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the time for data protection in Pakistan is now: developing the legal eco-system

Introduction

1.         Data protection helps us in safeguarding our fundamental right to privacy with appropriate legal frameworks that gives individuals rights over their data and put in place accountability systems and define the obligations of those who control and process this data.

 The Shift to Data



2.         The drivers of economic growth once were raw materials and resources like land, labour, and capital. The drivers have been shifting to brainpower industries, meaning they can be located anywhere in the world and tapped into with much-improved communication technologies.
3.         In May 2017, THE ECONOMIST said that data is a more valuable resource than oil. The shift from price to data[1] is accelerating. Data analytic techniques have become the oil extraction-and-refining plants and data companies have become the new oil giants. Data is the next “essential” facility and money maker, and this is prompting debate on how it should be regulated. Today, big data is a big driver of growth and for some companies, revenue.
4.         Bernard Marr says that “Over the last two years alone 90 percent of the data in the world was generated.”[2] Klaus Schwab says “data-powered business models create new revenue sources from their access to valuable information on customers in a broader context and increasingly rely on analytics and software intelligence to unlock insights.”[3]


Data Protection and Privacy



5.         Much of our everyday activity takes place in the online domain courtesy of various apps running on smartphones accessing the Internet on 4g technology. Many people are shopping online because of the multiple convenience it offers. Online retailers tend to remember your purchase history and base their recommendations on your subsequent purchases on this history.
6.         All this is done through algorithms that analyse one’s digital footprint extensively – every click, every like, every second spent on a website, key words in your communication, your demographic data, geographical location, age, gender, political orientation, etc.,- and mine a wealth of usable information from it. How can this data be safeguarded?

7.         Tech firms have been voraciously collecting the data of their consumers, offering free services as an enticement. The major platforms – the “frightful five” or FAANGs[4] - have played a key role in the process. [5] Shoshana Zuboff, in her book, The Age of Surveillance Capitalism, details how GOOGLE and FACEBOOK developed their business models to collect and monetise data – “A fundamentally illegitimate choice,” she says.[6]
8.         Can we expect tech-based companies to protect our personal information? Not if their business model or a revenue stream depends on sharing it. Protecting privacy requires a legal framework but will also require a technology adaptation.
9.         There is growing worry over social media companies’ non-social and non-economic influence over culture and information and the implicit threat they pose to the jurisdictions of governments. For instance, FACEBOOK and 270,000 users’ data – those who participated in a survey by CAMBRIDGE ANALYTICA and had consented to having their data harvested – led to a breach of the personal information for 87 million users and could possibly have affected the 2016 U.S. elections.[7] Similar concerns have been raised during the U.K.’s process of Brexit.


The Legal Framework for Privacy Protection



10.       Data protection is a trending topic and many governments have moved decisively to plug the gaps in their national laws. The British government introduced a new draft data protection bill in 2017 to replace the 1998 law.[8] Key features include the “right to be forgotten” on the internet and “the right to innocence” whereby citizens can request social media sites to remove any content they posted before the age of 18. The bill proposes tougher penalties on companies for data breaches and a requirement by businesses to inform the U.K. INFORMATION COMMISSIONER’s office about any breach within 72 hours.
11.       The EU’s GENERAL DATA PROTECTION REGULATION (G.D.P.R.) is the most important change in data privacy regulation in 20 years[9] and considered the world’s most aggressive set of internet privacy rules. G.D.P.R. is a common set of rules and practices that apply across Europe and, it is hoped, the world.[10] G.D.P.R. says that first, companies need your consent to collect your data and second, you should be required to share only data that is necessary to make their services work. More than 500 million people living in the European Union have the two important rights, i.e., the right of erasure and the right of portability.

