IT for Change made substantial contributions to the Alliance for Sustainable and Holistic Agriculture's (ASHA's) response to the Government of India's Ministry of Agriculture, Cooperation and Farmer Welfare on their Consultation Paper on IDEA (India Digital System of Agriculture).
In the letter, the signitories urge the Government of India in general and the Task Force for the development of Centralised Farmers’ Database and creation of framework for Digital Ecosystem of Agriculture in particular to stop implementation until there are far more extensive and meaningful consultations with all concerned stakeholders, and make farmers’ needs as the beginning point of this endeavour.
The concerns highlighted are:
- Execution before consultation: Implementation seems to have begun even before the consultation process began, through the signing of MoUs with several IT corporations. Even these pilots could have easily waited until the broad framework was created in a participatory approach.
- Language of the consultation paper being only English and filled with technical jargon. As a result, meaningful consultations cannot take place since the contents of this paper are inaccessible to the average farmer.
- The proposition of a “farmers’ database” based on digitised land records will lead to problems and exclusions, given the seriously flawed condition of the digitised land records themselves and their failure to capture the information of actual cultivators and those operating the landholding.
- Ownership of IDEA / AgriStack and its various components is unclear. As a matter of principle and policy, the digital infrastructure being developed for the agriculture sector must be housed in, belong to and be controlled by central and state governments.
- Who will benefit from this system: There are no mechanisms to ensure that the economic interests of farmers are ensured whereas the revenue models that will be adopted for entities getting involved in this ecosystem are predictable. It is also unclear what happens to the farmers who are excluded from this ecosystem; there is no clarity on grievance redressal mechanisms and whether they would be farmer-friendly. Accountability mechanisms have not been spelt out for various players including state departments and agencies.
- Data Sovereignty and Farmers’ Consent: Stronger consent framework to protect economic interests is necessary by giving farmers better control over their data. Any system that uses a person’s data must have that person as a stakeholder in the decision-making and governance process of that system.
- With no data protection law in place, this exercise is taking place in a legal vacuum, with no protection for the interests of the farmers whose data is being used.
- Restrictions on coping of raw data through data exchanges are necessary to ensure that farmers are in control of their data.
- No farmer representation in the existing task force or the governance framework of IDEA.
- Impinging on federalism as per the Indian Constitution by constraining states to adopt and implement this project, and linking financing to the adoption of this project. Preliminary anecdotal reports and experience indicate that the Union Government is denying states access to the aggregated database, whereas states are the ones which have provided the databases in the first instance.
- Insufficient digital access and literacy in the nation, with existing asymmetries creating a non-level playing field. It is unclear what autonomy does a farmer have, if s/he wants to be included in a limited manner, or wants to opt out. It is also unclear what happens to the farmers who are excluded from this ecosystem; there is no clarity on grievance redressal mechanisms and whether they would be farmer-friendly.
The letter demands:
- The deadline should be extended to enable meaningful inputs from farmer bodies and the general public. This should be accompanied by presenting the content of the consultation paper in multiple Indian languages in a manner that a lay person finds easy to understand and comprehend, and translating and disseminating it in all major Indian languages.
- Consultations and oral hearings should be held to enable the participation of farmers and their organizations, as well as experts in various related fields.
- All implementation of pilots should be suspended until the above consultation process is completed and the inputs from the consultation are duly incorporated, since personal data is being shared with private entities without necessary safeguards in place.
Read the complete letter that was sent to the Ministry here.