulator are premature. The proposals to establish a compulsory data sharing architecture and to impose restrictions on cross-border data transfers and local storage requirements are counter-productive and will undermine the stated objectives of the Framework.

“BSA supports efforts to enhance the collective benefits of data by advancing responsible policies that facilitate voluntary data sharing, collaboration, innovation, and growth while protecting privacy and security. However, the scope of the current Framework is overly broad and could impede efforts to achieve India’s objectives of attracting investment, encouraging start-ups to innovate, and tackling today's most pressing challenges”, said Venkatesh Krishnamoorthy, Country Manager — India, BSA | The Software Alliance. “We urge the Committee to encourage voluntary data sharing arrangements and to promote cross-border data flows to ensure the continued growth of India’s vibrant digital economy. The Framework must recognize that mandatory obligations are counterproductive throughout the data ecosystem and present additional complications if applied to data processors."

BSA looks forward to working with Government of India in creating a policy ecosystem that helps achieve the Prime Minister Modi's vision of a USD $1 trillion digital economy by 2024 while protecting the privacy and security of consumers.

Read BSA’s full comments here.


BSA | The Software Alliance (www.bsa.org) is the leading advocate for the global software industry before governments and in the international marketplace. Its members are among the world’s most innovative companies, creating software solutions that help businesses of all sizes in every part of the economy to modernize and grow.

With headquarters in Washington, DC, and operations in more than 30 countries, BSA pioneers compliance programs that promote legal software use and advocates for public policies that foster technology innovation and drive growth in the digital economy.


Michael O’Brien

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