I chanced across a recent critique of the Draft NEP 2019 titled “Observations on the DRAFT OF NATIONAL EDUCATION POLICY – 2019“. It has been authored by the Indian National Science Academy, New Delhi, Indian Academy of Sciences, Bengaluru and National Academy of Sciences, India, Allahabad. From the preamble:
This comment on the DNEP has been prepared by the three National Academies of Sciences and draws from extensive discussions with a wide range of educationists (teachers and researchers), students (school children, undergraduate and post-graduate and Ph.D. students) and other professionals. It focuses on some of the most pressing issues of concern, rather than attempting to be comprehensive and detailed. In the following, specific itemized comments that need careful revisiting have been flagged. It will require substantial deliberation to work out the detailed modalities for implementing some of these, and the three National Science Academies would be willing to assist in that task.
My critique follows. Their comments in italics.
The comments for the Technology in Education (Chapter 19) are very intriguing, especially coming from such eminence.
Generally, the role of technology should be more as a supplement to sound pedagogic practices, rather than replacement.
This is an unfortunate comment. Either the authors genuinely believe that the edTech world is trying to replace sound pedagogic practices (with “unsound edTech pedagogy”?), or they believe that edTech can replace sound pedagogic practices – both are absurd positions to take. They seem to believe, like many others, that edTech is an add-on, not an integral part of “sound pedagogic practices”.
Where technology does largely help is in extending the reach of education to the differently abled, or to those living in remote locations, or those outside the formal system.
In one broad stroke, they have marginalized all the brilliant research and practice happening all over the world in edTech in the past two decades. By conflating technology of access and accessibility with edTech, the authors have made another serious mistake. By indicating that those out of the formal system would largely benefit from it, they bar that possibility for the ones in the formal system.
Large parts of this chapter’s contents pertain to broad policy regarding the future of some technologies in education governance, with only a few policies pertaining to role of technology in education per se.
I am afraid they haven’t read the Chapter 19 in enough detail, but just skimmed through to a couple of paras they were looking for. The larger part of this chapter contains very specific policy directions on content, professional development, research, data, technologies and institutional capability development in edTech.
The purpose of the proposed NETF, partly to be funded by NASSCOM (DNEP- P19.1), to create an industry-linked, overarching and centralized body, remains unclear in respect of its relevance to education.
I don’t see a direction that NASSCOM should fund it. The text of the policy clearly states that public funding will be used initially and then later it could receive some funding from neutral technology bodies such as NASSCOM. I wonder if the need to criticize the policy sometimes gets in the way of an articulate reading of the policy.
I also do not see what is unclear about the NETF. P19.1.2 lays out very clearly that it will advise agencies, build institutional and intellectual capabilities in edTech, envision thrust areas and articulate new directions. What is unclear about that mandate is only how it will be empowered to do that, but the aims are spot on and clear.
It will also have access to a lot of data of students, teachers and institutions at all education levels nationwide, which raises serious concerns about privacy that are not adequately dealt with in the DNEP (Chapter 19, page 342, last paragraph).
I would like to draw their august attention to P19.6.1 (d) which emphasizes that laws around privacy will need to be strengthened. I can’t stress enough how weak we are in the matter of data. You need only to read the angst in the Sathyam committee report to understand that. What we should capture and how and why are always going to be debated, and they should. But that is no reason to vilify the approach.
The proposal for a body with such a broad mandate as the proposed NETF needs to be strongly justified before its creation can be supported. Presently no clear justification is provided.
I am sorry, but India needs an edTech body that can help, in a very inclusive, democratic and objective manner, shape how edtech can help in the sector’s transformation. The mandate is not broad, it is very specific to envisioning and implementing that plan of action that may emerge from consultations.
We feel that inputs from the IT-sector for guidance/suggestions on education technology research and deployment, especially in areas like automation, can directly be provided to the apex bodies managing education in each state through existing mechanisms.
I am pretty sure these are already in place (having been part of many such contributions), but why are we again conflating the IT sector and automation with edTech? Why do we believe that, without a body that can help channel edTech efforts in the country, that we will have any chance of embedding edTech in the fabric of teaching-learning in India? And NETF will evaluate all these suggestions from IT companies as well, providing considered advisories that will cut down some of the cost, time and effort required by the individual agencies and governments to do the same activity.
Further, AI and cloud technologies, their role in pedagogy and in the improvement of the quality of students in a country with a vast canvass of varied cultural and educational levels and systems may need to be discussed extensively before their inclusion in the education policy.
