TRAI’s Consultation Paper on OTT Platforms
Introduction
Recently, a Consultation Paper on Regulatory Mechanisms for Over-The-Top (OTT) Communication Services was published by the Telecom Regulatory Authority of India (TRAI). The paper explores several OTT regulation-related challenges and solicits input from stakeholders on a suggested regulatory framework. We’ll summarise the paper’s main conclusions in this blog.
Structure of the Paper
The Telecom Regulatory Authority of India’s Consultation Paper on Regulatory Mechanism for Over-The-Top (OTT) Communication Services and Selective Banning of OTT Services intends to solicit comments and recommendations from stakeholders about the regulation of OTT services in India. The paper is broken up into five chapters that cover the introduction and background, issues with regulatory mechanisms for OTT communication services, issues with the selective banning of OTT services, a summary of the issues for consultation, and an overview of international practices on the topic. Written comments from interested parties are requested and may be sent electronically to the Advisor (Networks, Spectrum and Licencing) at TRAI. These comments will also be posted on the TRAI website.
Overview of the Paper
- Chapter 1: Introduction and Background
- The first chapter of the essay introduces the subject of OTT communication services and argues why regulatory frameworks are necessary. The chapter also gives a general outline of the topics and the paper’s organisation that will be covered in the following chapters.
- Chapter 2: Examination of the Issues Related to Regulatory Mechanism for Over-The-Top Communication Services
- The second chapter of the essay looks at the problems with OTT communication service regulation. It talks about the many kinds of OTT services and how they affect the conventional telecom sector. The chapter also looks at the regulatory issues raised by OTT services and the various strategies used by various nations to address them.
- Chapter 3: Examination of the Issues Related to Selective Banning of OTT Services
- The final chapter of the essay looks at the problems of selectively outlawing OTT services. It analyses the justifications for government restrictions on OTT services as well as the possible effects of such restrictions on consumers and the telecom sector. The chapter also looks at the legal and regulatory structures that determine how OTT services are prohibited in various nations.
- Chapter 4: International Practices
- An overview of global OTT communication service best practices is given in the paper’s fourth chapter. It talks about the various regulatory strategies used by nations throughout the world and how they affect consumers and the telecom sector. The chapter also looks at the difficulties regulators encounter when trying to create efficient regulatory frameworks for OTT services.
- Chapter 5: Issues for Consultation
- This chapter is the spirit of the consultation paper as it covers the points and questions for consultation. This chapter has been classified into two sub-sections – Issues Related to Regulatory Mechanisms for OTT Communication Services and Issues Related to the Selective Banning of OTT Services. The inputs will be entirely focused on these sub headers, and the scope, extent, and ambit of the consultation paper rests on these questions and necessary inputs.
Conclusion
An important publication that aims to address the regulatory issues raised by OTT services is the Consultation Paper on Regulatory Mechanisms for Over-The-Top Communication Services. The paper offers a thorough analysis of the problems with OTT service regulation and requests input from stakeholders on the suggested regulatory structure. In order to make sure that the regulatory framework is efficient and advantageous for everyone, it is crucial for all stakeholders to offer their opinion on the document.
Related Blogs
.webp)
Executive Summary:
In late 2024 an Indian healthcare provider experienced a severe cybersecurity attack that demonstrated how powerful AI ransomware is. This blog discusses the background to the attack, how it took place and the effects it caused (both medical and financial), how organisations reacted, and the final result of it all, stressing on possible dangers in the healthcare industry with a lack of sufficiently adequate cybersecurity measures in place. The incident also interrupted the normal functioning of business and explained the possible economic and image losses from cyber threats. Other technical results of the study also provide more evidence and analysis of the advanced AI malware and best practices for defending against them.
1. Introduction
The integration of artificial intelligence (AI) in cybersecurity has revolutionised both defence mechanisms and the strategies employed by cybercriminals. AI-powered attacks, particularly ransomware, have become increasingly sophisticated, posing significant threats to various sectors, including healthcare. This report delves into a case study of an AI-powered ransomware attack on a prominent Indian healthcare provider in 2024, analysing the attack's execution, impact, and the subsequent response, along with key technical findings.
2. Background
In late 2024, a leading healthcare organisation in India which is involved in the research and development of AI techniques fell prey to a ransomware attack that was AI driven to get the most out of it. With many businesses today relying on data especially in the healthcare industry that requires real-time operations, health care has become the favourite of cyber criminals. AI aided attackers were able to cause far more detailed and damaging attack that severely affected the operation of the provider whilst jeopardising the safety of the patient information.
