Primer on Consumer Data Infrastructure

The emergence of large-scale data infrastructures in India to support financial services delivery (such as the proposed Public Credit Registry, the GSTN system, and the Indiastack) raises foundational questions regarding the role of the State and of the regulation of these infrastructures. These data infrastructures include the databases that aggregate information and data utilities that allow for various databases to exchange information. They seek to re-imagine and improve the credit information markets in India with roles for private and public information-collecting entities. They also seek to bring the benefits of the aggregation of such data to improve financial inclusion and supervision of the financial sector.The impact for individuals and firms whose information will be aggregated and shared needs to be understood. Consumer data forms the backbone of the information that will be passed through these infrastructures. This requires an understanding of the issues that arise from the interplay between the regulation of data infrastructures and the regulation of personal data. The impact of these new projects for existing financial infrastructures and databases in the country also need to be understood.These developments raise new considerations for regulators. The approach to the regulation and supervision of these databases and infrastructures is by no means certain in the Indian context. The effect they will have on the financial sector and the wider market, and accordingly the optimal stance for regulation remains to be understood. Finally, there is a need for clarity on the liability framework for entities accessing these infrastructures and those in charge of running the infrastructures especially in cases where harms or losses are suffered due to their misuse, breach or failure