Friday, August 23, 2013

Right to Privacy and Online Social Networking Space: What Indian Law can do?


With a tremendous increase in the usage of social networking website, an equally proportionate concern has also arisen regarding the issue of privacy. Though there are a number of judicial precedents dealing with issue of privacy in relation to telephone interception, surveillance etc, hardly are there any precedents which can sufficiently enlighten one to realise the scope of right to privacy in social networking space. Is there a crucial difference between the privacy in physical and online space? I argue that though there provisions, such as Section 72A of the Information Technology Act, 2000 (“IT Act”), make one criminally liable for negligently sharing personal data information, they are not sufficient for the purpose of online social networking.

In this issue of online space, the primary hurdle arises when seeks to identify the data which requires protection. Not every data can be given protection, for example, data which is already available in public domain. Also since the nature of online space is different, the measure of protection should be different. For instance, it is not as easy to locate a particular data in physical space as one can locate it online using ‘google.com’; hence, data is more vulnerable in online space than in physical space. This problem ultimately directs one to identify the nature of “privacy right” which one enjoys.

If one looks at the dictionary meaning of privacy, there is a possibility of getting an unclear and uncertain definition: ‘a state in which one is not observed or disturbed by other people’.[1]And, if one sees definition of right to privacy provided by the Supreme Court, then there is a possibility of getting a very broad definition. 

Clause 3 of the Draft National Privacy Bill, 2011 confers on every individual a right to privacy. Though a specific definition is not given, the clause contains a list of information which will be covered under the privacy right of an individual. Though there are a number of shortcomings in the (an exhaustive discussion on data protection and Privacy Bill will be done in one of the next posts). I herein discuss the existing legislations and legal principles which deal with the issue of data protection in online networking space.



Online Social Networking Space: How important is to protect the Right to Privacy?

With the advent of online networking websites, there is now a parallel society – a society where people, like physical world, socialise and interact with each other – but more importantly, there is now a society which, unlike its physical counterpart, does not have a secure legal regime of its own. Since the existence of the members of this parallel society is recognised by the data which they share, a need for its protection becomes significant.

Of course, no one would feel comfortable if one’s data, which can even be sensitive in nature, is shared without any restriction. For instance, consider the data shared by one on Facebook, considerably the most popular social networking website. According to the Data Policy of Facebook,[2]it receives different information from the users such as registration information, information which users choose to share [photos, notes etc.], information which others share about the user etc. While certain information (name, cover photos, gender, network, username and ID) are always publicly available, other information are not (wall posts, location, friend list etc.). As per the policy of Facebook, the information of a user is used in connection with the services and features provided by it. Such information can be used if Facebook has given a notice of its policy for using such information. This means, if one is really concerned of the privacy on Facebook, then it is better to read its data policy (For accessing full data policy of facebook, follow the link - https://www.facebook.com/full_data_use_policy)

Like Facebook, other websites such as twitter, linkedin etc. have their own policies. In any case, these online networking websites are in possession of an enormous amount of individual data. This raises a question: “Is there anything which legally regulates these websites, at least in India”? Following the revelation of US National Security Agency’s (“NSA”) surveillance program, there is now a series question about the reliability of major online social networking websites. Since most of them have their headquarters in USA, it becomes easier for NSA, and difficult for other countries, to regulate such kind of activities. May be, we are paying the cost of the USA’s monopoly on web world.

Scope of Right of Privacy in India: How far does it extend to Social Networking Sites?

Over a period of time, it has been recognised in India that right to privacy forms a part of the Right to Life.[3]According to the Supreme Court, Privacy and dignity of human life has always been considered a fundamental human right of every human being.[4]As far as the question of surveillance is concerned, in Bhavesh Jayanti Lakhani v. State of Maharashtra, it was held that surveillance per se may not violate individual or private rights including the right to privacy.[5] In exceptional circumstance, particularly surveillance in consonance with the statutory provisions may not violate such a right.[6]

