India’s Most Critical Trade & Regulatory Compliance Digest

Ameet Datta, Suvarna Mandal | February 2023

Lex Witness in association with The Trade & Regulatory Compliance Practice Desk at Saikrishna & Associates brings to you a detailed analysis on select updates and notifications.

MEITY HAS PROPOSED AMENDMENTS, IN RELATION TO ‘ONLINE GAMES’ AND ‘ONLINE GAMING INTERMEDIARIES’, TO THE INFORMATION TECHNOLOGY (INTERMEDIARY GUIDELINES AND DIGITAL MEDIA ETHICS CODE) RULES, 2021

The Ministry of Electronics and Information Technology (“MeitY”), on 2nd January 2023, invited public feedback on the proposed draft amendments, in relation to ‘online games’ and ‘online gaming intermediaries’ (“Draft Rules”), to the Information Technology (Intermediary Guidelines and Digital Media Ethics Code) Rules, 2021 (“IT Rules”). The Draft Rules were proposed right after the notification of the Government of India (Allocation of Business) (Three Hundred and Seventieth Amendment) Rules, 2022 as per which MeitY has been made the nodal ministry for “matters relating to online gaming”.

Some of the key draft amendments proposed by the MeitY to the IT Rules are as follows:

Key definitions: The Draft Rules propose to introduce definitions for the terms “online game” and “online gaming intermediary”:

Online game: An online game has been defined as a game that is offered on the “Internet” and is accessible by a user through a computer resource if the user makes a “deposit” with the expectation of earning “winnings”. The explanation to this proposed definition clarifies that a deposit can be made by a user in cash or in kind.

Further, as per the explanation, ‘winnings’ would mean a prize (in cash/kind) distributed/intended to be distributed to a user of an online game based on their performance and in accordance with the rules of the online game, and, the term ‘Internet’ would mean a “combination of computer facilities and electromagnetic transmission media, and related equipment and software, comprising the interconnected worldwide network of computer networks that transmits information based on a protocol for controlling such transmission”

Online gaming intermediary: An online gaming intermediary has been defined to mean an ‘intermediary’ offering one or more than one online game.

Due diligence by an intermediary: The Draft Rules seek to amend Rule 3 of the IT Rules, which provides the due diligence requirements of an intermediary, in the following manner:

Firstly, the Draft Rules propose to bring an online gaming intermediary within the scope of an intermediary for the purposes of due diligence under the IT Rules.
As per the Draft Rules, an intermediary would be required to take reasonable efforts to cause the user of the computer resource to not “host, display, upload, modify, publish, transmit, store, update or share any information” that is identified as fake or false by the fact check unit at the Press Information Bureau or other agency authorized by the Central Government for fact checking or a department of the Central Government responsible for fact checking. In fact, this draft amendment was introduced in the recent version of the Draft Rules that were published on 17th January 2023. Further, intermediaries would also be required to take such reasonable efforts in respect of information in the “nature of an online game” which is not in conformity with the existing laws, including the laws related to gambling and betting, as well as those related to competency of a person to enter into a contract.
Before hosting/publishing/ advertising an online game for a consideration, an intermediary would be required to ascertain, from both the online gaming intermediary as well as the self-regulatory body (which will be established if the Draft Rules are implemented in their current form), that the online game has been registered with the self-regulatory body. The intermediary would also be required to display that the online game is registered on its website, mobile based application or both.

Additional due diligence by online gaming intermediary: The MeitY has proposed additional due diligence requirements that an online gaming intermediary will be required to observe while discharging its duties under the IT Rules. Some of the additional requirements that would be applicable to online gaming intermediaries if the Draft Rules are implemented in their current form are as follows:

A “demonstrable and visible” mark of registration of the online game will have to be displayed by the online gaming intermediary.
The online gaming intermediary would be required to have a physical contact address in India.
Through the rules and regulations, privacy policy, terms of service and user agreements of the online gaming intermediary, the users of the computer resource will have to be informed about inter alia, all the online games offered by the online gaming intermediary as well as details regarding withdrawal/refund of deposit, risk of associated financial loss and addiction, the KYC procedure for registration of a user’s account, framework of the self-regulatory body of which such online gaming intermediary is a member.
A random number generation certificate and a no bot certificate from a reputed certifying body will have to be published on the website/mobile based application/both of the online gaming intermediary for each online game offered by it.
The online gaming intermediary will also be required to identify the user and verify such identity at the time of commencement of user account-based relationship for an online game, using the procedure followed by entities regulated by the Reserve Bank of India for identification and verification. Further, users must be allowed to voluntarily verify by using appropriate mechanism and such voluntarily verified users will be provided with a demonstrable and visible mark of verification.
A grievance redressal mechanism will have to be established that would also allow the complainants to track the status of their complaints.
Further, a Grievance Officer, a Chief Compliance Officer as well as a nodal contact person will have to be appointed.
Any change in the rules and regulations, privacy policy or user agreement would have to be informed, in English or any of the 22 languages specified in the Eighth Schedule of the Constitution, immediately after such change is effected.

