Naavi.org

This is just to record the night of 21/22nd June 2025, IST as an important day of our generation when we might have seen the closest to a World War 3 scenario.

India successfully conducted the Sindhur operations a few weeks back and hit Pakistani nuclear facilities significantly. But inside these facilities the US was hurt and moved into force a ceasefire before the final assault.

In Iran however, the same USA has moved in to neutralize the nuclear capabilities of Iran. Though the blow could be crippling, the counter action could create lot of problems to US in the form of terrorist attacks the way India has been bled for decades by Pakistan.

Neutralization or debilitation of terrorist forces anywhere in the world is welcome and as responsible global citizens we need to take note of this day as one of the most important day of our life.

Naavi

DPDPA Compliance is a complex process which requires discovery of personal data to which the act is applicable, Classifying it appropriately, understanding how the different sections of the Act apply to the data and determining what risks of non compliance exists, what Governance and Technical measures are to be initiated to mitigate the risks.

Many companies might have already initiated some measures in this regard. Many companies are developing products and services to assist the companies for compliance.

In this scenario, FDPPI as the apex organization promoting DPDPA Compliance has initiated a project to provide One free assessment of DPDPA Compliance for any Company in India per week (Till the scheme is withdrawn at its discretion).

The assessment requires one online session of around 90-120 minutes with the DPO or equivalent senior management person who may be assisted by others in the company. During the session, Naavi will conduct an online evaluation interview with appropriate questions and record the answers.

Based on the answers provided, an evaluation report would be issued.

The evaluation would be based on the celebrated DGPSI system used by FDPPI.

There are no strings attached to this free offer which is a near substitute for a Gap Assessment which would normally cost a few lakhs for any company.

The offer is based on requests received and on first cum first served basis. Once the requests are received, the interviews would be scheduled appropriately. Initially around 12 bookings would be accepted for the next 3 months and a decision will be taken on its continuance.

We invite interested DPOs to contact through email to Naavi . Kindly use the subject line “Free DPDPA Assessment”.

Naavi

P.S: I have received a query about why FDPPI is giving this assessment free even if it is for one company per week.

I would like to state that there are two objectives.

1. To remove the fear about DPDPA Compliance.
2. To prevent companies being mislead.
3. To provide an indication for Cyber Insurance readiness for DPDPA risk

Naavi

The Air India crash has a distinct signature of what experts call as a near improbable total two engine failure. However this also significantly increases the possibility of an “Electronic Sabotage” which could have caused the fuel cut-off or hydraulic failure etc which the experts indicate as a possible reason.

Though Air India is no longer a national carrier and is as much private as any other airline, the perception is that its reputation good or bad is linked to the reputation of India. Hence the enemies of India both within the country or outside target the airline to indirectly bring down the reputation of Air India. Hence Air India faces an “Enemy Risk” which other airlines donot face.

Since today’s aircrafts are all controlled by electronics, the safety of the aircraft is very much dependent on the safety of the electronic systems just like controlling a large computer network. It appears that there needs to be a CISO for every aircraft.

The more we think Air India is the nation’s pride, the more attention we would attract of Pakistani terrorists.

One of the Risk management strategies for the airline now is to change its name though it would be a sad decision to take.

Naavi

In an interesting decision of the UP State Consumer disputes redressal Commission, WhatsApp has been considered as a “Paid Service” with the payment having been received in the form of personal data shared by the account holder.

(Refer: article the420.in)

Naavi has been advocating the “Data Valuation” as one of the essential features of Data Management in a company and valuing of data and its disclosure is a recommended procedure under the DGPSI (Data Governance and Protection Standard of India) framework of compliance.

The exact value of the data may be under dispute but the fact that data has a a value is indisputable. In this case, the value of the data has not been specified in rupee terms but whatever is the benefit used by WhatsApp is to be treated as the consideration passed.

Hope Income Tax and GST is not applicable !

Naavi

For a long time there has been a discussion on whether the computer systems of an aircraft can be manipulated through external interference.

The tragic Ahmedabad plane crash will revive this discussion since there are certain indications of the possibility of such sabotage.

Apart from the social media watchers who are revealing some earlier X posts to suggest a terror plan, astrological analysis of the event also indicate the possibility of sabotage.

It is time the technical concerns, media concerns and astrological concerns may all be put to test with the investigations of the crash.

Let’s us watch the developments.

Naavi

We are all aware that Cookies are hosted on websites and they collect some technical information from visitors.

Normally cookies are implanted in the user’s system through at a location assigned by the browser. It is a text file and may contain some information.

The session cookies are those files which exist during a session and are automatically cleared when the session ends. Persistent cookies are those cookies that remain in the system and are available for future reference.

When a person visits a websites, a “Cookie Consent” is taken in which normally an option is given to provide consent for “Necessary Cookies”, “Statistical Cookies” and “Marketing Cookies”. Necessary cookies are normally mandatory while others can be optional.

When the person visits the same website again, the web server checks for the existence of the cookie related to the webserver using the cookie identity. Once it is found, it may use the information there in, to record the current session as related to the previous session. The web server may keep its own record of the earlier session and therefore build a profile of the user in its systems.

Certain cookies (mostly in the category of necessary cookies) are meant only to record the operating system, the browser used which are required for configuration of the web page. If it identifies the person as coming from a mobile, it may present a compatible page to enhance the viewer’s experience. If the information picked up is IP address, it can be analysed to identify the user’s location. Based on the location of the user, the content can also be modified.

In such uses the identify of the individual may not be required and hence the information may remain technical and statistical information of the “De-identified Personal Information” category.

However it is possible that some cookies which are “Persistent Cookies” and not deleted after the session, may capture more identifiable data of the individual and store it for future use. In such cases, a question arises whether the Cookie is a “Personally identifiable information” as per the data protection laws such as GDPR or DPDPA.

If a person is normally visiting a website and does not provide any of the information such as his name, email address etc in the process, the Cookie can only access statistical and technical information. In such cases it may not be a “Personally identifiable information” . If however the web server maintains such data which is linked to some other identified data in its possession and can link the current session with the personal information already available with the server, then the cookie gathered information along with the available information together becomes personally identifiable and comes under data protection laws.

The consent to be taken by the web site therefore depends on what is the configuration of the Cookie and whether any personal data of the visitor is already with the web server and also whether the cookie is a persistent cookie or not.

If cookies are not “Secure Cookies” the data may be transferred on http connections without transit encryption.

Usually the web sites are managed by the hosting company and the data fiduciary may not have a clear understanding of what cookies are in place and what kind of parameters they collect.

Hence it is necessary for DPOs to collect this information and construct their cookie policy appropriately. In particular we need to understand if cookies collect information that are of personal nature and whether any copies of such information are stored in third party accessible systems.

Currently websites take a consent which is not specifically explaining what is the purpose of the cookie, what type of information it collects, how long it retains, how it is used etc. Hence it may be necessary to list each cookie and obtain consent for each cookie separately. The current practice of taking the consent for all cookies or for categories of cookies like functional cookies or advertising cookies etc. needs to be modified forthwith.

If DPOs donot take control of the cookies on their websites, they may be a source of concern at any point of time. Cookie Control may be simple but needs to be managed along with a periodical audit.

Naavi