3. Attack Execution
The attack began with the launch of a phishing email designed to target a hospital administrator. They received an email with an infected attachment which when clicked in some cases injected the AI enabled ransomware into the hospitals network. AI incorporated ransomware was not as blasé as traditional ransomware, which sends copies to anyone, this studied the hospital’s IT network. First, it focused and targeted important systems which involved implementation of encryption such as the electronic health records and the billing departments.
The fact that the malware had an AI feature allowed it to learn and adjust its way of propagation in the network, and prioritise the encryption of most valuable data. This accuracy did not only increase the possibility of the potential ransom demand but also it allowed reducing the risks of the possibility of early discovery.
4. Impact
- The consequences of the attack were immediate and severe: The consequences of the attack were immediate and severe.
- Operational Disruption: The centralization of important systems made the hospital cease its functionality through the acts of encrypting the respective components. Operations such as surgeries, routine medical procedures and admitting of patients were slowed or in some cases referred to other hospitals.
- Data Security: Electronic patient records and associated billing data became off-limit because of the vulnerability of patient confidentiality. The danger of data loss was on the verge of becoming permanent, much to the concern of both the healthcare provider and its patients.
- Financial Loss: The attackers asked for 100 crore Indian rupees (approximately 12 USD million) for the decryption key. Despite the hospital not paying for it, there were certain losses that include the operational loss due to the server being down, loss incurred by the patients who were affected in one way or the other, loss incurred in responding to such an incident and the loss due to bad reputation.
5. Response
As soon as the hotel’s management was informed about the presence of ransomware, its IT department joined forces with cybersecurity professionals and local police. The team decided not to pay the ransom and instead recover the systems from backup. Despite the fact that this was an ethically and strategically correct decision, it was not without some challenges. Reconstruction was gradual, and certain elements of the patients’ records were permanently erased.
In order to avoid such attacks in the future, the healthcare provider put into force several organisational and technical actions such as network isolation and increase of cybersecurity measures. Even so, the attack revealed serious breaches in the provider’s IT systems security measures and protocols.
6. Outcome
The attack had far-reaching consequences:
- Financial Impact: A healthcare provider suffers a lot of crashes in its reckoning due to substantial service disruption as well as bolstering cybersecurity and compensating patients.
- Reputational Damage: The leakage of the data had a potential of causing a complete loss of confidence from patients and the public this affecting the reputation of the provider. This, of course, had an effect on patient care, and ultimately resulted in long-term effects on revenue as patients were retained.
- Industry Awareness: The breakthrough fed discussions across the country on how to improve cybersecurity provisions in the healthcare industry. It woke up the other care providers to review and improve their cyber defence status.
7. Technical Findings
The AI-powered ransomware attack on the healthcare provider revealed several technical vulnerabilities and provided insights into the sophisticated mechanisms employed by the attackers. These findings highlight the evolving threat landscape and the importance of advanced cybersecurity measures.
7.1 Phishing Vector and Initial Penetration
- Sophisticated Phishing Tactics: The phishing email was crafted with precision, utilising AI to mimic the communication style of trusted contacts within the organisation. The email bypassed standard email filters, indicating a high level of customization and adaptation, likely due to AI-driven analysis of previous successful phishing attempts.
- Exploitation of Human Error: The phishing email targeted an administrative user with access to critical systems, exploiting the lack of stringent access controls and user awareness. The successful penetration into the network highlighted the need for multi-factor authentication (MFA) and continuous training on identifying phishing attempts.
7.2 AI-Driven Malware Behavior
- Dynamic Network Mapping: Once inside the network, the AI-powered malware executed a sophisticated mapping of the hospital's IT infrastructure. Using machine learning algorithms, the malware identified the most critical systems—such as Electronic Health Records (EHR) and the billing system—prioritising them for encryption. This dynamic mapping capability allowed the malware to maximise damage while minimising its footprint, delaying detection.
- Adaptive Encryption Techniques: The malware employed adaptive encryption techniques, adjusting its encryption strategy based on the system's response. For instance, if it detected attempts to isolate the network or initiate backup protocols, it accelerated the encryption process or targeted backup systems directly, demonstrating an ability to anticipate and counteract defensive measures.
