Draft Guidelines for Open Data in Nigeria o Sources of Data in Nigeria Government Institutions Certain Private Organizations These Guidelines are for Critical National Data Government data in Nigeria shall be considered open if it is made public in a way that complies with the principles below: 1. Complete All public data is made available. Public data is data that is not subject to valid privacy, security or privilege limitations. 2. Primary Data is as collected at the source, with the highest possible level of granularity, not in aggregate or modified forms. 3. Timely Data is made available as quickly as necessary to preserve the value of the data. 4. Accessible Data is available to the widest range of users for the widest range of purposes. 5. Machine processable Data is reasonably structured to allow automated processing. 6. Non-discriminatory Data is available to anyone, with no requirement of registration. 7. Non-proprietary Data is available in a format over which no entity has exclusive control. 8. License-free Data is not subject to any copyright, patent, trademark or trade secret regulation. Reasonable privacy, security and privilege restrictions may be allowed. Compliance must be reviewable. 1. What is Open Data? Data: For the purposes of these Guidelines, the term “data” refers to all structured information, unless otherwise noted. Dataset: For the purposes of this Guideline, the term “dataset” refers to a collection of data presented in tabular or non-tabular form. Fair Information Practice Principles: The term “Fair Information Practice Principles” refers to the eight widely accepted principles for identifying and mitigating privacy impacts in information systems, programs and processes, delineated in the Nigerian National Strategy for Trusted Identities in Cyberspace1. 1 TBD Government information: “Government information” means information created, collected, processed, disseminated, or disposed of, by or for the Federal Government. Information: “Information” means any communication or representation of knowledge such as facts, data, or opinions in any medium or form, including textual, numerical, graphic, cartographic, narrative, or audiovisual forms. Information life cycle: “Information life cycle” means the stages through which information passes, typically characterized as creation or collection, processing, dissemination, use, storage, and disposition. Personally identifiable information: “Personally identifiable information” (PII) refers to information that can be used to distinguish or trace an individual’s identity, either alone or when combined with other personal or identifying information that is linked or linkable to a specific individual. The definition of PII is not anchored to any single category of information or technology. Rather, it requires a case-by-case assessment of the specific risk that an individual can be identified. In performing this assessment, it is important for an agency to recognize that non-PII can become PII whenever additional information is made publicly available (in any medium and from any source) that, when combined with other available information, could be used to identify an individual. Mosaic Effect: The Mosaic Effect occurs when the information in an individual dataset, in isolation, may not pose a risk of identifying an individual (or threatening some other important interest such as security), but when combined with other available information, could pose such risk. Before disclosing potential PII or other potentially sensitive information, agencies must consider other publicly available data – in any medium and from any source – to determine whether some combination of existing data and the data intended to be publicly released could allow for the identification of an individual or pose another security concern. Open data: For the purposes of these Guidelines, the term “open data” refers to publicly available data structured in a way that enables the data to be fully discoverable and usable by end users. In general, open data will be consistent with the following principles: Public. FGN MDAs must adopt a presumption in favor of openness to the extent permitted by law and subject to privacy, confidentiality, security, or other valid restrictions. Accessible. Open data are made available in convenient, modifiable, and open formats that can be retrieved, downloaded, indexed, and searched. Formats should be machine-readable (i.e., data are reasonably structured to allow automated processing). Open data structures do not discriminate against any person or group of persons and should be made available to the widest range of users for the widest range of purposes, often by providing the data in multiple formats for consumption. To the extent permitted by law, these formats should be non-proprietary, publicly available, and no restrictions should be placed upon their use. Described. Open data are described fully so that consumers of the data have sufficient information to understand their strengths, weaknesses, analytical limitations, security requirements, as well as how to process them. This involves the use of robust, granular metadata (i.e., fields or elements that describe data), thorough documentation of data elements, data dictionaries, and, if applicable, additional descriptions of the purpose of the collection, the population of interest, the characteristics of the sample, and the method of data collection. Reusable. Open data are made available under an open license that places no restrictions on their use. Complete. Open data are published in primary forms (i.e., as collected at the source), with the finest possible level of granularity that is practicable and permitted by law and other requirements. Derived or aggregate open data should also be published but must reference the primary data. Timely. Open data are made available as quickly as necessary to preserve the value of the data. Frequency of release should account for key audiences and downstream needs. Managed Post-Release. A point of contact must be designated to assist with data use and to respond to complaints about adherence to these open data requirements. 