General comments Petr Elias, Czech Statistical Office When specifying the purpose of GAMSO it is mentioned that the aim is to complement and further elaborate over-arching activities listed in GSBPM and to develop a generic activity model for statistical organization. While the aim and the target audience of GSBPM is evident it is not the case in the GAMSO. The GSBPM provides a clear framework for integrating data and metadata standards as a template for harmonizing statistical computing infrastructure and to provide a framework for process quality assessment and improvement focused on the managerial issues dealing with the corporate governance of metadata projects and business. Target audience are managers, designers, subject matter specialists, methodologists and IT experts. The GSBPM is aimed to assist statistical metadata experts to develop business cases for a new or enhanced SMS. In this direction are also specified the over-arching activities (see GSBPM Version 5 section VI). By GAMSO is neither clear the usefulness nor the target audience of this model. Every national statistical office is based on its national and supra-national legislations which are specifying clearly the obligatory areas of “overarching activities” and the consequent statistical organization model. This model is then obligatory for all users both inside and outside the CSO. Questionable is in GAMSO also the “underestimation” of issue dealing with the quality of statistics and its management. While in GSBPM is this issue mentioned with the highest priority, in GAMSO it is hidden under 2.3. "Manage capabilities" which is far from highlighting. We could not find anywhere the description of the SN-BAM model and therefore we could not consider usefulness of applicability of this model for GAMSO. Ebbo Petrikovits, Czech Statistical Office The chapter Purpose declares the reason for preparing the document on GAMSO v0.2. (i) to extend the GSBPM by adding activities for supporting statistical production, mainly (ii) co called “over-arching processes” which were briefly characterized in the GSBPM v. 5.0. The basic question is to whom should be the intended the document GASMO; who is the target audience - top management of the statistical institutes, statisticians, IT specialists, administration of the SO ? Chapter Origins states that two documents were taken as main sources of information for elaborating the GSMO. The GSBPM practically full version and SN-BAM about 80% of the full version. When I have compared the text of GAMSO version with the SN-BAM content I have a feeling that both text are practically the same. In this context I have following question. Why both documents were compiled into one document with the same content? What is the value added? It seems to me the reasonable activities would be to finalize the SN-BAM. It means to give a new title of the document (leave out the “Statistical Network”) and devoted the document to the supportive processes inside the statistical institutes. Finally we will have two basic documents GSBPM and Supportive processes within statistical organizations. Of course the second document should contain also the specification of the target audience. I would recommend leaving out the fifth component of the structure – “Other organization-specific activities (resp. processes). The document should be applicable for the whole portfolio of statistical organization responsibilities, not the described for groups of activities. In this connection national statistical acts should be taken in consideration. Concerning the component “4. Production”, it seems to me that this part is redundancy to the GSBPM. I would recommend, leaving out this part of the text and replacing it with a link to the GSBPM document only. Concerning the component “1. Strategy” I would recommend to add one item on statistical data confidentiality and data disclosure and one item on ICT security. There are very important issues connected with statistical activities. For further activities on this topic I would recommend to focus on the document SN-BAM; this document should be next document increasing the set of models connected with statistical work (similarly as GSIM model). It is not necessary to put various models (GSBPM, GSIM and Supporting Processes) in one document. Strategy Laurie Reedman o o o o o I don’t really like the table format. There is way too much text in one or two skinny columns. After scrolling down a few times I forgot what the column headings were and then I got lost trying to go up and down. I found the column headings on the left under Activity, Level 1, 2 and 3 to be too abstract. I wasted a bit of time wondering what the levels were. Maybe if the table was wider or if it was just in paragraph format you could use indentation or some other signal to the reader that there are indeed 3 levels, and not spell it out “Level 1, 2, 3” at the top. I think it is only Production that has 3 levels anyway. Under 1. Strategy, 1.1 Position – maybe you could find a better heading than “Position”. It doesn’t fit very well with the other headings (Govern, Influence and collaborate, ...). The others are all verbs but for me the word “position” needs something with it to give it action. Similar to Capability where the headings are about managing different things, maybe in 1.1 the heading could be crafted around establishing/enforcing/strategizing the NSO’s position within the NSS. I’m not sure about the column Includes. Does it mean that the things listed there are the only things included, or just a sub-set, maybe the most significant ones? Under Capabilities the things listed in the Includes column start to sound a bit motherhoody, such as Promote capabilities (what does that mean? Awareness building seminars?) and Manage quality (of course, but in this context, what would that look like?). (Laurie Reedman, Statistics Canada) Eurostat feedback: o o o The first header of the model is strategy. In management terms, leadership should also be included and there are elements under strategy (vision, values for example) which are not really linked to strategy by rather leadership. Mission is missing in the model, as far as we can see at least. It is a very important statement explaining the raison d'être of the organisation, which is an important statement for staff and stakeholders. The terminology in the second line of headers in the model (position, govern and influence and collaborate) are not easy to understand. Maybe they could be reformulated in a more consistent and selfexplanatory way 1.3 (AH) The description in GAMSO starts with reference to “liaison and coordination with other statistical organizations”. SN BAM does not narrow the scope in this way. 1.3 should including Influencing, and collaborating with, agencies whose primary mission and identification is not as a “statistical organization” (eg administrative departments, industry bodies) to make by-product data available for statistical purposes. 