Establishment of Self-regulatory body(ies): The MeitY has proposed to establish self-regulatory bodies (“SRO”) that will be responsible for registration and developing a framework to secure conformity by the online games and online gaming intermediaries.

These SROs will be required to register with the MeitY as per the criteria provided in the Draft Rules. This registration can be suspended or revoked by the MeitY.
Further, a registered SRO can register an online game and grant membership to an online gaming intermediary basis the criteria for such registration/membership as provided in the Draft Rules.
A registered SRO will be required to communicate the fact of the recognition of every online game registered with it to the Central Government.
A registered SRO will also be required to establish a grievance redressal mechanism for resolution of complaints of users that have not been resolved by the grievance redressal mechanism of its member online gaming intermediary.

Notification of any other game as an online game: As per the Draft Rules, MeitY can notify and treat a game, that has been made available on the Internet and is accessible through a computer resource ‘without making a deposit’, as an “online game” if the MeitY is satisfied that such a game can create risk of harm to “the sovereignty and integrity of India or security of the State or friendly relations with foreign States or public order, on account of causing addiction or other harm among children”.

The Firm’s Take

There are certain concerns regarding the Draft Rules that need to be addressed by the MeitY. Firstly, there is no central legislation on online gaming. The Draft Rules seek to regulate online gaming in the absence of a legislative enactment for regulating online gaming. This is a concern since the existing law would in any case prohibit gambling applications/ games of chance. Glaring lack of legislative enactment for regulating online games which are games of skill (both paid/unpaid models) is of significant concern.

Secondly, publishers of games cannot possibly be classified as intermediaries because they curate and publish their own content and do not fall within the legislative definition of what constitutes an intermediary. In the true sense, the term ‘online gaming intermediaries’ would include game stores, such as the Xbox Games Store or the PlayStation Store, and other online mobile app stores. To expect these intermediaries to verify and authenticate users and to undertake due diligence steps, which should ideally be borne by the publishers of online games, will not only be impractical but perhaps unachievable.

Moreover, to expect online intermediaries, such as app stores and game stores, to individually register online games published by third party publishers is not only unrealistic but also goes against the way gaming businesses are structured. The Draft Rules also present the possibility of complicating the relationship between users/subscribers and publishers of online games since the Draft Rules, in their current form, require intermediaries to virtually bypass the gaming publishers while engaging with the users/subscriber of individual online games to comply with the additional due diligence requirements.

The Ministry would also have broad powers to declare any game which is made available on the Internet and accessible by a user through a computer resource, without making any deposit, as an online game which goes beyond the scope of what the Draft Rules seek to regulate.

While the intention behind introducing the Draft Rules is vested in the interest of the end user of an online game, the above noted concerns need further consideration by the MeitY. There is a need for a robust uniform regulatory framework for online games which is balanced and provides the much-needed assurance to the online gaming industry whose fates have mostly been decided by the States under their respective laws.

GOVERNMENT TO HOLD PUBLIC CONSULTATION ON PROPOSED AMENDMENT OF IT RULES WITH RESPECT TO FACT CHECKING MISINFORMATION BY GOVERNMENT AND DUE DILIGENCE BY INTERMEDIARY TO PREVENT SHARING OF FALSE, UNTRUE OR MISLEADING INFORMATION

Introduction

The Ministry of Electronics and Information Technology (“MeitY”) has invited comments from stakeholders and the general public on an amendment proposed to Rule 3(1)(b)(v) (“proposed amendment”) of the Information Technology (Intermediary Guidelines and Digital Media Ethics Code) Rules, 2021 (“IT Rules”) with respect to due diligence obligations of social media and other intermediaries regarding fact checking misinformation by Government to prevent sharing false, untrue or misleading information.

