SFLC.in writes to National Health Authority against mandatory imposition of CoWIN

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SFLC.in writes to National Health Authority against mandatory imposition of CoWIN

The registrations for phase III of COVID vaccination were launched by the Government of India via the CoWIN website and mobile application on 28.04.2021. It has been made mandatory for 18-44 year old people to register for vaccination using CoWIN. No walk-ins for vaccination have been allowed by the National Health Authority.

SFLC.in wrote to CEO of National Health Authority, Dr. R.S. Sharma and Minister, Health and Family Welfare, Dr. Harsh Vardhan against this decision. The concerns raised by SFLC.in in its letter includes:

a. Digital Exclusion : At a time when entire country is grappling with COVID-19, the objective of the government should be to ensure maximum vaccination. As of December, 2020, TRAI had noted that India has only 58 internet subscribers out of 100. Unfortunately, mandatory imposition of CoWIN for 18-44 will lead to digital exclusion of people, particularly those who do not have smartphones or an internet connection. While CoWIN allows 4 registrations per number, that does not necessarily mean that this deficit would be bridged.

b. Digital Literacy: This decision also does not consider the digital literacy of people. Significant number of people in the country do not have the digital literacy to be able to register online for vaccination via CoWIN’s website or mobile application.

c. Lack of specific privacy policy: CoWIN does not have a specific privacy policy in place. Instead, the privacy policy is linked to National Health Data Management Policy which cannot be a substitute for a specific privacy policy. The Health Data Policy does not specify the personal data collected by CoWIN, data sharing with third parties, data retention, and deletion. SFLC.in had raised this issue in January, 2021. Still however, the CoWIN app links to the Health Data policy.

d. Languages supported by CoWIN: While CoWIN’s mobile application supports 12 languages, none of these languages are South Indian languages. The CoWIN’s website only supports English making it further difficult for a significant section of people to register for vaccination.

e. Technical infrastructure of CoWIN; The issues concerning delay in OTP and loading of website have been raised in the past as well. Civil Society Organisations including SFLC.in had raised this concern earlier also. In order to vaccinate the entire population, it is important to upgrade CoWIN’s infrastructure to meet high demand. Unfortunately, there were several delays in the registration process when the registration process for 18-44 old was opened up.

Through its letter, SFLC.in has requested the National Health Authority to look into these concerns and to immediately open up walk-in registration as well. Like the vaccination programmes for diseases like polio, the focus should be to not just have vaccination centres but also to reach out to the population who will have difficulty in reaching the centres like the differently abled and the aged. The objective of the programme should be to include everyone. Any policies that result in exclusion of citizens should be changed.

You can read the letter here:


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