NASSCOM recently submitted its feedback to the Ministry of Civil Aviation (MoCA) on the Discussion Draft of the National Unmanned Aircraft System (UAS) Traffic Management Policy (Draft UTM Policy or Draft Policy).
The main recommendations made by NASSCOM are as follows:
1. Define the term “data” in the draft Policy: The definition of term “data” has not been provided in either draft UAS Rules, 2020 or the draft Policy. A definition will be useful to clarify its scope and ensure uniformity of thought on the issues of data protection, privacy standards and security controls.
2. Policy to be aligned with the Personal Data Protection (PDP) Bill: DGCA may issue a detailed guidance on the data privacy and data protection aspects of this draft Policy when the PDP Bill is passed by the Parliament. The draft Policy should also clarify how the concerned parties should comply with it, in case there is a contradiction or an inconsistency with the PDP Bill. Inconsistencies between the Policy and the PDP Bill may create confusion about the requirements to be met under the applicable laws.
3. Reconsider data localization requirement: The data localization requirement in the draft Policy may be removed to allow free cross border data flows, while ensuring the highest levels of data protection and privacy, in accordance with the set requirements.
4. Broader consultation on UAS related policies: To benefit from the learnings of other countries’ UTM development, UTM associations, like Global UTM Association (GUTMA)iii may be invited to contribute to future deliberations on UAS policy and its implementation.
The full submission is posted below. Our previous blog on the draft National UTM Policy is available here. If you have any questions, please contact komal[at]nasscom[dot]in.