- Evasive Tactics: The ransomware utilised advanced evasion tactics, such as polymorphic code and anti-forensic features, to avoid detection by traditional antivirus software and security monitoring tools. The AI component allowed the malware to alter its code and behaviour in real time, making signature-based detection methods ineffective.
7.3 Vulnerability Exploitation
- Weaknesses in Network Segmentation: The hospital’s network was insufficiently segmented, allowing the ransomware to spread rapidly across various departments. The malware exploited this lack of segmentation to access critical systems that should have been isolated from each other, indicating the need for stronger network architecture and micro-segmentation.
- Inadequate Patch Management: The attackers exploited unpatched vulnerabilities in the hospital’s IT infrastructure, particularly within outdated software used for managing patient records and billing. The failure to apply timely patches allowed the ransomware to penetrate and escalate privileges within the network, underlining the importance of rigorous patch management policies.
7.4 Data Recovery and Backup Failures
- Inaccessible Backups: The malware specifically targeted backup servers, encrypting them alongside primary systems. This revealed weaknesses in the backup strategy, including the lack of offline or immutable backups that could have been used for recovery. The healthcare provider’s reliance on connected backups left them vulnerable to such targeted attacks.
- Slow Recovery Process: The restoration of systems from backups was hindered by the sheer volume of encrypted data and the complexity of the hospital’s IT environment. The investigation found that the backups were not regularly tested for integrity and completeness, resulting in partial data loss and extended downtime during recovery.
7.5 Incident Response and Containment
- Delayed Detection and Response: The initial response was delayed due to the sophisticated nature of the attack, with traditional security measures failing to identify the ransomware until significant damage had occurred. The AI-powered malware’s ability to adapt and camouflage its activities contributed to this delay, highlighting the need for AI-enhanced detection and response tools.
- Forensic Analysis Challenges: The anti-forensic capabilities of the malware, including log wiping and data obfuscation, complicated the post-incident forensic analysis. Investigators had to rely on advanced techniques, such as memory forensics and machine learning-based anomaly detection, to trace the malware’s activities and identify the attack vector.
8. Recommendations Based on Technical Findings
To prevent similar incidents, the following measures are recommended:
- AI-Powered Threat Detection: Implement AI-driven threat detection systems capable of identifying and responding to AI-powered attacks in real time. These systems should include behavioural analysis, anomaly detection, and machine learning models trained on diverse datasets.
- Enhanced Backup Strategies: Develop a more resilient backup strategy that includes offline, air-gapped, or immutable backups. Regularly test backup systems to ensure they can be restored quickly and effectively in the event of a ransomware attack.
- Strengthened Network Segmentation: Re-architect the network with robust segmentation and micro-segmentation to limit the spread of malware. Critical systems should be isolated, and access should be tightly controlled and monitored.
- Regular Vulnerability Assessments: Conduct frequent vulnerability assessments and patch management audits to ensure all systems are up to date. Implement automated patch management tools where possible to reduce the window of exposure to known vulnerabilities.
- Advanced Phishing Defences: Deploy AI-powered anti-phishing tools that can detect and block sophisticated phishing attempts. Train staff regularly on the latest phishing tactics, including how to recognize AI-generated phishing emails.
9. Conclusion
The AI empowered ransomware attack on the Indian healthcare provider in 2024 makes it clear that the threat of advanced cyber attacks has grown in the healthcare facilities. Sophisticated technical brief outlines the steps used by hackers hence underlining the importance of ongoing active and strong security. This event is a stark message to all about the importance of not only remaining alert and implementing strong investments in cybersecurity but also embarking on the formulation of measures on how best to counter such incidents with limited harm. AI is now being used by cybercriminals to increase the effectiveness of the attacks they make and it is now high time all healthcare organisations ensure that their crucial systems and data are well protected from such attacks.
.webp)
Introduction
In India, the rights of children with regard to protection of their personal data are enshrined under the Digital Personal Data Protection Act, 2023 which is the newly enacted digital personal data protection law of India. The DPDP Act requires that for the processing of children's personal data, verifiable consent of parents or legal guardians is a necessary requirement. If the consent of parents or legal guardians is not obtained then it constitutes a violation under the DPDP Act. Under section 2(f) of the DPDP act, a “child” means an individual who has not completed the age of eighteen years.
