Professor David Rhind CBE
Chair of APPSI
APPSI Secretariat, The National Archives Kew,
Richmond, Surrey, TW9 4DU,
Email:secretariatappsi@nationalarchives.gsi.gov.uk
Lord McNally MP
Minister of State for Justice
Ministry of Justice
102 Petty France
London
SW1H 9AJ
Dear Minister,
APPSI Response to the Cabinet Office Open Data and Public Data Corporation
Consultations
Much activity in regard to Public Sector Information Re-use has continued – at international,
national and more local levels – over the past few months and APPSI has been briefed on and
discussed such developments. The key developments have however been the two government
consultations on Open Data and a Data Policy for the Public Data Corporation. This letter
describes APPSI’s responses to these two documents.
Upon the launch of the Open Data and the PDC consultation exercises, APPSI invited
representatives of the Cabinet Office Transparency Team to host a workshop on the Open Data
and the PDC consultations with members in the 32nd meeting of APPSI on the 13 September
2011. APPSI welcomed government’s commitment to Open Data and the efforts being made to
refine policy to meet the Transparency and Open Data objectives. We submitted our substantial
responses to both consultations by the deadline of 27 October 2011. These responses are
enclosed with this letter.
APPSI are of the view that the fundamental changes which are being sought in behaviour in
opening up government data to scrutiny, and for re-use, can only succeed over an extended
period. APPSI in its response to the Open Data consultation has also expressed concern about
the apparent lack of a strategic plan for what APPSI terms a ‘National Information
Infrastructure’.
In both of its responses APPSI structured the response in two parts. The second part sought to
answer the specific questions raised in the consultation document. However preceding this
detailed response APPSI addressed some broader, more strategic policy matters. As an
example, these included ‘what is the government’s appropriate role in the information supply
chain?’ The old view was that government was simply a provider of information that it happened
to hold. In some government bodies this has altered into the paid-for provision of services and
products based on information they hold, increasingly ‘co-mingled’ with data held by others.
Sometimes this exists in alliance with selected private sector bodies and sometimes in
competition with them. Government’s role and boundaries on managing data are thus
becoming ever more diffuse. It has been argued that this undermines the commitment by the
private sector, members of which see a lack of clarity and instability as de-stabilising factors.
APPSI had greater difficulty dealing with the PDC consultation than with that on Open Data. In
part this was because members saw the present concept of the PDC being unlikely to deliver
what was intended - and indeed that the consultation proposal conflates mutually incompatible
functions together: operations, sales and marketing, standards setting, procurement, policymaking, and a vehicle for private investment. APPSI members also saw the latter part of the first
objective (i.e. “...balancing the desire for more data free for re-use whilst ensuring affordability
and value for taxpayers”) as an aspiration rather than an objective; there are no proposed
quantitative measures of PDC success and no business case. Based on the consultation
document and various press statements about the PDC, APPSI saw the concept as creating
unjustified complexity e.g. with two levels of Board involved and bringing together (possibly)
three organisations which address very different markets and have different users.
The Public Data Corporation consultation however served as a trigger for APPSI re-thinking a
more radical and strategic approach. This focused on three ‘big issues’: the need to tackle
deleterious impacts of the Trading Fund model so far as Open Data is concerned, the need to
address the complex, confusing, and partially contradictory array of legislation which exists and
the need to create a sustainable funding mechanism for ‘Core Reference Data’. The latter are
those where there is a moral right for the public to have access (e.g. details of all the UK laws)
or where there are large safety, public service, efficiency and cost benefits if everyone uses the
same definitive and regularly up-dated sources of data: APPSI’s view is that these at least
should be available at no more than marginal cost. APPSI highlighted eight areas where
government could facilitate the benefits of Open Data through a different approach to a PDC.
Without implementation of such an alternative approach, APPSI fears that the existing
complexity and tensions could continue.
Within its responses to the Open Data and PDC consultations, APPSI has - utilising the
commitment and passion of its members and their substantial and wide ranging expertise – set
out to provide guidance and foster a transparent debate on the virtues of the respective policy
proposals. The APPSI proposals in regard to the PDC are challenging but are carefully
documented and draw evidence from many sources.
I hope you will find our views of interest and I would be more than happy to discuss with you in
person any aspects of our response that maybe of particular interest.
Yours Sincerely,
Professor David Rhind CBE
Chair of APPSI
cc. Oliver Morley, Chief Executive and Keeper, and Carol Tullo, Director of Information
Policy and Services, The National Archives