ICT Watch’s Response towards the Government’s "National DNS"

Couple of times ago, Minister of Communication and Information Rudiantara issued the rule of the game regarding National DNS suggesting that all internet provider in Indonesia must synchronize their DNS with DNS Trust+Positif. Apparently, it’s actually still a part of Ministerial Legislation Draft (MLD) regarding the Universal Service Obligation (USO). ICT Watch Indonesia support this policy with a number of terms and condition.

In the response letter signed by ICT Watch Indonesia’s Executive Director Donny BU, ICT delivered at least five points of response regarding the USO MLD which will be implemented by the Ministry. Each of those points highlight article 4, article 5, article 9, article 11, and article 18 of the MLD. The MLD is also open for anyone to give suggestion regarding the USO.

In the first point that highlights article 4 of the USO MLD, regarding the National DNS, ICT Watch underline that further explanation or information about the National DNS, as well as the management plan (establishment, management, supervision), needs to be prioritized before the USO MLD gets ratified.

This is regarded to be relevant with article 3 of the USO MLD which requires the telecommunication and informatics USO management to be implemented based on following principles: transparent, non-discrimination, accountable, and professional.

Therefore, ICT Watch Indonesia also suggest the Ministry to open the consultation channel as wide as possible by inviting related multi-stakeholders and academics who are competent in technical dynamics. According to ICT Watch Indonesia, this is important to get the best consensus for design, development, management and management of National DNS which is transparent and accountable for Indonesian Internet resilience.

This response by ICT Watch is not without any reason. The response explains that DNS Technology, especially the distributed anycast topology (not centralized), is best functioned to improve the Internet resilience (fast, secure, stable).

However, should this DNS technology has better management, it will be used by related parties to do the information censorship. This is what people are worried about since it means that there has been violation towards the rights of citizens. The information censorship has been done by a number of countries, like China, Turkey, Pakistan, Malaysia, and South Korea, ICT Watch Indonesia claimed.

Moreover, ICT Watch also underlined four other articles, which are article 5, article 9, article 11, and article 18. In article 5 (2), they suggest that the sentence stating about the utilization of USO fund for disability should be emphasized.

As for article 9 (2) point “c” and “d”, regarding the needs for any suggestion for program and benefit, ICT suggest that the sentence should be amended. For article 11 (4), regarding the monitoring and evaluation, ICT suggest that the article should clearly state the involvement of “multi-stakeholders”. This is to include parties from the industry, civilians and academics, as part of the monitoring and evaluation processes.

For article 18 point “b”, ICT suggest that it should be strengthened by referring to the previous response which is related to article 11 (4). As for point “c”, ICT suggest that there should be one point added (point “d”) to strengthen the regulation written in article 18 “c”, regarding the customer care service in regard to the practices of procurement of telecommunication and Informatics USO.

For further view on the response, you may visit this link (in Indonesian).