Should Pilots Be Paid? The Procurement View

A scholarship cell accepted a 'no-cost POC' on last year's live applications because the vendor said they only needed a week and would not copy anything. The week became three. Embeddings sat on a vendor laptop that went home. There was no DPA. There was no entry in the gift register, because nobody thought a pilot was a gift or a procurement. There was, however, processing of personal data of minors' families. When the cell later tendered, that vendor knew the schema, the failure modes, and the officers' habits. The others did not. Free had been expensive in every way except the invoice.

This is a procurement opinion, not a statute. Unpaid pilots with production data are still processing. Prefer paid, scoped pilots with a data processing agreement, a purpose, an erasure date, and a written statement that the pilot does not promise the implementation. If you cannot pay, do not use production personal data. Synthetic or public data is the price of a free visit.

GFR, GeM, your gift rules, and DPDP duties still apply in their own ways. A zero rupee invoice does not zero those duties. Not legal advice.

Free is a price

The vendor is paid in schema knowledge, in a logo, in a reference they will put in the next bid, and sometimes in your traces. You are paid in a demo. That trade is often uneven. It is also a fairness problem: one firm has had a paid-in-kind discovery. The later RFP, if it looks like their notes, is a vendor-written spec you did not even have to paste.

Vigilance cultures that obsess over a conference mug and ignore a three-week live-data trial are watching the wrong object. Write the trial as a procurement or do not do it.

What a paid pilot looks like

A small, competed or fairly invited scope: one workflow, named data classes, named languages, a start and an erase date, a DPA with a training ban, logs in your store, and a report you own. Payment is real even if it is modest. Modest and documented beats large and unofficial.

If only one firm is invited, write why. A single-source pilot is still a single-source procurement of a service, however small. Do not call it a knowledge partnership to escape the note.

If the right-hand column is empty, you do not have a pilot. You have a leak with a slide deck.

Element	Paid scoped pilot	Unpaid production peek
Lawful basis and DPA	Written, signed before data moves	A slide that says anonymised
Price	A rupee value and a sanction	Logo and learning as informal currency
Scope	One workflow, one month, named fields	'Let us try it on last year's dump'
Erasure	Certificate, embeddings included	Laptop left on a Friday
Later tender	Pilot report is department's, shared or not by rule	One bidder has a map of your mess

When unpaid is defensible

A demo on the vendor's data, or on a public circular corpus, or on a synthetic set you issued to every shortlisted firm. A bake-off in your room on a held-out pack that does not leave. Those are evaluations, not pilots. Call them evaluations. Do not sneak a connector to the live MIS 'just to make it real'.

If a firm insists that only live data will prove value, they are asking to start processing. That request should meet a DPA and a price, or a no.

• No production personal data without a DPA, even if unpaid.
• Prefer a paid instrument you can put in the file.
• Same evaluation pack for every later bidder.
• Erase, certify, and write that the pilot is not the award.

The later tender

If a pilot happened, the RFP should either share the non-sensitive lessons with all bidders or be written so that the pilot firm has no exclusive nouns. Paying them does not bar them, unless you wrote a bar. Not paying them does not make their head-start fair.

Write in the pilot order whether the vendor is eligible for the implementation. Pick one. Ambiguity here is how you collect complaints from both sides.

Objections you will hear — and what to do with them

These are the lines that stall the file. Answer them in the room, then put the answer in the note. A spoken answer without paper will be forgotten by the next officer.

There is no budget head for a pilot.

Then find a professional-services head, or do an evaluation on synthetic data, or wait. Absence of a head is not a lawful basis to process families' scholarship files for free.

Startups cannot survive if we do not give them a free go-live.

A paid scoped pilot is better for a startup than a free peek that later becomes a complaint. If your eligibility otherwise bars startups, fix eligibility. Do not pay them in other people's personal data.

It is only anonymised.

Then show the anonymisation, the residual risk, and why re-identification from applications is hard. Most 'anonymised' dumps of application forms are not. Counsel and the DPO, not the salesperson, decide.

Payment will make the pilot a procurement and slow us down.

Yes. That slowness is the point. Processing citizens without a paper is fast in week one and slow for a year after the complaint.

How to invite without creating a favourite

If you will pay three firms to run the same pack, write the invitation so each sees the same scope, the same erase date, and the same later-eligibility rule. Do not let one firm 'help design the pack'. That firm has then written the exam. If only one firm is invited, the note must say why the market was not asked — and that reason will be read later as a PAC cousin. Most scholarship cells do not have that reason. They have a Saturday email.

Publish a short notice even for a small paid pilot if your rules allow it. A notice is how a second DPIIT-recognised firm appears. The extra week is cheaper than a complaint that you gifted a schema to a friend. If GeM or your manual has a small-value professional-services path, use it. Do not invent a 'knowledge partnership' that your accounts cannot book.

A three-week path to a defensible pilot

If three weeks feels long, your ceremony date was the wrong constraint. Data is the constraint.

1. Week 1: decide evaluation (synthetic, all bidders) versus pilot (processing, DPA, price). Do not mix.
2. Week 2: write scope, erase date, training ban, eligibility for the later buy. Sanction the rupee.
3. Week 3: run, log, erase, certify, file the report. Only then talk about implementation.

How this shows up in the file

The note says: this pilot is a paid processing activity / this evaluation uses no production personal data. It names the DPA, the erase date, and whether the vendor may bid later. It says unpaid production peeks are not used in this department.

If a free peek already happened, write it down. Late honesty is better than a missing page.

This article is informational field guidance for Indian public institutions, not legal, procurement, security-accreditation or engineering advice. Confirm against the current Gazette, GFR, GeM term, CVC instruction, CERT-In direction, DPDP text, departmental manual and your counsel before you file it.

How to put this in the RFP, not the preamble

A P2 Procurement who searches “paid pilot government procurement” is usually drafting or scoring a bid. “Should Pilots Be Paid? The Procurement View” belongs in eligibility, the evaluation matrix, or a numbered annexure. If it only lives in the covering note, L1 will ignore it.

A free pilot on live files is not a favour. It is processing without a price, often without a DPA. Pay for a scoped pilot or keep the data off the table. QCBS weights are a choice you must publish before opening. Accuracy is a task plus a dataset, not a slogan. SLAs for agents must name tool-calls, human gates and log export — uptime alone is a hosting metric.

Do not let a vendor write the specification and then bid on it. Record unsolicited proposals. Pay for pilots that touch personal data. Write exit before you write go-live.

1. Move the control from the preamble into a scored or eligibility row.
2. Attach a one-page definition (accuracy, SLA, language, data handling).
3. Require an artefact in the technical bid, not a slide.
4. Extend the bid date if a corrigendum is material.
5. Minute the demo on your data, offline if you claimed air-gap.

Close this loop before the next CAB

Put “Should Pilots Be Paid? The Procurement View” on the next change-advisory or bid-opening agenda as a single line item with an owner. If it cannot earn a line item, it will not earn a control. The owner should be a P2 Procurement, not “the vendor.”

Revisit the item when the model, the GeM term, the region, or the SI changes. “paid pilot government procurement” is not a one-time workshop. It is a watch item. Date the last check. Unsigned watch items are souvenirs.