2. Why Is an Open Data Guideline Necessary For|In Nigeria? Opening up government data and information are key foundations to enabling engagement with citizens by using new technologies to connect the public to government and to one another. Making government data and information available online invites individuals and organizations to transform data and information into tools and applications that help individuals, institutions and communities; and to promote partnerships with government to create innovative solutions to the opportunities and challenges faced by Nigerians. Increase transparency in Governance Further Government goals Create economic opportunities for Nigerians Additional funding for NITDA to make sure Open Data Initiatives in Nigeria have the requisite infrastructure 3. The Benefits of Proactive and Relevant Guidelines to Nigeria Longevity beyond any individual leader’s term A wake-up call to spur slow-moving FGN MDAs & Bureaucracies Strengthen the Nigerian FOI Act 4. Elements of an Effective Open Data Guideline Goals- Why are you launching an open data program? What do you hope to achieve? Share this information in your policy. Be explicit and help people understand the benefit of spending time and energy on open data. Datasets Specify the types of datasets to be included in your portal. You can limit them to certain areas, such as finance or crime, or be more inclusive. We recommend including as much data as possible. For example, a City regarded as a IT hub’s policy explicitly states that all city data that does not contain personal information should be on the open data portal. They have an “open by default” mandate. This means that all public data is considered “open data” unless it contains personal information about citizens. This approach makes it easier to get all agencies to publish their data on the open data portal. Plus, you’ll save yourself time you would have spent answering the question, “What do I publish?” Designated Roles Use your open data policy to designate the roles of specific stakeholders within your open data program. Another major city, for example, used its policy to create a working group between department heads and its Chief Data Officer. The group convenes on a regular basis to discuss how each department is contributing to the mayor’s open data initiative 5. The Paths to Open Data Guidelines|Policies available for Nigeria to consider individually or Hybrid a. Executive Orders b. Non-Binding Resolutions c. Internal Regulations d. Codified Laws 6. What data owners need to do with data Table 1: Expectations for Data Owners in Nigeria The FGN Must Notes The FGN must take steps to expand public Enforced by NITDA access to government data by making it available online unless restricted by law, contract or policy; The FGN must re-prioritize and expand data collection efforts towards those that enable citizens and sectors to create value from government data; FGN-MDAs must adopt NITDA’s open license for data and ensure data accessibility through NITDA in accordance with Nigeria’s Open Data Policy, which should include the requirement that data be published in an open machine-readable format NITDA must ensure that citizens can give feedback on, and assessment of, the quality of published information and provide input to which data should be prioritized for publication 7. How the data needs to be published Nigeria’s Open Data Guideline & Policy2, should include the requirement that data be published in an open machine-readable format 3. What type of data needs to be put in the public domain? To evolve from Stakeholder Engagement & Deliberation 1. Pre Implementation Activities a. Stakeholder Engagement & Interaction b. Guidelines Adoption 2. Pre Implementation Activities by the FGN Prior to adopting the Open Data Charter, Nigeria should release a high-level public statement (issued by the Head of State, Minister, or NITDA-DG) that articulates the adoption of the Open Data Charter and defines the following four key elements: 2 To be Developed 1. Appointment of a key ministry, department, or agency, including a direct individual, to serve as point of contact responsible for implementing the Open Data Charter’s principles. 2. Delivery mechanism(s) through which the Open Data Charter will be operationalized by the institution. The specific activities, methodologies, tools, and processes of the mechanism(s) that will be used to deliver the Open Data Charter should be defined. 3. Time-bound actions that outline specific, realistic deadlines by which progress toward implementation can be demonstrated. 4. Means of verification of the specific actions that will be taken by the institution to track the progress of the Charter’s implementation. 8. Pre Implementation Guidelines a. Agencies management of information resources must begin at the earliest stages of the planning process, well before information is collected or created. Early strategic planning will allow the Federal Government to design systems and develop processes that unlock the full value of the information, and provide a foundation from which agencies can continue to manage information throughout its life cycle. b. Agencies shall take the following actions to improve the management of information resources throughout the information’s life cycle and reinforce the government’s presumption in favor of openness: