Setting the Context on the Need for a Governance Model for the AA Ecosystem

11 Sep 2023

Dr. Arghya Sengupta the founder and Research Director at Vidhi Centre for Legal Policy, set the tone for the exposition of the Nurturing a User-Driven Governance Entity for the Account Aggregator Ecosystem in India (NUDGE) report. He underlined the pressing need for establishing a governance model tailored to the context of Account Aggregators (AA) in India.

His insights revolved around the vital role played by the Digital Personal Data Protection (DPDP) Act and the concept of a consent manager in navigating the complexities of data sharing in the digital economy. Further, Dr. Sengupta recommended a semantic shift to highlight the AA ecosystem’s user-centric approach. He advocated for the term “aggregator accounts” to replace “account aggregators” to ensure the focus remains on individuals.

Dr. Arghya Sengupta

Central to his speech was the need to situate the individual firmly at the heart of the AA framework. Dr. Sengupta put forth a triad of recommendations: firstly, licensing Account Aggregators as consent managers under the aegis of the data protection board; secondly, recognizing Sahamati as the self-governing entity for the financial ecosystem within the purview of RBI’s Account Aggregator Master Directions; and finally, incorporating references to the RBI Account Aggregator Master Directions within the forthcoming Data Protection Rules to establish an unambiguous governance structure.

In his speech, Dr. Sengupta presented an image of the “India Fractal”– a networked architecture where Account Aggregators function as vital nodes, facilitating the seamless flow of data, thus forming intricate connections among various data stacks. Ultimately, Dr. Sengupta aimed to draw attention to the overarching objective of AAs in empowering individuals as the rightful custodians of their digital personal data.


Listen to Arghya speak at this event here. This workshop was co-hosted by Vidhi Centre for Legal Policy and Sahamati. Check out the link for more speakers and their blogs: https://sahamati.org.in/events/governance-for-data-empowerment/