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Reimagining Data Governance in India - A Citizen-Centric Approach to Health Data
April 9, 2025

Context:

  • India’s population of 1.4 billion generates data with immense potential economic value, possibly rivaling 38 OECD nations when adjusted for Purchasing Power Parity (PPP).
  • As technology proliferates, robust data governance policies must enable citizens to benefit from the value of their data.

Understanding the Policy Gap:

  • Identity vs. property: A fundamental confusion.
  • Policymakers often conflate data as identity (linked to privacy and personal rights) with data as property (a tradable economic resource).
  • This conceptual confusion hinders value creation, innovation, and knowledge discovery.

Healthcare Data - A Case Study in Missed Opportunities:

  • Current scenario - Public vs. private divide:
    • Large private hospitals have digital systems.
    • Government hospitals have basic digital setups (aided by the National Health Mission).
    • Small private clinics, where most Indians seek care, lack digital infrastructure and incentives.
  • Consequences of poor digitisation:
    • No interoperable medical records for citizens.
    • Health insurers struggle with pricing competitiveness.
    • Researchers lack access to large datasets for medical or AI-driven discoveries.

Ayushman Bharat Digital Mission (ABDM) - The Governance Response:

  • Framework and features:
    • Managed by: The National Health Authority.
    • Principles:
      • Citizens own their health data.
      • Interoperability across health facilities.
    • Components:
      • Registries (doctors, drugs, health facilities).
      • Middleware for data exchange.
      • Consent management system.
  • Challenges in implementation:
    • Clinical data is generated during doctor-patient interactions, where future data value is not perceived.
    • Citizen engagement is key to realising data value and driving innovation.

Towards a Free Market for Health Data:

  • Enabling citizen agency: If patients can sell/share their anonymised data, it incentivises:
    • Clinics to comply with ABDM.
    • Patients to maintain complete digital records.
    • Emergence of data intermediaries and health information exchanges.

Global Models vs. Indian Reality:

  • United States - Health Insurance Portability and Accountability Act (HIPAA) model:
    • Patients can access, but not share, their data with third parties.
    • Hospitals and insurers monetise de-identified data without compensating patients.
  • United Kingdom - National Health Service (NHS) model:
    • Health data owned by public institutions.
    • ~90% of records created and controlled by the NHS.
  • Why don't these models fit India?
    • India's healthcare system is highly privatised and decentralised.
    • Neither corporatist (US) nor statist (UK/EU) models are suitable.

A Citizen-Centric Data Governance Vision:

  • Principles for reform:
    • Empower citizens to treat data as property, not just as identity.
    • Build regulatory safeguards for privacy, including:
      • Anonymisation tools as digital public goods
      • Digital forensics to ensure transparency and reduce information asymmetry
  • Way forward:
    • Shift from Western models of data protection to a locally relevant, innovation-friendly policy.
    • Recognise and harness the economic potential of citizen-owned data in the healthcare sector.

Conclusion:

  • India must adopt a citizen-centric data governance framework that promotes individual agency, incentivises data interoperability, and fosters innovation in health systems.
  • Recognising data as economic property rather than merely a marker of identity is crucial to unlocking the next wave of digital transformation in India’s healthcare ecosystem.

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