Section 9 under the DPDP Act, 2023
With reference to the collection of children's data section 9 of the DPDP Act, 2023 provides that for children below 18 years of age, consent from Parents/Legal Guardians is required. The Data Fiduciary shall, before processing any personal data of a child or a person with a disability who has a lawful guardian, obtain verifiable consent from the parent or the lawful guardian. Section 9 aims to create a safer online environment for children by limiting the exploitation of their data for commercial purposes or otherwise. By virtue of this section, the parents and guardians will have more control over their children's data and privacy and they are empowered to make choices as to how they manage their children's online activities and the permissions they grant to various online services.
Section 9 sub-section (3) specifies that a Data Fiduciary shall not undertake tracking or behavioural monitoring of children or targeted advertising directed at children. However, section 9 sub-section (5) further provides room for exemption from this prohibition by empowering the Central Government which may notify exemption to specific data fiduciaries or data processors from the behavioural tracking or target advertising prohibition under the future DPDP Rules which are yet to be announced or released.
Impact on social media platforms
Social media companies are raising concerns about Section 9 of the DPDP Act and upcoming Rules for the DPDP Act. Section 9 prohibits behavioural tracking or targeted advertising directed at children on digital platforms. By prohibiting intermediaries from tracking a ‘child's internet activities’ and ‘targeted advertising’ - this law aims to preserve children's privacy. However, social media corporations contended that this limitation adversely affects the efficacy of safety measures intended to safeguard young users, highlighting the necessity of monitoring specific user signals, including from minors, to guarantee the efficacy of safety measures designed for them.
Social media companies assert that tracking teenagers' behaviour is essential for safeguarding them from predators and harmful interactions. They believe that a complete ban on behavioural tracking is counterproductive to the government's objectives of protecting children. The scope to grant exemption leaves the door open for further advocacy on this issue. Hence it necessitates coordination with the concerned ministry and relevant stakeholders to find a balanced approach that maintains both privacy and safety for young users.
Furthermore, the impact on social media platforms also extends to the user experience and the operational costs required to implement the functioning of the changes created by regulations. This also involves significant changes to their algorithms and data-handling processes. Implementing robust age verification systems to identify young users and protect their data will also be a technically challenging step for the various scales of platforms. Ensuring that children’s data is not used for targeted advertising or behavioural monitoring also requires sophisticated data management systems. The blanket ban on targeted advertising and behavioural tracking may also affect the personalisation of content for young users, which may reduce their engagement with the platform.
For globally operating platforms, aligning their practices with the DPDP Act in India while also complying with data protection laws in other countries (such as GDPR in Europe or COPPA in the US) can be complex and resource-intensive. Platforms might choose to implement uniform global policies for simplicity, which could impact their operations in regions not governed by similar laws. On the same page, competitive dynamics such as market shifts where smaller or niche platforms that cater specifically to children and comply with these regulations may gain a competitive edge. There may be a drive towards developing new, compliant ways of monetizing user interactions that do not rely on behavioural tracking.
CyberPeace Policy Recommendations
A balanced strategy should be taken into account which gives weightage to the contentions of social media companies as well as to the protection of children's personal information. Instead of a blanket ban, platforms can be obliged to follow and encourage openness in advertising practices, ensuring that children are not exposed to any misleading or manipulative marketing techniques. Self-regulation techniques can be implemented to support ethical behaviour, responsibility, and the safety of young users’ online personal information through the platform’s practices. Additionally, verifiable consent should be examined and put forward in a manner which is practical and the platforms have a say in designing the said verification. Ultimately, this should be dealt with in a manner that behavioural tracking and targeted advertising are not affecting the children's well-being, safety and data protection in any way.
Final Words
Under section 9 of the DPDP Act, the prohibition of behavioural tracking and targeted advertising in case of processing children's personal data - will compel social media platforms to overhaul their data collection and advertising practices, ensuring compliance with stricter privacy regulations. The legislative intent behind this provision is to enhance and strengthen the protection of children's digital personal data security and privacy. As children are particularly vulnerable to digital threats due to their still-evolving maturity and cognitive capacities, the protection of their privacy stands as a priority. The innocence of children is a major cause for concern when it comes to digital access because children simply do not possess the discernment and caution required to be able to navigate the Internet safely. Furthermore, a balanced approach needs to be adopted which maintains both ‘privacy’ and ‘safety’ for young users.
