Centre for Internet & Society

CIS submitted comments in response to MEITY's Consultation Paper on National Open Digital Ecosystems (NODEs) The comments were authored by Aman Nair, Elonnai Hickok and Arindrajit Basu with inputs from Gurshabad Grover.

This Submission consists of the following parts: 

  1. General comments 

  2. Responses to the questions posed by the White Paper 

  3. A proposal for the implementation of a NODE framework.


Broadly speaking, we would recommend that before implementation NODE project in its present form should be reassessed for :

  • Impact assessment on national security.

  • Security standards and practices.

  • Clarity on architecture of the NODE

  • Lack of clarity on the implementation of the NODE

  • Absence of clear evaluation metrics, 

  • Comparative and reliable appraisal of past efforts including Aadhaar and India Stack, 

  • Clear and uniform policy prescription delineating personal data from non-personal data and a governance framework for both

  • Use of open source technologies beyond just open standards and open API’s,

  • Lack of clear institutional mechanisms for redress 

  • Drawing of clear ‘red lines’ on the scope of a  NODE

  • Adherence to public ownership, interest and benefit of the ecosystem

  • Clearly articulated governance framework that  explicitly constitutional rights and values 

  • When conceptualizing, designing, implementing and evaluating a NODE, the following questions are scrutinised for the entire ecosystem:

Is there a law allowing for the creation of the NODE?

Will the NODE enable an intrusion into fundamental rights? If yes, 

    • Is an intrusion into fundamental constitutional rights necessary, i.e. is it the least intrusive option available?

    • Is the intrusion proportionate to the objective (e.g. public service delivery) being sought to be objective? Is the objective legitimate? 


This re-assessment should serve as an essential pre-requisite before the NODE approach is rolled out. Read the full submission here

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