Dear Dr. ‘Bosun Tijani, well done to you and the team on this draft. Just a few thoughts after going through.
✨ Suggested Additions
1. Provisions for digital literacy programs: India's National Digital Literacy Mission (IDLM) which has been adopted as a full-fledged Government scheme, which sets provisions to educate the populace on digital technologies, internet safety, and others, can be incorporated.
2. Support for Startup and SMEs: Programs similar to Singapore's Startup SG can be studied, which introduces incentives, subsidies, and support mechanisms specifically targted at starups and SMEs. This could be in a SOP form and can be contextually updated where need be.
3. Capacity Building in Government Agencies: wherever there is a good idea implemented, there's often always a challenge of continuity. An interative training for government employees to ensure the efficient use of digital tools and technologies can be incoroporated in the bill.
🔑 Suggested Modifications
1. Part III on Electronic Signatures: A suggestion will be to simplify this section to broadly accept digital signatures that comply with international standards. This includes stipulating specific Public Key Infrastructure (PKI), and related standards. In my experience working on Cryptography, standards are extremely key, regardless of implementation.
Meanwhile, the procedures for retaining documents, records, and the likes, may overlap with existing best practices and standards for digital records management. It will be great to reference established digital records management standards (such as ISO 15489), rather than detailing specific steps, because that may be prone to irregularities.
2. In terms of the licencing requirements, it will be great to introduce a tiered system, for example, one that provides an easier entry for small businesses and startups, and creates more rigorous requirements for larger enterprises. A self-regulatory policy framework, with periodic audits is more optimal than an upfront exhaustive licensing.
3. In terms of mandatory local data storage, it may be better to allow data to be stored on international servers, that comply with local data protection standards. Like an hybrid allowance. One way to implement this in the interim, is to implement cross-border data flow agreements - which should incorporate the existing standardized NDPR framework, in my opinion. So we're not replicating efforts.
4. Finally, in terms of Cybersecurity standards, a one-size-fits-all cybersecurity requirment may not be suitable for all types of businesses and may be costly to implement. It will be great to adopt a flexible, risk-based approach to cybersecurity that allows businesses to implement measures proportionate to their risk profile. However, adherence to international cybersecurity frameworks like the NIST Cybersecurity Framework, should be mandated.
My 2-Cent and hope this sees fruition. Have a great weekend and week ahead.
Following the first stakeholder engagement with the media on the Digital Economy & e-Governance Bill, we are pleased to formally release the draft bill to the general public for review and input as it goes through the various stages of reading at the National Assembly.
This release is ahead of the Ministry’s plan for this bill to be taken round the country to ensure inclusive and wide ranging input and understanding, and its impact and benefits to the growth of our digital economy.
We look forward to receiving and collating your feedback through various channels including here on LinkedIn as well as through the email address: policy@fmcide.gov.ng