In India, the most important legislation which regulates the data privacy is Information Technology Act, 2000 (“IT Act”). Under Section 43A of the IT Act, if a body corporate, dealing/processing/possessing any sensitive personal data or information, negligently causes any wrongful loss or gain to any person, it can be held liable for compensation. Information Technology (Reasonable security practices and procedures and sensitive personal data or information) Rules, 2011 [“IT Rules”] enumerates seven forms of ‘sensitive personal data or information’.[7]However, IT Rules also provide that any information, which is available in public domain or furnished under Right to Information Act, 2005 (“RTI Act”), will not be considered as sensitive personal information.[8]A clarification to the IT Rules states that the ‘rules are regarding sensitive personal data or information and are applicable to the body corporate or any person located within India’.[9]

Section 72A of the IT Act penalises a provider of service criminally if it, with the intent of causing wrongful loss or gain, discloses the personal information which it has received while providing the service. However, for becoming criminally liable, such disclosure should be without the consent of the person concerned. Relating this to the Facebook Data Policy, it becomes clear that facebook, by notifying the users of its policy, takes their consent. How many users actually read such policy is not very clear. There is a possibility that a large number of users may not be reading the Facebook Data Policy at all, or they may not be aware of any such policy. Can, in this situation, they give their consent? The relevant part of Facebook Data Policy reads as:

“………….While you are allowing us to use the information we receive about you, you always own all of your information. Your trust is important to us, which is why we don't share information we receive about you with others unless we have:

·         received your permission;
·         given you notice, such as by telling you about it in this policy; or
·         removed your name or any other personally identifying information from it.
·         Of course, for information others share about you, they control how it is shared…….”

In order to ensure that one is aware of the kind of information which Facebook can share, it would be advisable to read its data policy. There are a number of external applications, for e.g., flipkart log in, which requires one’s explicit permission before the personal data can be shared. At the same time, there are situations when there an implicit consent can also be taken, for example, by consenting to be a member of Facebook. It is the latter form of consent which is problematic because, in this situation, a user’s knowledge (and, what about consent?) of his data sharing depends on whether he has read the data policy.

Even if it is assumed that one has read the data policy of online networking websites, there is hardly any bargaining power on their part. Because of this, users are simply left with a choice to either use these websites or not use it. In the contemporary period, when keeping one isolated from web world is nothing less than a suicide, not using social networking websites is not a proper solution. Hence, if one does not like Facebook’s policy, one may simply keep oneself away from it.

Other legislations in India which deal with data privacy are: Indian Penal Code, 1860, Copyright Act, 1957, Credit Information Companies Regulation Act, 2005 etc. Yet another legal mechanism through which data can be protected is the contractual obligation (Facebook does this!). Though Copyright Act provides protection to a database, the main purpose was not to protect the data of an individual. The main purpose, for providing copyright protection to database as a literary work, is to incentivise the creation of such works. So far as contracts are concerned, obligations will be determined in accordance with the established principles and legal provisions of contracts. Further, the claims under a contractual obligation are usually of civil nature; hence, there is a less possibility criminal prosecution unless, of course, there is an involvement of the crime. Coming to the Indian Penal Code, Lord Macaulay, while drafting the code, would not have thought of the problems underlying the internet world. It is true that, with a liberal interpretation, IPC can be applied to offences committed on online social space. But, it would still be insufficient since the purpose of IPC was not to deal with the online space.

It is clear that these legislations cannot sufficiently provide protection to the data of an individual. A step, in the form of Privacy Bill, has now been taken. In one of the next posts, I will analyse the effectiveness of the data protection regime under the Privacy Bill.






[1] Oxford English Dictionary
[2] https://www.facebook.com/about/privacy
[3] People's Union for Civil Liberties (PUCL) v. Union of India, (1997) 1 SCC 301, 17
[4] Ramlila Maidan Incident, In re, (2012) 5 SCC 1 at page 118
[5] Bhavesh Jayanti Lakhani v. State of Maharashtra, (2009) 9 SCC 551, ¶102
[6] Ramlila Maidan Incident, In re, (2012) 5 SCC 1, 119
[8] RTI Act is applicable mainly to public authorities
[9] http://pib.nic.in/newsite/erelease.aspx?relid=74990

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