Comments on Draft National Policy on ICT in School Education

The Department of School Education & Literacy under the Ministry of Human Resources Development has invited comments on its latest draft of the National Policy on ICT in School Education. We, at the Centre for Internet and Society (CIS) have the following comments on the latest draft:

• Digital content and resources already available in the public domain must be leveraged by the Government and this intention must be specifically expressed in the policy.

• The provision in the copyright law providing for fair use of copyrighted material must be completely taken advantage of in developing, sharing, disseminating and exchanging digital content and resources. Material already part of the public domain should be included in the pool of resources to be utilised by the Government under the policy.

• It is not enough for the State to provide “open and free access” to ICT and ICT-enabled tools and resources to all students. It is important that the Government adopts the concept of global Open Educational Resources (OER) and license Indian content appropriately. OER refers to digitised materials offered freely and openly for educators, students and self-learners to use and reuse for teaching, learning and research.¹ OER materials are being increasingly integrated into open and distance education. The policy should mandate the State to license all digital content under OER.

• It is commedable that the policy mandates use of Open Standards for the State to maintain and share digitsed content. However, we recommend that the policy uses the same definition for “Open Standards” as that incorporated in the Government's Open Standards policy so that the same phrase is defined uniformly across all national policies.

• The policy should not foreclose the option of including freeware or resources obtained gratis in the educational material for students. It should allow the State to make efforts to obtain freely available educational material and incoporate it as part of the educational material.

• Course developed by the State should be licensed under a Creative Commons License, preferably an attribution-only² or sharealike³ CC license 3.0. Similarly, software used as part of educational resource must be licensed under a GPL or a BSD license.

• Teachers and students should be sensitised towards the fair use exception in the Indian copyright law so that maximum utilisation of the provision is facilitated.

• School libraries should be encouraged to exercise their right to the fair use exception applicable to libraries. Even though the law on fair use in respect of public libraries seems restricted in terms of the number of copies of a book that can be made (and thus, leading to staggered borrowing) and making it a prerequisite for the book to be unavailable for sale in India. However, there is significant room for interpretation of these ambiguous provisions and take advantage of the fair use exception to provide greater access to educational materials available in school libraries. Other statutes such as the Public Libraries Act govern the operations of State libraries and this, in addition to the fair use provision, would allow for greater flexibility in operation for the libraries. The State should endeavour to make the most of these provisions and interpret them to enable greater access to learning material for the students.

• The policy should require libraries to follow an anonymisation policy which ensures that the details of books borrowed by the students remain private and the students' privacy is adequately safeguarded in this regard.

• As far as ICT for children for special needs is concerned, it is recommended that the State use the DAISY format to make documents accessible and comply with WCAG guidelines to ensure accesssibility of web content.

• Indian law on fair use exception applicable for distance education is still unclear. Therefore, we recommend that this policy be used test the feasibility of fair use in case of distance education in India.

• The results and findings from the monitoring, evaluation and research should be declared Open Government Data (OGD) and shared or disseminated accordingly. A piece of data is open if anyone is free to use, reuse and redistribute it – subject only, at most, to the requirement of attribute and share-alike.⁴ Open data commissioned or produced by the government or government controlled entities constitutes OGD.⁵

• As far as use of software for education is concerned, students need to read code before they write code, just as in the case of books. Therefore, Free and Open Source Software (FOSS) has to be made available so that the source code is accessible for the students to read and improve upon. De facto proprietary software could be made available where budget exists so that students can learn in a technology-neutral fashion and are exposed to multiple implementations of an idea. However, proprietary software availability will be inapplicable for domains which operate exclusively on free software.

• The present draft recommends educating students and teachers on use of firewalls and other security measures to be used to block “inappropriate websites”. We feel that there is no requirement for a centralised policy on blocking websites. We recommend community-based blocking wherein each school can decide the criteria on which they want to block a website.

• It is very critical to ensure that there is no surveillance done on children so that there is a free environment for children to use the digitised content and the internet for their educational purposes.

• We recommend that the State is mandated to have all Indian language content be encoded using Unicode standards.

• We have gone through the comments made on the draft version by IT for Change and Free Software Foundation (FSF) and we are broadly in agreement with the points made by them. We would like to reiterate that use of FOSS must be made mandatory.

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