39 principle of data minimization: that processing must also be adequate, relevant, and limited to what is necessary; and principle of accuracy: that data must be accurate and, where necessary, kept up to date principle of storage limitation: that data is to be kept in a form that permits identification of data subjects for no longer than is necessary for the purposes for which the personal data are processed; principle of integrity and confidentiality: that data processing must be secure; and principle of accountability: data controller is to be held responsible. XII. BECAUSE, therefore, it is respectfully submitted that in the twenty years since the judgment in PUCL Wiretapping, there has been an evolution both in the understanding of the nature of harms caused by surveillance in the digital age, as well as a clearer understanding of the contours of the proportionality standard, and how this standard interacts with the specific manner in which surveillance infringes upon privacy and other fundamental rights. It is respectfully submitted – as demonstrated below – that Section 69 of the IT Act and the IT Rules do not comply with this standard. XIII. BECAUSE the judgment in PUCL Wiretapping (supra), as is evident from a reading of Paragraphs 17 and 30 thereof, based its standards and guidelines upon existing jurisprudence dealing with what constitutes “just, fair, and reasonable” procedure established by law, which is the