Background

The MeitY on 2nd January 2023, had published draft amendments to the IT Rules in relation to online gaming. While granting an extension of time for the public consultation process, the MeitY through a press release also announced a proposed amendment relating to due diligence by an intermediary under Rule 3(1)(b)(v) of the IT Rules.

Rule 3(1)(b)(v) requires social media and other intermediaries to comply with due diligence guidelines by making reasonable efforts to cause their users not to host, display, upload, modify, publish, transmit, store, update or share information which is patently false and untrue or misleading in nature. The amendments now proposed to the Rules expand the applicability of these Rules to “online gaming intermediaries” and proposes to mandate that the due diligence requirements will include taking down information identified as fake or false by the Fact Check Unit of the Press Information Bureau (“PIB”) (https://factcheck.pib.gov.in/ and Twitter handle @PIBFactcheck) as “misinformation or information which is patently false and untrue or misleading in nature”.

The PIB is a department falling under the Ministry of Information and Broadcasting, generally tasked with communicating government policies and news/information pertaining to the Government of India. It appears that the PIB or any other agency authorised by the Central Government will be tasked with “fact checking” or identifying misinformation in respect of any business of the Central Government. As a result of this proposed amendment, intermediaries will be required to take down any post/information identified by the agency authorised by the Central Government under the proposed Rule as constituting misinformation or information which is patently false and untrue or misleading in nature, failing which such intermediary may be unable to rely on the safe harbour defence under Section 79 of the Information Technology Act, 2000 (“IT Act”) for non-compliance of its due diligence obligations as mandated under Section 79(2)(c) of the IT Act.

The Firm’s Take

Fake news has the potential to misinform the public and may even lead to incitement of communal disharmony and disturbance to peace. It is therefore highly desirable that fake news be checked, countered and taken down. However, given that the PIB is part of the Government and not an independent watchdog, concerns about censorship in the guise of fact checking are naturally bound to arise, particularly in a vibrant democracy such as India, with diverse viewpoints. Critical analysis and examination of the government’s policies and actions has been an enduring and healthy aspect of Indian democracy. Therefore, countering fake news while not stifling legitimate criticism of the government may be more effectively done by an independent body.

Previously, the Ministry of Information and Broadcasting had also issued an advisory to private news channels, noting that certain TV news channels have made false claims to incite audiences, and asking TV channels to refrain from airing such content. To that extent, the amendments proposed by MeitY are aligned with the government’s previous actions against fake news. Presently, the Indian Penal Code, 1860, Information Technology Act, 2000 and Disaster Management Act, 2005 contain provisions that criminalize actions tantamount to circulating fake news

Accordingly, while the proposal to take down content that is disproven by fact checking is a welcome one, it may be advisable to mandate an independent body with the task of fact checking, rather than government affiliated bodies as is presently envisaged.

Bureau Of Indian Standards Publishes Standard For Usb Type C Receptacles, Plugs And Cables

On 9th January, 2023, the Bureau of Indian Standards (“BIS”) established and notified the Indian Standard ‘IS/ IEC 62680-1-3:2022 Universal Serial Bus Interfaces for Data and Power Part 1 Common Components Section 3 USB Type-C Cable and Connector Specification’ (“Standard”) for USB Type C receptacles, plugs and cables.

According to the press release, the Standard is an adoption of the existing International Standard, IEC 62680- 1-3:2022, and provides requirements for USB Type-C ports, plugs and cables for use in various electronic devices like mobile phones, laptops, notebooks etc. Further, the Standard has been established to assist with the Government’s mission to reduce e-waste and move towards sustainable development as it would provide common charging solutions for smartphones and other electronic devices, in turn, reducing the number of chargers per consumer.

The Standard has been established and notified under BIS’s power of establishing Indian Standards under Rule 15 (1) of the Bureau of Indian Standards Rules, 2018 (“BIS Rules”). However, as per Rule 24 (2) of the BIS Rules, the standard is voluntary and will not be binding until it is referred to in a legislation or made mandatory by a specific order of the Government (like the Electronic Goods Compulsory Registration Order).

Presently, no order/legislations have been issued mandating the Standard, however news reports suggest that the USB Type-C is likely to be adopted as the standard charging port in India by March 2025.