I think we need to realize that we have all been operating using AI and cloud technologies for quite a while now already. This is like saying that we don’t have a specific reason to call out these technologies, but we generally feel that a vast “canvass” of diversity will perhaps fail to benefit from these technologies. I understand concerns about privacy. I understand fears that machines will provide sub-human experiences not suited to education. But can we bury our heads in the sand hoping that the storms will blow away? We need to embrace edTech not fear it. These naysayer statements could equally then apply to other people who would like to bring any change whatsoever to the education system, whether edTech or not. It is the job of responsible and eminent people to bring cogent and articulate arguments, not sweeping statements like these.
The proposed NRED (DNEP- P19.5.5 and P19.6.1), will collect very detailed data and academic records on all students/ teachers/ institutions from school to HEIs. However, the purpose of such detailed collection of personal data has not been clarified. Unless the purpose is made clear, we cannot support such collection of deep personal data.
The purpose is mentioned in the policy. Firstly, we have a huge issue on data that can guide policy making and even institutional decision making at scale. Many reports in the past have expressed this gap. Secondly, securely handling data of individual stakeholders, like for any other service provided by public or private agencies, is an essential part of delivering services themselves and removing corruption from the system. Thirdly, creating predictive models that identify at-risk learners and help provide different remediation to them, has been proved to be useful across the world. Fourthly, the timeliness and accuracy of data is a pain point for India, which we have to resolve. If the sector has to be responsive, they cannot wait for an ASER annual report, can they? Fifthly, emphasis on strengthening laws and securing data is extremely important in this enterprise. This has been detailed P19.6.1.
Collection of such concentration of data, especially given its potential linkage to Aadhar No. (DNEP- P19.6.1b), its integration with data on “educational information management systems for community monitoring” (DNEP- P19.6.2), and the statement that “Data is a key fuel for artificial intelligence based technologies”), cannot be supported, especially because there are many examples of misuse of personal data. Explanation of mechanisms to protect privacy must be explicitly stated. (DNEP- P19.7.4). This aspect also needs careful legal scrutiny in view of recent observations of the Supreme Court of India in respect of issues of privacy of individuals
I think this is again a case of partial and opportunist reading of the policy. While it is fair to demand more clarity, how can one argue that data is not the fuel for AI based technologies – in fact data is the core requirement for machines to learn. I see the fear on Aadhar and “community monitoring” as a fear of “big brother is watching you”. Logical, and could happen, but it is for specific purposes without which we cannot gurantee any improvements in efficiency in this sector. Neither can we empower communities to ask for their rights and for promises made to be fulfilled by the public administration. That it needs to be done ethically, with strengthening of laws, with safeguards and by raising awareness through educating people of the dangers, is clearly mentioned in the policy document.
This proposal is therefore not desirable in its present form. If there is to be a database set up for governance and planning purposes, it should be restricted to institution-level information about enrolment, teacher strength, number of courses etc., and should not include data at the individual-level.
If that is the case, I would argue that institutions should not store admission and exam data of students either. If we cannot make the sector accountable through such data, it is akin to saying that this sector does not want to be held accountable, just wants autonomy without accountability.
Some of the recommendations about technology in education (DNEP- P19.2.1, P19.2.2, P19.2.3, P19.3.1, P19.3.3, P19.4.1c, P19.4.2, P19.4.3, P19.4.4, P19.4.6a, P19.5.2 and P19.5.3) may be moved to other appropriate sections of the DNEP document.
I am sorry I don’t agree. For example, P19.2.1 states that “Teachers will be completely empowered through adequate training and support to lead the activities and initiatives related to the use of appropriate technologies in classrooms, and for all other uses of technology in educational institutions.” Where else should this clause reside if not in the section about edTech? Activities like “improve the quality of pedagogy and learning processes through the use of intelligent tutoring systems and adaptive assessment systems; create new types of interactive and immersive content (e.g. using augmented and virtual reality); strengthen educational planning and management and bring greater transparency and efficiency to the examination system as well as to administrative and governance processes and scale up the ODL system so that it can respond to the growing demand for education” – where should these go?
P19.3.1 states “To skill teachers at all levels in the use of educational technology, all teacher preparation programmes will include hands-on training in leveraging technology-based resources”. Where should this go if not in the edTech section?
In sum, the proposals made in Chapter 19 need much greater elaboration and justification to show their relevance to education policy. Until these are provided, we recommend that these proposals not be immediately implemented as a part of the NEP
I think, in my summary, I would ask the authors to go back, study the document objectively, and provide reasoned arguments and sound alternatives/suggestions to ensuring that we have a chapter on edTech in the policy that helps to power our education system forwards into the digital age. Anything less, I won’t accept from such eminent and influential stakeholders in the system.