12.       After G.D.P.R., California passed a digital privacy law that gives consumers more control over and insight into the spread of their personal information online. This is one of the most significant regulations that governs the data-collection practices of technology companies in America.[11] This is quite a step as most of the existing laws do little to limit what companies can do with consumer information.
13.       Unfortunately, Pakistan’s ELECTRONIC DATA PROTECTION ACT, 2005,[12] and the PERSONAL DATA PROTECTION BILL, 2018[13] remain draft pieces of legislation. Pakistan’s lack of data protection laws may make it difficult (i) for international market platforms and other e-Commerce companies to operate locally and (ii) to protect its citizens from data breaches.[14]  This is an entry barrier as companies may hesitate to operate in a weak regulatory regime. And in general, the feeling of insecurity about one’s personal data can also stifle competition and innovation.[15]
14.       It is common knowledge that data from government repositories has been accessed without permission and can be purchased economically.[16] Telecom companies in Pakistan have been known to sell subscribers’ data to third parties, something that is even stated in the privacy policies of some companies. Hence, the talk of a national data regulator is timely.[17]
15.       Pakistanis based in Europe will see their online transactions and activity protected under the G.D.P.R. These include banking services, e-commerce transactions, and activity on social media. It cannot be one-sided protection and companies in Pakistan will need to adapt to service clients and customers in Europe (and the world). The EU plans to limit market access to the region if countries do not rise to meet Europe’s standards. Data protection laws are becoming part of trade deals. It’s time that Pakistan moved decisively to promulgate data protection legislation not just for economic reasons but for personal security and privacy!
16.       It will be a while before regulations in protecting data become effective, leading to the question: should data be protected or should less of it be collected? Both protection and collection have their attendant costs and risks. Even the American NATIONAL SECURITY AGENCY could not prevent an employee from walking off with a thumb drive full of information and releasing it to the world in 2013.


  


