Sunil Abraham, executive director of the Centre for Internet and Society, wrote this in response to the FactorDaily story on TwitterSeva, a special feature developed by Twitter’s India team to help citizens connect better with government services.

TwitterSeva is great, but it should not be considered a sufficient replacement for proper e-governance systems.

This is because there are several serious shortcomings with the TwitterSeva approach, and it is no wonder that enthusiastic police officers and bureaucrats are somewhat upset with the slow deployment of e-governance applications. They are also right in being frustrated with the lack of usability and scalability of existing applications that hold out the promise of adopting private sector platforms to serve citizens better.

Let’s take a look at why the TwitterSeva approach is not adequate:

1. Vendor and Technology Neutrality: Providing a level ground for competing technologies in e-governance has been a globally accepted best practice for about 15 years now. This is usually done by using open standards policies and interoperability frameworks.

India does have a national open standards policy, but the National Informatics Centre (NIC) has only published one chapter of the Interoperability Framework for e-Governance .

The thing is, while Twitter might be the preferred choice for urban elites and the middle class, it might not be the choice of millions of Indians coming online. By implicitly signaling to citizens that Twitter complaints will be taken more seriously than e-mail or SMS complaints, the government is becoming a salesperson for Twitter. Ideally, all interactions that the state has with citizens should be such that citizens can choose which vendor and technology they would like to use. Ideally, the government should have its own work-flow so that it can harvest complaints, feedback and other communications from all social media platforms be it Twitter or Identica, Facebook or Diaspora, and publish responses back onto them.

Apart from undermining the power of choice for citizens, lack of vendor and technology neutrality in government use of technology undermines the efficient functioning of a competitive free market, which is the bedrock of future innovation.

When it comes to micro-blogging, Twitter has established a near monopoly in India. There are no clear signs of harm and therefore it would not be wise to advocate that the Competition Commission of India investigate Twitter. However, if the government helps Twitter tighten its grip over the Indian market, it is preventing the next cycle of creative destruction and disruption. Therefore, e-governance applications should ideally only “loosely couple” with the APIs of private firms so that competition and innovation are protected.

2. Holistic Approach and Accountability: Ideally, as the Electronic Service Delivery Bill 2011 had envisaged, every agency within the government was supposed to (within 180 days of the enactment of the Act) do several things: publish a list of services that will be delivered electronically with a deadline for each service; commit to service-level agreements for each service and provide details of the manner of delivery; provide an agency-level grievance redressal mechanism for citizens unhappy with the delivery of these electronic services.

Notwithstanding the 180-day commitment, the Bill required that “all public services shall be delivered in electronic mode within five years” after the enactment of the Bill with a potential three-year extension if the original deadline was not met. The Bill also envisaged the constitution of a Central Electronic Service Delivery Commission with a team of commissioners who “monitor the implementation of this Bill on a regular basis” and publish an annual report which would include “the number of electronic service requests in response to which service was provided in accordance with the applicable service levels and an analysis of the remaining cases.”

Citizens suffering from non-compliance with the provisions of the Bill and unsatisfied with the response from the agency level grievance redressal mechanism could appeal to the Commission. The state or central commissioners after giving the government officials an opportunity to be heard were empowered to impose a fine of Rs 5000.

Unlike the piecemeal approach of TwitterSeva, the Bill had a much more comprehensive and accountable plan for e-governance adoption in the country.

3. Right To Transparency: Some of the interactions that the government has with citizens and firms may have to be disclosed under the obligation emerging from the Right to Information Act for disclosure to the public or to the requesting party. Therefore it is important that the government take its own steps for the retention of all data and records — independent of the goodwill and lifecycles of private firms.

Twitter is only 10 years old. It took 10 years for Orkut to shut down. Maybe Twitter will shut down in the next 10 years. How then will the government comply with RTI requests? Even if the government is not keen on pushing for data portablity as a right for consumers (just like mobile number portability in telecom, so that consumers can seamlessly shift between competing service providers), it absolutely should insist on data portability for all government use.

This will allow it to shift to a) support multiple services, b) shift to competing/emerging services c) incrementally build its own infrastructure and also comply with the requirements of the Right to Information Act.

4. Privacy: Unfortunately, thanks to the techno-utopians behind the Aadhaar project, the current government is infected with “data ideology.” There is an obsession with collecting as much data as possible from citizens, storing it in centralized databases and providing “dashboards” to bureaucrats and politicians. This is diametrically opposed to the view of the security community.

For example, Bruce Schneier posted on his blog in March this year (in a piece titled ‘Data is a Toxic Asset‘) saying: “What all these data breaches are teaching us is that data is a toxic asset and saving it is dangerous. This idea has always been part of the data protection law starting with the 2005 EU Data Protection Directive expressed as the principle of “Data Minimization” or “Collection Limitation”. More recently technologists and policy makers also use the phrase “Privacy by Design”. Introducing an unnecessary intermediary or gate-keeper between what is essentially transactions between citizens and the state is an egregious violation of a key privacy principle.”

5. Middle Class and Elite Capture: The use of Twitter amplifies the voices of the English-speaking, elite, and middle class citizens at the expense of the voices of the poor. While elites don’t exhibit fear when tagging police IDs and making public complaints from the comforts of their gated communities with private security guards shielding them the violence of the state, this might be a very intimidating option for the poor and disempowered.

While the system may not be discriminatory in its design, it will have disparate impact on different sections of our society. In other words, the introduction of TwitterSeva will exacerbate power asymmetries in our society rather than ameliorating them.

The canonical scholarly reference for this is Kate Crawford’s analysis of City of Boston’s StreetBump smartphone, which resulted in an over-reporting of potholes in elite neighbourhoods and under-reporting from poor and elderly residents. This meant that efficiency in the allocation of the city’s resources was only a cover for increased discrimination against the powerless.

6. Security: The most important conclusion to draw from the Snowden disclosure is that the tin-foil conspiracy theorists who we used to dismiss as lunatics were correct. What has been established beyond doubt is that the United States of America is the world leader when it comes to conducting mass surveillance on netizens across the globe. It is still completely unclear how much access the NSA has to the databases of American social media giants. When the complete police force of a state starts to use Twitter for the delivery of services to the public, then it may be possible for foreign intelligence agencies to use this information to undermine our sovereignty and national security.

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