Feedback on the Framework on OSS Adoption in E-Governance Systems

In September, 2013, the DeitY invited comments on the Framework on the proposed adoption of Open Source Software in E-Governance Systems (available at https://egovstandards.gov.in/Public_review_Framework_on_oss).

The Framework, published in September, 2013, provides a set of recommendations and procedures to encourage, manage and increase the adoption of Open Source Software in E-Governance systems. Further, the Framework goes on to discuss various important issues, including the deployment of unified software for all major devices, with the utilization of a standards based web browser, the integration of OSS with other on-going initiatives, and the development of an eco-system consisting of institutions, industry, academia and other key stakeholders to promote and adopt OSS. The envisaged Centre of Excellence on OSS to realize this Framework is noteworthy.

CIS commends the DeitY for this initiative, and appreciates the opportunity to provide feedback on the Framework.

The text of CIS Feedback is reproduced below:

PRELIMINARY

• This submission presents comments from the Centre for Internet and Society[1] on the Framework on Open Source Software Adoption in ‘E-Governance’ (“Framework”), published by the Department of Electronics and Information Technology, Ministry of Communications and Information Technology, Government of India (DeitY).[2]

• The Framework, published in September, 2013, provides a set of recommendations and procedures to encourage, manage and increase the adoption of Open Source Software in E-Governance systems.[3] Further, the Framework goes on to discuss various important issues, including the deployment of unified software for all major devices, with the utilization of a standards based web browser, the integration of OSS with other on-going initiatives, and the development of an eco-system consisting of institutions, industry, academia and other key stakeholders to promote and adopt OSS. The envisaged Centre of Excellence on OSS to realize this Framework is noteworthy.

• CIS commends the DeitY for this initiative, and appreciates the opportunity to provide feedback on the Framework. CIS’ comments are as stated hereafter.

COMMENTS

Scope and Applicability

• In the section pertaining to Scope and Applicability, the Recommendation proposed is to give priority to preferred areas for the adoption of this Framework.[4]
  
  It is suggested that the preferred areas alluded to aforesaid be identified and disclosed. It is further suggested that the Framework identify a timeline for operationalization of all of the proposed recommendations, including the identification of the preferred areas and the adoption of the Framework in these areas. It is also suggested that a time frame be provided for the implementation of the Framework to all other areas, besides the preferred ones.

Preamble

• In the section titled Preamble, the Recommendation proposed is to consider OSS along with Closed Source Software.[5] considering the socio- economic and strategic benefits provided by OSS.[6]
  
  CIS appreciates the welcome measure in considering OSS alternatives along with CSS. While viewing this as indeed the first step in the right direction, CIS would suggest the development of a mechanism and the adoption of further measures in order to migrate entirely to an entirely OSS based system; with preference being given to OSS between OSS and CSS.

Factors Influencing the Adoption of OSS in Government

• In the section dealing with Factors Influencing the Adoption of OSS in Government, the Framework states that the influencing factors are to be prioritized on the basis of feedback from managers/users.[7]
  
  CIS proposes that it may be clarified who the managers/users being spoken of are, and what is the type and manner of feedback expected for the evaluation of influencing factors. CIS suggests that feedback also be sought in a more inclusive and holistic manner, after seeking consultation from other stakeholders as well.

Device Drivers

• Under the section dealing with Device Drivers, the onus to ensure availability of device drivers for GNU Linux Operating Systems has been placed on the users.[8]
  
  CIS strongly suggests that this be modified to state that the availability of device drivers for GNU Linux Operating Systems must be assured by vendors as a part of procurement requirements.

Procurement Guidelines

• Under the section dealing with Procurement Guidelines, it has been recommended that vendors must provide justifications for excluding OSS in their response to proposals.[9]
  
  CIS suggests that vendors be given a time frame within which to ensure compliance with the Framework, and thereafter be required to include OSS in their response to proposals, post which justifications ought not to be considered, as a matter of policy, but could be on an exceptional case to case basis.

CONCLUDING OBSERVATIONS

• CIS welcomes the initiative of the DeitY towards the adoption of OSS in E-Governance Systems. This Framework, while indeed addressing the important issues associated towards the end of adoption of OSS in E- Governance, would be further strengthened by addressing the concerns enumerated above.
• CIS is thankful to the DeitY for the opportunity to provide feedback on this Framework. As a non-governmental research organization working in the areas of Openness[10] and Access to Knowledge.[11] CIS appreciates this effort by the DeitY, and would be privileged to work with the Government on this and other matters in these areas.

[1]. See www.cis-india.org (last accessed 26 October, 2013).

[2]. See https://egovstandards.gov.in/system/files/PublicReviewDocument/Framework_on_OSS_Ver0.8.pdf (last accessed 26 October, 2013).

[3]. Hereafter referred to as OSS.

[4]. See Page 9 of the Framework.

[5]. Hereafter referred to as CSS.

[6].See Page 12 of the Framework.

[7].See Page 16 of the Framework.

[8].See Page 20 of the Framework.

[9].See Page 22 of the Framework.

[10].See http://cis-india.org/openness (last accessed 26 October, 2013)

[11].See http://cis-india.org/a2k (last accessed 26 October, 2013).See http://cis-india.org/a2k (last accessed 26 October, 2013).

This submission was prepared on behalf of CIS by Nehaa Chaudhari. Click to download the submission file here. For specific section wise review comments, click here.