TIME TO THINK ABOUT ELECTRONIC DATA RETENTION POLICY

Organization and retrieval of information are the basis for efficient operation and for compliance of legal requirements in any organization. In government organizations, there already exist a set of well established processes (and standards) for management of information stored in conventional paper based documents. However, in recent times, the digital revolution has marked the beginning of the information age, where dynamics of information management have undergone a radical shift. Enhanced capacity and increased flexibility of data stored in electronic format require a new approach to data retention policy in line with newly established norms in the digital world.

      

In relation to this, an article was published in CIO.IN with title 'Indian IT Depts.: Information Retention? We Don’t Care!' on 21st Nov 2011. The article is based on the survey done by Symantec. Excerpts from the above article are as under:

1) "...Surprisingly enterprise IT departments don’t think a information retention plan is important"

2) "Currently, India has no central Act which lays down provisions related to data retention laws, according to Symantec"

3) "According to Symantec’s findings, India organizations take an average of 10 days to provide their lawyers with information they need to make an early case assessment--compared to five days globally"

(for details, please refer - http://www.cio.in/news/indian-it-depts-information-retention-we-don-t-care-196462011)

Under NeGP (National eGovernance Plan), 'State Data Centers' (SDCs) are being established in the federal states/union territories in India. Data retention is being given due importance in SDCs. Provision for data retention has been elaborated under "Data Retention Plan" in  section 12 of 'Guidelines For Technical and Financial Support For Establishment of State Data Centre (SDC)' issued by the DIT (Department of Information Technology, Government of India). Details (as mentioned in the guidelines) are given as under:

"12.0 Data Retention Plan

12.1 The State would formulate an appropriate Data Retention policy and ensure that the data centre architecture supports the same. The Data Retention Policy would be guided by the following factors:

a. Data classification and risk assessment of data.
b. Data Retention Period.
c. Data Security aspects.
d. Disposal of data once the retention period is over."

(for more details, please refer: http://www.mit.gov.in/sites/upload_files/dit/files/downloads/sdc/guidelines.pdf)

Ensuring a clear understanding on classification of data helps in better information processing within an organization. In general, data can be classified on the basis of legal, business and personal relevance. However, online availability of data on internet and use of ubiquitous mobile devices to access data have increased the significance of additional classifications of data on the basis of user authorization, user authentication and sensitivity to security. In future, once platform evolution of e-government enables seamless information exchange across departments, the expectations for continuous improvement in governance through self assessment and self learning processes based on statistical analysis of accumulated data would further increase complexities of data classification, data exchange and data retention.

To meet the challenge, an early move towards adoption of data retention policy is important. Systematically designing organizational change management and capacity building to support strategic information management could be helpful in evolution of next generation government organizations (or departments), which would manage public data with greater efficiency. 

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Related Information:

Notification has been issued for 'Policy on Electronic Record Retention & Preservation' by the Departments of Information Technology and Bio-Technology, Government of Chhattisgarh on  27 SEP 2013. This can be referred at following link:-

http://www.chips.gov.in/sites/default/files/No._450_and_451_English.pdf

WHY IS THE NEED TO PROMOTE FINANCIAL INCLUSION?

Following is the excerpt from an article "Who’s afraid of Aadhar?" by Pratap Bhanu Mehta, published in 'The Indian Express' on Wed Jan 25 2012:-

".... here is a simple true story. A domestic help in Gurgaon wanted to open a bank account. The bank account was important for a number of reasons. Small savings would lose their value if they did not earn interest and, at that margin of poverty, even a few rupees mattered. Vulnerability to violence was likely to increase if the money was kept in possession. She approached several banks to open an account. Despite having West Bengal identity papers, ration card and election card, she was turned away. Banks would refuse to recognise these papers. Despite being “introduced” by people who presumably had sound standing, banks simply refused to open her account. Public sector bank managers were asked why they were refusing to open an account? Did they not have a mandate for financial inclusion? The answer came, “Poor people’s accounts remain dormant.” But more often, the response was “the identity papers are not adequate.” When asked why, the response was “these have been issued in West Bengal. We cannot trust them. The lady might be Bangladeshi.” Eventually, a public sector bank agreed to open the account, but only after an incredible weighty Know Your Customer process was brought to bear.

This story was staggering at many levels. It illustrated the difficulty migrant workers had in opening bank accounts. Identity in India is not portable; it has been made too place-specific, too difficult to authenticate. In this case, despite the fact that there were some identity papers, they were declared untrustworthy. The constant refrain was: “We don’t know who these people are” — even when asked, “why did that matter? After all you are going to hold her money, not the other way around”. " (http://www.indianexpress.com/news/whos-afraid-of-aadhar/903580/ - as accessed on 01 MAR 2012)

Apart from illustrating the difficulty faced by migrants for getting an access to banking facilities due to non-portable nature of identity proofs issued in India, the story highlights following important points:-

1) There is a need for financial inclusion, further:

• Uneven development at rapid pace may only add to the need for financial inclusion.
• Modernization is expected to bring about changes to the traditional means of livelihood for financially excluded citizens. Financial inclusion may help in supporting systematic and sensible transitioning in this regards.

2) Returns from micro-financing is not seen as a substantial addition to profitability by the existing banking system, following efforts in this regards could be helpful:

• Banks deploying innovative financial instruments targeted at financial inclusion could be given special privileges/attractive benefits (like tax-benefits, infrastructure support) based on number of financially excluded citizens these banks may help in becoming financially included.
• With significant volumes of new financially included account holders on board, banks may start considering them as a target market and streamline their strategy to focus on their banking needs. Thereafter, there is a possibility that these banks themselves may find it interesting (lucrative) to explore ways to convert dormant account holders (belonging to the low income group citizens availing banking facilities on getting financially included) to active account holders.
• Close association of banks with the low earning capacity people (as their market) may enable banks to understand the financial behavior of different segments in this market. The learning will eventually help in funding (through credible financial mechanism) entrepreneurial endeavors at the grass root level.

3) Probably, majority of financially excluded citizens are themselves not serious to get financially included, therefore this issue is not getting prominence in political agenda. Following could be promoted in this regards:

• State initiated programs (like benifit for rural un-employed citizens, medical insurance for Below Poverty Line citizens) may be linked through banking services to the beneficiaries to give initial push towards financial inclusion.
• Awareness programs to make people understand the importance of saving and the benefits of banking services may be launched by the state.

4) Needy citizens face difficulty in getting access to basic banking services, in this regards:

• Available infrastructure for IT enabled services (in banking sector) may be easily scaled up to expected volumes.
• Business process re-engineering taking into consideration the requirements for financial inclusion may be required for the special services targeted for financial inclusion.

5) Unskilled labour working as 'domestic help' belong to the unorganized sector in India, probably:

• It may be helpful to develop an institutional mechanism for the sector.

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