[1] Data is giving rise to a new economy, The Economist, 6 May 2017
[3] Klaus Schwab, The Fourth Industrial Revolution, World Economic Forum, 2016
[4] Facebook, Amazon, Apple, Netflix and Google. Termed the Frightful Five by Farhad Manjoo, these are the largest companies in terms of market capitalisation. In 2017, these giants added nearly a trillion dollars to their aggregate value. The ECONOMIST says “The five biggest American tech firms together make about a tenth of all corporate profits. Second, the externalities they may impose on their users, including a loss of privacy and tech addiction. And third, their probable pollution of the public sphere with fake news, mass manipulation and lobbying.” 26 April 2018
[5] Data is a “key input and high value product of the digital economy. Indeed, some of the most interesting, and in some cases alarming, legal issues in the digital economy lie in the collection, aggregation, and commercial use of consumer data.” said Makan Delrahim of the U.S. DEPARTMENT OF JUSTICE at the Harvard Antitrust Conference 2019. Remarks
[6] Interview in The Intercept, 2 February 2019. See the book details here and The Guardian’s book review here. “Setting out merely to connect us, Facebook found itself in possession of our deepest secrets. And in seeking to survive commercially beyond their initial goals, these companies realised they were sitting on a new kind of asset: our “behavioural surplus”, the totality of information about our every thought, word and deed, which could be traded for profit in new markets based on predicting our every need – or producing it.”
[7] Cambridge Analytica harvested the personal information of approximately 87 million Facebook users not just to target would-be voters with campaign ads but, as former Cambridge Analytica staffer Christopher Wylie put it to the N.Y. Times, to “fight a culture war in America.” See also Facebook and Cambridge Analytica: What You Need to Know as Fallout Widens, N.Y Times, 19 March 2018
[9] The EU GENERAL DATA PROTECTION REGULATION (G.D.P.R.) became operational on 25 May 2018, replacing the Data Protection Directive 95/46/EC. G.D.P.R. is “designed to harmonise data privacy laws across Europe, to protect and empower all EU citizens data privacy and to reshape the way organisations across the region approach data privacy.” Source: https://www.eugdpr.org/ The G.D.P.R. website: https://gdpr-info.eu/.
[10] What the G.D.P.R., Europe’s Tough New Data Law, Means for You, NY Times, 6 May 2018. GDPR allows regulators to fine any company in breach as much as four per cent of its total worldwide sales. It promotes three legal and business principles for firms that want to gain or retain user trust: transparency (say what you do), user control (empower your customers), and accountability (do what you say). See also The EU’s GDPR: Lessons for U.S. Policymakers, Disruptive Competition Project, 25 May 2018 and The EU GDPR: What To Know About The EU's General Data Protection Regulation, Forbes, 28 November 2017, The right of erasure, an expansion of the “right to be forgotten,” gives individuals the ability to have their personal data erased upon request. The right of portability gives individuals the ability to access their own data with greater ease. Upon request, individuals will be able to transfer their personal data from one provider to another. The transfer of such data should promote ease of access among individuals and competition among providers.
[11] California Passes Sweeping Law to Protect Online Privacy, N.Y. Times, 28 June 2018. “The new law grants consumers the right to know what information companies are collecting about them, why they are collecting that data and with whom they are sharing it. It gives consumers the right to tell companies to delete their information as well as to not sell or share their data. Businesses must still give consumers who opt out the same quality of service.
[14] On 23 April 2018, Careem, a ride-sharing service in Pakistan, admitted that “users' personal data compromised in massive data breach.” Dawn, “Careem users' personal data compromised in massive data breach,” 23 April 2018. Another article said that “The hack affected user data of over 14 million users and 558,880 Captains in the 13 countries and 90 cities that Careem operates in.” Dawn, “There are no laws to protect your data in Pakistan. So how can we minimise breaches like the Careem hack?”, 30 April 2018, Time Magazine said “If you’re one of the millions of Americans feeling like it’s time to start better protecting your personal data, you’re pretty much out of luck, according to cybersecurity experts.” We Talked to Security Experts About How to Protect Your Online Data. Here’s What They Said, 17 April 2018
[15] On Data Privacy, Business Recorder, 10 May 2018. Edited in some places to delete extraneous text.
In the online space, consumers may not be the king, but their data surely is, both for legitimate and illegitimate data scavengers! Therefore, securing and maintaining user trust is critical to the expansion of online economy, which has opened up quite a few avenues for entrepreneurship, innovation and value addition at home. Pakistan’s is a low-trust market, so online platforms will need to be vigilant with users’ data privacy.
In that vein, episodes such as data breach at Careem, reported over a fortnight ago, do not help. It’s already damaging that the ride-hailing service sat, for three months, on the fact that personal data of some 14 million of its users had been hacked. More alarming is that the company didn’t tell which markets and users were particularly affected or where the hacked info had ended up.
The ensuing silence over this matter by local authorities suggests that users of online economy are pretty much on their own.
The issue of consumer protection, of which users’ data privacy is an integral part, needs prompt attention. Users cannot be reasonably expected to decipher the entire online fine-print of terms & conditions and privacy policies. And due to the tech giants’ “all-or-nothing” approach towards which personal data they can track, keep and share with third parties, even the discerning customers have no choice but to join the ubiquitous platforms, or else feel left out. Currently, a vacuum exists in Pakistan as to which regulatory body should oversee online space, where e-commerce players (like Daraz, Home shopping and Yayvo), on-demand services (like Careem, Uber, Foodpanda, etc.), and several other intermediary platforms (e.g., OLX, PakWheels and Rozee) operate. After all, this space cuts across tech, finance and commerce. An E-commerce policy, which has long been in the works, is yet to come out.
Data protection regulations need to be put in place to safeguard online users as well as address culpability of firms that fail to protect their users’ data. After such data breaches, in Pakistan and elsewhere, online companies are learning that they can get over such episodes with little to no reputational damage. This will hurt the online ecosystem going forward.

[16] Cyber insecurity, The News, 22 December 2019.

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