Translating the death registration form into plain English

 

I worked on the death registration form as a volunteer for Zen Citizen. I'd have liked to use some screenshots but the login is very buggy and I could not get into the Seva Sindhu portal once I completed the project. So, here’re some text-only highlights: 

Preferred language: This is a field at the beginning of the form. At first, it seems like an innocent enough query. But look at it more deeply and it can unhinge the entire form. By preferred language, what is the government asking? Is it the preferred language in which I want to fill the form? Or, is it the preferred language in which I want the Death Registration certificate to be provided? 

I selected English and proceeded to the subsequent fields. However, the language preference continued to haunt me. Further below in the form, it asks for the deceased’s name in Kannada. This on an English form. What happens if I am not a Kannada-speaking person? Of course, you can always use transliterating tools to input the name in Kannada, but how do I verify if it’s a correct reproduction of my name? 

The converse is even more problematic: that is, being asked to type the name in English when I have chosen Kannada as my language for the form. In English, one’s name can be spelled in so many ways. How do you verify if it’s correct if you don’t know English? This can result in a critical failure because if the certificate spells your name wrong, it’s a dud. None of the government agencies will accept it and getting it corrected is a lifetime’s work. 

Ration card: The form assumes everyone has a ration card! How did this come to be? If you don’t have a ration card, you cannot even begin with the form as the name of the deceased is automatically populated from the ration card. 

Date & time of death: The time selection menu progresses by the minute. This can be very tedious to navigate to the exact hour and minute. Providing a time selection menu like we use to set alarms in mobile phones shouldn’t be too difficult. The other question is why the time of death is relevant, unless we are investigating homicide. 

We also looked at the necessity of some of the data being collected – like the age of the deceased’s spouse. We are waiting to hear from Seva Sindhu on this and other queries. 

My learnings from this project as of now

• The form is not designed from the user’s perspective. It seems to primarily solve things for the government agency rather than the citizen.  
• It works on many assumptions -- that someone typing in English also knows how to type their name in Kannada; that everyone has a ration card; that if they cannot figure out something, they can always avail the services of a broker. 
• The form does not seem to be tested with users. Else, some of the things I highlighted here may have caught the eye of the form creators. 
• The form does not seem to take into cognizance the varied background of the users. Given that it’s a death registration form, it is applicable to everyone (!) and hence must be usable by everyone. 

The lacunae of this form are not unique to it. God knows, there are worse government forms out there. It is representative though and makes for a good beginning. Hope to be able to report positively on this project in the days to come. 

DPDP: It’s all about consent (and clarity)

 

Last month I wrote on the blog that in India we seem to be waiting for plain language to be made a compliance requirement. I couldn’t have spoken sooner. 

The Digital Personal Data Protection (DPDP) Act [pdf] lays down the rules for collection, storage, and use of personal data online. A rule under this Act requires companies to collect informed consent from their users on the data they collect and be clear about the exact purpose they are going to use it for. 

And guess what? They need to ask for consent in plain language.

“Every request for consent under the provisions of this Act or the rules made thereunder  (sic) shall be presented to the Data Principal in a clear and plain language, …” [Emphasis mine.]

(Data principal here means the person who owns the data.)

The DPDP Act is largely inspired by Europe’s General Data Protection Regulations (GDPR), though it is different in some respects, too. However, both require plain language. Here’s what the GDPR says:

“Requests for consent must be ‘clearly distinguishable from the other matters’ and presented in ‘clear and plain language’.”     

Are Indian companies equipped to create a plain language consent form? 

No. And neither are they equipped to comply with most of the Act. DPDP has fundamentally questioned the way Indian companies do business. Most of them simply do not bother about privacy. And now they are being asked to obtain consent that is “free, specific, informed, unconditional, with a clear affirmative action”. That’s a big ask. 

The Act also lets the data principal withdraw consent at any time, after which the companies can no longer use or store their data. All of this must be complied within May 2027. As one can imagine, companies are scrambling to meet the deadline. 

So my guess is that no one is bothered much about drafting a plain language consent form. I’d be happy to be proved wrong. 

None of the news articles and blog posts I skimmed mention the term “plain language”. They do talk about clarity in the consent form. But how will companies go about achieving clarity without being aware of plain language guidelines is anybody’s guess. And, if their consent forms are not in plain language, they cannot be in true compliance of the law. 

It doesn’t help that the Act itself is not in plain language. That’s a missed chance to set an example. However, some wins are that it provides helpful snippets in the margins which highlight important parts of the Act (see screenshot below). 

 It also talks about different use cases where it becomes applicable. This makes it easy to understand.  

Overall, I would celebrate the fact that India’s new digital privacy act demands clarity and actually mentions plain language, not to forget its pathbreaking use of “she” and “her".  But we need to keep moving ahead.

(Pic credit: Pexels, Mohammed Yasir https://www.pexels.com/@mohammad-yasir-3365802/.)

A (somewhat) plainspeaking Indian bank, standards update, PLAIN webinar..

 Read the third edition of Clear Enough here.