References
- https://www.meity.gov.in/writereaddata/files/Digital%20Personal%20Data%20Protection%20Act%202023.pdf
- https://www.firstpost.com/tech/as-govt-of-india-starts-preparing-rules-for-dpdp-act-social-media-platforms-worried-13789134.html#google_vignette
- https://www.business-standard.com/industry/news/social-media-platforms-worry-new-data-law-could-affect-child-safety-ads-124070400673_1.html
.webp)
The Digital Covenant: Aligning Communication with SDG Goals
“Rethinking Communication, Cyber Responsibility, and Sustainability in a Connected World”
Introduction
It is rightly said by Antonio Guterres, United Nations Secretary General, “Everyone should be able to express themselves freely without fear of attack. Everyone should be able to access a range of views and information sources.” In 2024, when the Global Alliance for PR and Communication Management asserted that it aligns with the era of digital transformation, where technology is moving at terminal velocity and bringing various risks and threats, it called on the global leaders and stakeholders to proclaim ‘Responsible Communication’ as the 18th Sustainable Development Goal (SDG). On May 17th, as we celebrate World Telecommunication and Information Society Day (WTISD) 2025, we must align our personal, professional, and virtual spaces with a safe and sustainable information age.
In terms of digital growth, it is indubitable that India is growing at a brisk pace consistently in alignment with its South Asian and Western counterparts and has incorporated international covenants on digital personal data and cyber crimes within its domestic regime.
UN Global Principles for Information Integrity
The United Nations has displayed its constant commitment to the achievement of the seventeen SDGs that were adopted at the United Nations Conference in 2012 in Rio de Janeiro. It recognises that you cannot isolate the digital transformation, technology, and digitisation from other areas that are included within the SDGs, such as health, education, and poverty. The UN released Policy Brief 8 in June 2023 by the UN Secretary-General that seeks to empirically derive data on the threats posed to information integrity and then come up with norms that help guide the member states, the digital platforms, and other stakeholders. The norms must be in conformity with the right to freedom of opinion and expression and the right to information access.
In line with its agenda, it has formulated Global Principles of Information Integrity, which include “Societal Trust and Resilience”, “Healthy Incentives”, “Public Empowerment”, “Independent, Free and Pluralistic Media” and “Transparency and Research”. The principles recognise the harm caused by hatred, misinformation, and disinformation propagated by the misuse of advances in Artificial Intelligence Technology (AI).
Breaking the Binary: Bridging the Gender Digital Divide
The reflection of how far we have come and how far we have to go can be deciphered with a single sentence, i.e., using digital technologies to promote gender equality. This can be seen both as a paradox and a pressing call to action. As we celebrate WTISD 2025, the day highlights the fundamental role of Information and Communication Technologies (ICTs) in accelerating progress and bringing those not included in this digital transformation to become a part of this change, especially the female population that remains isolated from mainstream growth. As per the data given by ITU, “Out of the world population, 70 per cent of men are using the internet, compared with 65 per cent of women.”
This exclusion is not merely a technical gap but a societal and economic chasm, reinforcing existing inequalities. By including such an important goal in the theme of this day, it marks a critical moment towards the formation of gender-sensitive digital policies, promoting digital literacy among women and girls, and ensuring safe, affordable, and meaningful connectivity. We can explore the future potential where technology is the true instrument for gender parity, not a mirror of old hierarchies.
India and its courts have time and again proven their commitment to cultivating digital transformation as an inherent strength to bridge this digital divide, and the recent judgement where the court declared the right to digital access an intrinsic part of the right to life and liberty is a single instance among many.
CyberPeace Resolution on World Telecommunication and Information Society Day
CyberPeace is actively bridging the gap between digital safety and sustainable development through its initiatives, aligning with the principles of the Sustainable Development Goals (SDGs). The ‘CyberPeace Corps’ empowers communities by fostering cyber hygiene awareness and building digital resilience. The ‘CyberPeace Initiative’, a project with Google.org, tackles digital misinformation, promoting informed online engagement. Additionally, Digital Shakti, now in its fifth phase, empowers women by enhancing their digital literacy and safety. These are just a few of the many impactful initiatives by CyberPeace, aimed at creating a safer and more inclusive digital future. Together, we are spreading awareness and strengthening the foundation for a safer and more inclusive digital future and promoting responsible tech use. Let us be resolute on this World Telecommunication and Information Society Day for “Clean Data. Safe Clicks. Stronger Future. Pledge to Cyber Hygiene Today!”
References