Attached to this letter are APPSI‟s responses to the questions set in the Open Data and Public
Data Corporation consultations.
In addition to APPSI‟s past support of the Open Data concept, we have also identified a number
of key questions and obstacles to be addressed if it is to achieve its potential. In this letter we
address some „big picture‟ matters which are not the primary focus of the consultations yet we
believe will influence overall success.
APPSI welcome government‟s commitment to Open Data and the efforts being made to refine
policy to drive the Open Data and Transparency agenda forwards. We have made much
progress of late and we applaud the desire to address the challenges of Open Data quickly. But
we very much believe that the fundamental changes which are being sought in behaviour in
opening up government data to scrutiny, and for re-use, will only succeed over an extended
period. We are concerned that the apparent lack of prioritisation in addressing issues and the
lack of a strategic plan for what we have termed a „National Information Infrastructure‟ will
simply overwhelm and confuse the large numbers of organisations and individuals involved. We
note for example the plans to create an information assets register: in principle this makes
sense but several attempts in government to do so in the past have not been fulfilled. The
current focus on finding savings across government will make doing new things – even if
ultimately they may bring benefits – all the harder.
Though some potential benefits arising from Open Data are clear (e.g. public accountability)
others are dependent on big policy questions being addressed successfully. These include
„what is the government‟s appropriate role in the information supply chain?‟ For example, 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 may be becoming ever more
confused.
The history of the last three years in regard to funding of the collection of government
information has seen a rapid shift towards making more data free at the point of use which has
then been compromised by the realities of funding the on-going data collection. Now we
perceive many different emphases across government bodies (and even within them). The
consultation documents reflect this tension (e.g. as in “to provide more freely available data for
re-use year on year within the constraints of affordability”). This affordability constraint limits
transparency and does not enable us in future to assess the performance of government.
Quite a lot of evidence exists that at least parts of the private sector do not object to paying for
certain government data. Their main concern is that it often takes significant amounts of time to
conclude access to data, notably since interacting with „customer facing‟ parts of government to
understand the characteristics of data, etc is often protracted and confusing – notwithstanding
substantial improvements – licensing of data can often prove complex and costly.
Notwithstanding that view, APPSI considers that there are some categories of government data
which will provide real social and economic value by being made free at the point of use
because of the merits of a single, definitive database being used by all parties. The Postal
Address File is an obvious example.
We had much greater difficulty dealing with the PDC consultation than with that on Open Data.
In part this was because we saw the present concept of the PDC being unclear: Some APPSI
members commented that it resembles a solution looking for a problem. It appears to create
complexity (e.g. with two levels of Board involved, brings together (possibly) three organisations
which address very different markets and have different users.
After much discussion, we believe that the key issues are ones of data and public policy more
generally than is addressed in the consultation document. These are manifested around the
effects of the Trading Fund model, the inchoate state in which multiple related UK policies and
statutes have evolved in isolation, and the crucial need for sustainable financing of core national
databases. Thus we agree strongly with – and would go further than - the government
statement in the Open Data Consultation (page 14) that: “government‟s approach to the
release of public data can be described as haphazard and in need of reform”.
The Public Data Corporation consultation has however served as a trigger for APPSI re-thinking
a more radical and strategic approach. Without the consideration of an alternative approach,
we expect that the existing complexity and tensions could continue.
We have set out in our response to the Open Data and PDC consultations the changes we think
are necessary, why they are needed and how best they can be affected.
Advisory Panel on Public Sector Information
27 October 2011