In June this year, the Department of Telecommunications (DoT) released a draft amendment to the Telecom Cybersecurity Rules, 2024. Through this draft amendment, it has sought to introduce a new category of service providers within the scope of the rules. Called Telecom Identifier User Entities (TIUEs), these are entities that use telecom identifiers to validate their users or deliver their services.
MediaNama’s discussion aimed to understand the impact of these rules on businesses of different scales, workflow disruptions, and onerous compliance requirements. It also sought to explore the privacy implications of the draft amendment for end users and the jurisdictional issues arising between the IT Ministry and the DoT.
Our objective was to identify:
- The scope of the compliance burden that the draft amendment imposes on businesses
- Disruption to onboarding and validation workflows
- The intent behind the draft amendment
- The effectiveness of the MNV platform in preventing fraud and cybercrimes
- The effectiveness of the current KYC measures in place
- Risk of capturing businesses that have minimal telecom interactions (e-receipts/loyalty programs, and food delivery services)
- Scope for shifting to alternative forms of user validation, like email
- Impact of the platform on user privacy
- Possible limitations on the scope of information TIUEs will have to give back to the DoT
- Checks and balances to prevent misuse of MNV details by businesses
- Privacy safeguards that are necessary for the MNV platform
- Jurisdictional overlap between the IT Ministry and the DoT
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Executive Summary
In June this year, the Department of Telecommunications (DoT) released a draft amendment to the Telecom Cybersecurity Rules, 2024. With this amendment, businesses that use telecom identifiers to validate customers and deliver services will have a range of compliance requirements, including sharing data related to the identifiers with the Government and validating users via a Mobile Number Validation (MNV) Platform. During MediaNama’s discussion on the amendment to the rules, speakers pointed out several concerns about the broad scope of its application. They noted that the rules provide limited clarity on how the platform would function and what information would be shared with Telecom Identifier User Entities (TIUEs) seeking user validation services. Unanimously, participants expressed that the Government should provide transparency about the platform’s functioning. Some argued that the unclear voluntary or mandatory nature of the platform leaves businesses unsure about whether they have to integrate it into their workflows, particularly if they rely heavily on mobile numbers. It was argued that the lack of safeguards on the type of information TIUEs may have to share with the Government or telecom providers could expose commercial data and create competitive risks. Some participants…
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