The Firm’s Take

While from an environmental standpoint, the potential standardisation of charging ports appears to be a step in the right direction, however, there is a need to carefully assess the long-term and short-term implications of this move and the government must consider other relevant factors prior to the mandatory implementation of this Standard in India. For instance, the European Union, prior to amending its Radio Equipment Directive 2014/53/EU for standardizing chargers, conducted a detailed Impact Assessment and submitted the Impact Assessment Report which carefully investigates and analyses economic, social and environmental impacts in assessing the policy options. Other significant impacts such as impact on consumers’ perspective and convenience, effects on the industry, SMEs, innovation, competitiveness were also analyzed in the report. For example, the report notes that “the environmental impact from the fact that USB Type C cables and connectors are heavier (by 21.6% to Lightning and 237% to USB micro-B) are larger than the reduction from standalones sales of cables”. Therefore, while in the long run, the potential harmonisation of charging solutions is likely to benefit environmentally, it is important that all potential impacts due to the change in this policy are carefully analyzed by the government. A phased out implementation is ideal for the Indian context as most consumers retain their devices (and in turn, the chargers) for longer periods than average.

The Department Of Consumer Affairs Releases ‘endorsement Know-hows!’ For Celebrities, Influencers, And Virtual Influencers On Social Media Platforms

On 20th January 2023, the Ministry of Consumer Affairs (“Ministry”) released a guide on ‘Endorsement Know-hows!’ for celebrities, influencers, and virtual influencers on social media platforms (“Guide”). The Guide has been introduced to address the issues relating to celebrity endorsements and misleading advertisements through social media platforms. The Guide requires all influencers, celebrities (famous personalities including but not limited to the entertainment and sports industry), and virtual influencers (fictional computer-generated ‘people’ or avatars who have realistic characteristics, features, and personalities of humans, and behave in a similar manner as influencers) that have the power to influence the purchasing decisions of their audience to provide relevant disclosures while endorsing products and services.

The Ministry Press Release to the Guide states that the same are in alignment with the Consumer Protection Act, 2019 (“CPA”), and its allied rules, the Guidelines for Prevention of Misleading Advertisements and Endorsements for Misleading Advertisements, 2022 (“Guidelines on Prevention of Misleading Advertisements”), and that any endorsement by influencers/celebrities will have to comply with the same. It is worth noting that this Guide has not been notified by the Ministry under the CPA and therefore does not have the force of the law. However, given the recent scrutiny of the Advertising Standards Council of India and the Ministry over celebrity endorsements we anticipate that the Guide, read with the Guidelines on Misleading Advertisements will be referenced by ASCI and the Central Authority to regulate advertisements.

The salient features of the Guide are as follows:

Disclosure of Material Connection – The Guide requires any person with access to an audience and the power to influence their audience’s purchasing decision with respect to a product, brand, or experience to disclose any “material connection” between the advertiser and the celebrity/influencer. The Guide defines “material connection” as any monetary or other compensation, free products with or without any conditions (such as gifts or discounts), contest and sweepstakes entries, trips or hotel stays, media barters, coverage and awards, or any family, personal, or employment relationship.
Disclosures should be Hard to Miss – The Guide requires the celebrities/influencers to ensure that the disclosure of material connections is hard to miss, i.e., the endorsement message should be clear and prominent. Additionally, it should not be included with a group of hashtags or links. The Guide further provides disclosure requirements on the following types of media:

Endorsement in a Picture: The disclosures are required to be superimposed on the image in a manner that viewers can notice it.
Endorsement in a Video: Disclosures should appear in the video endorsing the product/service and not only in the description of the video. The disclosure to be both in audio and video format.
Endorsement in a Live Stream: The disclosures should be displayed continuously and prominently in a live stream.

Features of the Disclosure – The Guide prescribes specifications with respect to the form and manner of disclosures:

Simple and Clear: The disclosure is required to be made in simple and clear language. Additionally, the Guide states that on limited space platforms, like Twitter, the celebrities/influencers should display terms such as “XYZ Ambassador”.
Terms Allowed: In order to indicate disclosures of material connection, the use of terms such as “advertisement”, “ad”, “sponsored”, “paid promotion” or “paid” are allowed.
Language: The Guide requires the endorsements and disclosure to be in the same language.
Platform Tool: The disclosure of material connection by the celebrity/ influencer/virtual influencer is required to be different from platform disclosure tools.

