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ARTICLE
Access Management (IAM) tools (as discussed earlier) allow thereby automating enforcement measures. Access Control
for safe identity verification while reducing data exposure. Mechanisms tools such as Single Sign On, zero trust along
Data Masking and other anonymization tools such as with Multi Factor Authentication, Adaptive authentication
Pseudonymization (replacing an attribute such as name, based on real time risk assessment mechanisms support
date of birth with a code or number) will help banks handle dynamic enforcement of data access policies.
user requests while lowering the risks involved in direct
access to personal information. (F) Maintaining Records of Processing Activities
(RoPA).
(C ) Impact Assessment
Under the new data protection regime, organizations have
It is highly likely that Banks will be categorized as Significant
to keep comprehensive records of their personal data
Data Fiduciaries (SDF) under DPDPA. In that case, it will be processing operations including the purposes of processing
mandatory for banks to carry out Data Audits and Data and data categories as well as retention periods. Banks can
Protection Impact Assessments (DPIA) periodically. Banks use AI-powered tools for Automated Record -Keeping. Logs
may use the following PETs: can be maintained securely using differential privacy and
Automated Risk Evaluation Tools: Real time encryption techniques which protect personal data.
monitoring of compliance risk can be possible using AI
enabled PETs. Such tools are also capable of generating (G) Prevention from Breaches and Security of
reports that are critical for conducting DPIAs.
Data
Privacy Assured Audit Logs: Encrypted and Last but not the least, India's flagship data protection law
unchangeable logs that are transparent and requires organizations to establish strong security protocols
accountable but do not reveal any user information. to prevent unauthorized data access and potential
Differential Privacy: Helps organizations analyze large information leaks or breaches. Banks are already using End-
datasets for audits while ensuring that no individual data to-End Encryption technology to safeguard information from
points can be reverse engineered. unauthorized access throughout both transmission and
storage processes. Further, AI-based PETs can be used to
(D) Purpose Restriction and Data Minimization help prevent potential breaches by detecting unauthorized
access patterns. This will ensure real-time anomaly
At present banks use a large pool of diverse customer-
detection.
related data for developing credit assessment and risk
assessment models. However, DPDPA has mandated that Challenges to adoption of PETs in Indian
organizations should collect only bare minimum data for a
specified purpose and prevent unauthorized access or usage. Banks
To comply, banks need to introduce newer models which rely Lack of Use Cases - The technology surrounding PETs is
on fewer data points or uses alternative data sources (e.g. rapidly evolving and is in the early adoption phase. There
Data from social media). PETs such as Federated Learning are very few banks in India which are actively using PETs in
will be useful for banks to build credit models using real life banking and finance scenarios.
decentralized data without sharing raw data across
institutions. Synthetic Data (artificial data generated to Low level of Awareness - Data Privacy, as a concept, has
reproduce the original data statistically) is another such PET gained prominence in the last few years. However,
that banks can use for data analytics without revealing real awareness about the concept of PETs and their importance
user information. in enhancing data privacy is still not at the desired level.
Leaders in the banking industry must promote the concept
(E) Policy Management down the line for its early adoption.
Banks will need to formulate and implement clear policies
regarding processing, retention, and security of personal High level of Investment - Effective implementation of PETs,
data to comply with DPDPA provisions. AI-enabled PETs can "entities must develop internal technology stacks or
perform ongoing monitoring of data policy compliance software to create unified audit trails, build data inventory
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