Data-Sharing and
Governance
Consultation
ANALYSIS OF RESPONSES
Respondents
 26
Written responses received from:
 Private Citizens
 State Agencies
 Government Departments
 Members of the Oireachtas
 Rights Groups
 Research Bodies
 Solicitors
 Industry Representative Bodies
Proposed Definition of Data-Sharing

1. The receiving body determining a need for data from the sending
body to support or improve its business processes, perform a
statutory function, or to provide evidence to support policy
evaluation and development

2. The receiving body identifying an existing legal basis for the datasharing, or creating a new one

3. The sending body agreeing to provide the data

4. Technical and legal details being agreed in writing – data
protection restrictions, transmission channel, format, contents,
security etc.

5. Generally, the receiving body will need to match the shared data
with data it currently holds
Do you agree with the proposed
definition of data-sharing?
Agree
9%
No Response
44%
Disagree
17%
Somewhat Agree
30%
If you do not agree, how do you
believe the definition could be
improved?
- “Two or more” parties
- Open Data concepts –
e.g. “Open by design”
- Governance led approach
- Establish an interoperability community
What do you believe are the priority areas for datasharing to contribute to improved public services?

Removal of Duplication

Evidence based evaluation of programmes

Better Governance Culture

Training of public service staff

Setting of information standards

Better access to services and information

Better use of spatial information, health
information and educational information
Do you agree that more effective
data-sharing can help drive public
service reform?
Somewhat Agree
19%
Agree
50%
No Response
31%
Examples of suggested drivers for
public sector reform

Sharing of education data to assess outcomes

Streamlining the provision of services to the public

Streamlining identification of individuals across service
providers

Improved transparency to reduce need for FOI requests

Improved Data Governance strategies at Management
Level

Reduce costs and increase revenues by removing
Duplication and reducing fraud and error
Do you share the assessment that a
new legislative framework for datasharing is required?
Disagree
8%
Agree
61%
Somewhat Agree
4%
No Response
27%
What type of legislative reform is
necessary?

Clarification of data retention issues

Wider access to anonymised records

Resolve Data-Sharing disputes between Public Service
Bodies

Measures to create Accountability

Governance centred reform, with sharing based on
existing law

Sanctions for poor Data Governance and Breaches

Establish requirement for Data Sharing Officers and
Privacy Impact Assessment
what do you see as the main
obstacles to data-sharing?

OBSTACLES

Institutional reluctance

Lack of resources (Financial, staff, technological)

Lack of institutional knowledge and training

Lack of enforced interoperability standards for
data

Lack of accountability, Organisational
asymmetry
Proposed solutions:

PROPOSED SOLUTIONS

Supervision and enforcement of sharing by
central Departments/Agency

Link compliance to budget

Implement training and standardise data across
different Bodies
Suggestions for public
consideration, analysis and
debate?

Consult with stakeholders in Public Sector, NGO Sector
and Civil Society, Academia

Use of Public Forums to clarify the benefits of Public
Service Data-Sharing

Circulate Heads of draft legislation

Use of online materials to provide information

Further Public Consultation
How far can the Bill go in providing the
necessary powers to share data, while at
the same time ensuring clarity around
what exactly is permitted?






Set Protocols for sharing to create clarity
Purpose of sharing should be based in primary legislation
Data-sharing only for lawful and specified reasons
Engagement with a governing body beneficial
Address interoperability issues
Approval role for Data Protection Commissioner
Should both personal and sensitive
personal data be covered by these
provisions?
Disagree
8%
Somewhat Agree
8%
Agree
34%
No Response
50%
What other specific data-sharing
arrangements should be considered?

Educational information

Public/Private exchanges (other than Personal Data)

Sharing of business data and crime data

Reform access to existing publicly available data sets

Infrastructure Data, Ordnance Survey, Transport, BER
Ratings
Should "Trusted Third Parties" be
Included in the Bill?
Disagree
12%
Agree
42%
Somewhat Agree
8%
No Response
38%
Should there be provisions relating
to "anonymised" data?
Disagree
4%
Agree
36%
No Response
48%
Somewhat Agree
12%
Do you agree that “The problem [of data
governance] is therefore primarily one of
better implementation, rather than an absence of
legislation.”?
Agree
24%
Disagree
8%
Somewhat Agree
28%
No Response
40%
Should the Data Protection Commissioner have a
role in monitoring and reporting on compliance with
these governance provisions?
Disagree
8%
Agree
35%
Somewhat Agree
15%
No Response
42%
In what circumstances should a Department
be able to “opt out” of the transparency
requirement for a particular data-sharing
arrangement?

Never – transparency should be absolute

When connected to the investigation of Crime or National Security

When necessary to protect sensitive data

When approved by a Data Governance Supervisor

“Commercial Confidentiality” should not be allowed as a ground for
excluding reporting and transparency

When approved by the Data Protection Commissioner
Should new governance and transparency
arrangements apply to all existing data-sharing
arrangements, not just new ones?
Disagree
7%
Agree
27%
Somewhat Agree
8%
No Response
58%
Is the base register concept a
useful one?
Somewhat Agree
8%
Agree
58%
No Response
34%
What other base registers could usefully be
defined?

Registers chould be approved by Data Governance Supervisor

Educational Qualifications and Awards

Eircodes

Legal Judgments

Vehicle Registration

Geospatial information, Addresses and Eircodes

Health Identifiers

Identification Management

National Infrastructure
Next steps

Publication of consultation responses on
Department of Public Expenditure and Reform
Website

Preparation of General Scheme

Drafting of Data-Sharing and Governance Bill

Further engagement with stakeholders and
public