Due-Diligence Requirements –The Guide further requires celebrities and influencers endorsing the product/ service of an advertiser to review and assure themselves that the advertiser can validate the statements made in the advertisement. It further recommends that the product/service that the influencer/celebrity seeks to endorse must be used/experienced by them.
Failure to Disclose Material Connection – In the event, a celebrity/ influencer fails to disclose any material connection or does not comply with the CPA or its allied rules, then such celebrity/influencer can be liable for strict action under the law.

The Firm’s Take

The Guide has been introduced with the aim of preventing unfair trade practices and misleading advertisements on social media platforms, especially considering the large number of users on these social media platforms that may fall prey to misleading promotions by celebrities and influencers that have some influence on the purchasing decisions of their audience. The Guide, read along with the CPA and Guidelines on Prevention of Misleading Advertisements will likely provide the regulatory framework to regulate celebrity endorsements on online platforms. Further, it appears that the Guide also provides teeth to the Advertising Standards Council of India’s Guidelines for Influencer Advertising on Digital Media.

Jan Vishwas (amendment Of Provisions) Bill 2022 – A Brief Review

On 22nd December 2022, the Hon’ble Minister for Industry and Commerce introduced the Jan Vishwas (Amendment of Provisions) Bill, 2022 (“Bill”) which seeks to decriminalise minor offences and rationalise monetary penalties by amending 183 provisions across 42 Acts. The Bill has been referred to a Joint Parliamentary Committee which is expected to submit its report in the upcoming budget session of the Parliament.

Salient Features

Decriminalisation of minor offences: The Bill proposes to decriminalise procedural lapses and minor non-compliances which do not have large negative externalities and instead seeks to impose monetary penalties for penalising each such contravention or non-compliance.
Appointment of Adjudicating Officers: The Bill proposes empowering the Central Government to appoint adjudicating officers for determining the amount of penalty payable under the acts as amended under the Bill including the Air (Prevention and Control of Pollution) Act, 1981, the Environment (Protection) Act, 1986, etc.
Automatic increase in fines and penalties: The Bill seeks to increase the minimum amount of fine and penalty levied by ten per cent after the expiry of every three years once the Bill is enacted into a law.

From a broad business compliance perspective, the following key legislations have been proposed to be amended under the Bill:

The Information Technology Act, 2000 (“IT Act”)

Increased monetary penalty under Section 70 (7) – The Bill seeks to increase the penalty imposed under Section 70B (7) from Rs 1 lakh to Rs 1 crore. Section 70B (7) penalises noncompliance with the directions issued under Section 70B(6) of the IT Act. It is worth noting that if the Bill is implemented in its current form then such a penalty would be imposed in case of any violation of the Indian Computer Emergency Response Team’s (“CERT-In”) Directions issued on 28th April, 2022 since the said Directions were issued under Section 70B (6) of the IT Act. The term of imprisonment of 1 year under Section 70B (7) remains unchanged.
Decriminalisation for disclosure of information in breach of lawful contract under Section 72A – The Bill seeks to decriminalise disclosure of information in breach of a lawful contract by any person (including an intermediary) by decriminalising the extant provision, which currently prescribes imprisonment for a term of up to 3 years or fine extending up to Rs 5 lakhs or both, by instead proposing a provision imposing a fine extending up to Rs 25 lakhs.
Decreased term relating to monitoring and collecting traffic data or information for cyber security under Section 69B – The Bill seeks to decrease the term of imprisonment for failure to provide technical assistance and facilities to authorised Government agency for accessing traffic data from 3 years to 1 year. Furthermore, the fine liable to be paid may extend to Rs 1 crore.
The Bill seeks to increase the powers of the adjudicating officer appointed by the Central/State Government (for adjudging contravention of provisions of the IT Act or any rule, regulation, direction or order made thereunder, and determining corresponding penalties) to the entire Act, and not just to limited provisions (i.e. Sections 43 to 47, IT Act) as is the case presently

The Environment (Protection) Act, 1986 (“EPA”)

