A report published today raises a difficult policy tension: how to scale fast takedowns of non-consensual intimate imagery (NCII) while protecting the sensitive data that takedown systems inevitably process. According to MediaNama, an RTI response confirms that the government’s Sahyog Portal will handle data linked to NCII, but the privacy measures for that data were not shared in the response. The core concern is straightforward: systems intended to protect victims can themselves become high-risk data repositories if security and governance are not transparent and strong.
NCII takedown workflows typically depend on some combination of user complaints, content URLs, and increasingly hash-based matching (so platforms can detect reuploads without repeatedly viewing the content). That approach can be extremely effective at scale, but it introduces questions: Who can access the data? How is it stored? What is the retention period? Is there encryption at rest and in transit? Are there audit logs? Are there clear constraints preventing misuse? The MediaNama report emphasizes that these privacy and protection details were not disclosed through the RTI response, leaving outside observers unable to evaluate safeguards.
This is not a niche issue. India is rapidly expanding its digital governance tooling across law enforcement coordination and platform compliance. A portal like Sahyog can become a central operational channel between intermediaries and government agencies. Centralization can improve speed and accountability, but it also increases the impact of any breach or insider misuse. For victims, the stakes are especially high because leaked NCII-related data can cause secondary harm even if the original content is taken down.
From an engineering standpoint, “privacy by design” is not optional in this category of system. Data minimization—storing only what is strictly necessary—is a key principle. So is differential access control, where only the smallest necessary set of officials can see sensitive fields, and platforms receive only the information required to comply with takedown requests. Strong cryptographic practices and tamper-evident audit logs become essential, as does independent security testing.
From a policy standpoint, non-disclosure of safeguards creates a trust deficit. While some operational details may reasonably be withheld for security reasons, baseline transparency about data handling is a common expectation for systems touching highly sensitive personal information. Publishing a high-level privacy and security architecture, retention guidelines, grievance mechanisms, and oversight structure can go a long way.
The larger implication is that India’s platform regulation era is maturing from “content removal rules” to “infrastructure for enforcement.” As that infrastructure grows, privacy governance becomes as important as the underlying legal authority. The RTI-reported lack of disclosed privacy measures is a warning signal: without strong, transparent protections, even well-intentioned tools can create new vulnerabilities.