Decriminalisation of any noncompliance/contravention of the EPA – The EPA currently criminalises any non-compliance/contravention with its provisions, or the rules/orders/directions issued thereunder with imprisonment for a term extending up to 5 years or a fine extending up to Rs 1 lakh or both. In cases, where the contravention continues beyond a period of 1 year after the date of conviction, the offender can be imprisoned for a term up to 7 years.
The Bill proposes to decriminalise non-compliance/contravention of the EPA, rules, orders and directions issued thereunder by relying on monetary penalties, and not imprisonment, for each such contravention or noncompliance. Such penalties which shall range between Rs 5,000 to Rs. 15 lakhs.
Similarly, in case of contravention of any of the provisions of the EPA by a company, then such company shall be liable to pay the penalty for “each such contravention” of minimum Rs 1 lakh extending up to Rs 15 lakhs. In case the errant company continues contravention of the EPA, then it shall be liable to pay an additional penalty of Rs 1 lakh for every day during which such contravention continues.
Additionally, the Bill proposes to decriminalise various other provisions (pertaining to contravention of standards, handling hazardous wastes, failure to render assistance to authorities, etc.) by seeking to impose monetary penalties only
Appointment of an Adjudicating Officer – The Bill proposes appointing an Adjudicating Officer (“AO”) who will be empowered to impose the penalties prescribed under the EPA based on various factors as identified in the Bill. The penalties imposed by the AO will be deposited into an ‘Environmental Protection Fund’ proposed to be setup under the EPA. Appeals against the order of the AO will lie before the National Green Tribunal.

Legal Metrology Act, 2009 (“LM Act”)

Decriminalisation relating to Quoting/publishing a non-standard unit – The penalty under Section 29 of the LM Act for quoting a non-standard unit is currently imprisonment up to one year/fine or both, on the second or subsequent offence. The Bill proposes to replace the imprisonment clause with a fine of Rs 50,000 for the second offence extending up to Rs 1 lakh and for the third and subsequent offence with a fine extending up to Rs 2 lakhs.
Decriminalisation relating to sale of commodities, etc. by non standard weight or measure – Section 34, LM Act penalises sale of any commodity by any means other than the standard weight or measure or number, with a fine ranging from Rs 2,000 extending up to Rs,5000 and mandates a term of imprisonment of up to 1 year or fine or both for the second or subsequent offence. The Bill seeks to decriminalise any violation of Section 34 by mandating a fine extending up to Rs 25,000 and for the second offence with fine which may extend up to Rs 50,000 and for the third and subsequent offence, with fine extending up to Rs 1 lakh.

The Firm’s Take

The introduction of the Bill is laudatory measure adopted by the Government of India to reduce compliance costs for business enterprises and enhance ease of doing business in India. The process of decriminalisation of minor offences will also have a salutary effect on reduction of cases in our judicial system by establishing an alternative mechanism for expeditious enforcement of various acts by prescribing monetary penalties for such minor offences. The Bill is a recognition by the Government of India of the inherent need to reduce the regulatory and compliance burden on business enterprises by imposing criminal liability only for serious offences and decriminalising procedural lapses which otherwise would have attracted criminal liabilities under the extant law.

About Author

Ameet Datta

Ameet Datta is a Partner at Saikrishna & Associates. He is an IP litigator and TMT lawyer with over 22 years of experience and wide ranging expertise across IP Law, Technology law, privacy and data protection law, white collar crime cases around data breaches, and, media & entertainment law specifically in relation to licensing, content aggregation & acquisition, film & music production, distribution/ licensing, format rights, defamation and right of publicity. Ameet has extensive experience with the creative sector in terms of multiple litigations including licensing disputes before the Courts & the Copyright Board. Ameet is closely involved with Copyright laws, Technology regulations and policy matters. In 2010, Ameet appeared as an expert witness before the Indian Parliamentary Standing Committee overseeing amendments to the Copyright Act, 1957. Ameet has been highly ranked as a recommended lawyer for IP Litigation, and, telecoms, media & entertainment by Chambers & Partners (Asia Pacific), WTR1000; as a recommended lawyer for IP litigation by Legal 500, and recommended as an IP Star by MIP

Suvarna Mandal

Suvarna Mandal is a Partner at Saikrishna & Associates. She has nearly a decade of experience in providing trade & regulatory compliance advice to domestic and international clients for understanding and complying with a wide range of national, state as well as sector-specific legislations and regulations in the spheres of telecommunications, technology law, consumer law, environmental law, product compliance and safety regulations (including packaging standards, labels and safety standards), data protection and privacy, media law, advertising regulations, etc. She provides end-to-end compliance counselling to clients across various industries and sectors such as software services, consumer electronics, technology, telecom, media, intermediaries, e-commerce, online value-added services sectors, consumer goods and medical devices. Suvarna also works closely with clients’ Government Affairs team to prepare strategic policy documents, representations and formal communications towards policy development and policy reform efforts with the Government.