1.3 can include strategic engagement with key users of official statistics to better address their needs. If such strategic engagement activities are not in scope for 1.3 then they need to be supported elsewhere in GAMSO. Although this particular variation from the wording of SN BAM is not supported by ABS, the other additions to 1.3 compared with SN BAM (eg reference to local, regional, national, multi-national co-ordination) are understood and supported. We note that the feedback from INEGI in regard to 1.3 makes the same point as this ABS feedback. Capability Ron Prevost, U.S. Census Bureau It may help to expand section 2 to include some additional statements on concrete ways in which GAMSO (or extensions thereof) might be used. Examples might include (a) specific forms of the "cost and resource management" referenced in the second paragraph of section 2; (b) benchmarking of some features of a statistical organization; (c) coordination across statistical organizations; or (d) management training. Nadia Mignolli, ISTAT Capability Manage capabilities Manage data, metadata and process data Manage quality Capability Manage capabilities Not present Concerning “Manage data, metadata and process data”, this should be part of the Business Line “Corporate Support”, more specifically under “Manage IT” and/or “Manage information and knowledge”. With regard to “Manage quality”, this is an activity that is not inherent to the Business Line “Capability” and already performed in BAAM “Manage”. Eurostat feedback: Positioning key capabilities like "data, metadata and process data management" and "quality management" under "manage capabilities" is counter intuitive and not in line with the proposed approach as they refer to actual statistical capabilities involved in the production of statistics. It can create confusion of the scope of activities targeted under this heading. They should be given a much higher profile. 2.2 Alistair Hamilton There is nothing in the description of Capability that explicitly refers to sharing and reuse internationally. Readers familiar with broader modernisation strategies under HLG may “take this as read”. An ABS reviewer noted, however, others could o o read the description of “2 Capability” as encouraging sharing and reuse of infrastructure within/across a statistical organization read 2.1 and 2.2 as somewhat linear – eg we identify the need for new/improved a capability (2.1) and then we develop capability improvement projects from the requirements stage through to their completion (2.2). It could be assumed all capability developments in 2.2 are projects entirely within the statistical organisation. CSPA suggests that sharing and reuse may entail projects at multiple levels. In terms of roles identified in CSPA, the main project to design and build a shared capability solution may be collaboration, or it may have taken place already within a different statistical organisation. Even in such cases, the statistical organization adopting the shared infrastructure will almost certainly still require a local project that addresses the “Assembler” role from CSPA. This capability project will integrate the infrastructure within the local organization’s environment, including any required extensions/modifications. It is envisaged these “Assembler” activities (in addition to any CPSA capability "Design" and "Build" activities performed locally) would be within scope for 2.2 within GAMSO. (CSPA “Configurer” activities for an individual statistical program would be in 4.3.) It is proposed to add the following sentence to the end of the existing description for 2.2. This activity includes cases where capability improvements are developed through partnering with other statistical organizations or by selecting and implementing reusable infrastructure originally developed by others. 2.3 Alistair Hamilton ABS has similar concerns to Istat and Eurostat in regard to GAMSO adding a reference to Data, metadata and process data (paradata) management are also included here which is not present in SN BAM. Developing, maintaining and supporting capabilities (eg systems, policy frameworks and business processes) for managing data and metadata are included in “Capability”. Most of the activities associated with managing specific data and metadata, however, would not. Management of data and metadata associated with one particular production process could be recorded under Production. As Istat suggests, applied management of data and metadata as a corporate resource could be part of 3.5. Similar concerns arise in regard to adding the reference to Manage quality. Once again, some aspects of Manage Quality (eg design and operation of quality gates during an individual statistical production process) might be considered part of Production. Other aspects might be considered strategic. Corporate support Ron Prevost, U.S. Census Bureau Section 3.5 Corporate Support/Manage Information and knowledge: Add a specification to manage and communicate policies related to the confidentiality and privacy of individual and business information. Also add the disposal of records no longer needed for production or the archival of records specified by national laws. Section 3.6 Corporate Support/Manage consumers and suppliers: Add management/coordination with corporate data suppliers to support potential data streams (Big Data/ The Internet of Things) and analytics. Nadia Mignolli, ISTAT Corporate Support Manage consumers and suppliers Manage communications and media relations Manage stakeholders consultations Educate users and improve statistical literacy Manage cross-product user support Production Implement o Disseminate … Manage user support Corporate Support Manage consumers and suppliers Public affairs Media relations Stakeholders consultation Manage user support Production Implement o Disseminate … Not present Concerning “Manage consumers and suppliers” as a whole, the detail level of the single activities in GAMSO seems to be excessive. However, this does not represent a real problem, as the compatibility between GAMSO and BAAM is ensured in any case. The real question is the presence of “Manage user support” also in GAMSO “Production”/ “Implement”/“Disseminate”, that at this point is redundant and not justified (but by the need to be compliant with the GSBPM). In general, “Manage user support” is a specific action belonging only to the Business Line “Corporate Support”. For this reason in the BAAM is it placed there and it should not be duplicated elsewhere, introducing overlapping single activities (e.g. Manage user support vs Manage cross-product user support, etc.). Eurostat feedback: o o Management of statistical confidentiality is wrongly placed: it is not an IT issue. It would be better placed under information management. Manage HR: staff motivation and satisfaction could be included 3.6 – Title (AH) While the title for 3.6 aligns with SN BAM, comments from ABS reviewers highlighted this is an area where both SN BAM and GAMSO could be clarified. It is understood that “suppliers” is intended to be a reference to data providers / respondents. The word can be easily misinterpreted, however, as referring to commercial provides of goods and services for the statistical organization. Rather than simply clarifying the wording, however, it is proposed that 3.6 focus more specifically on consumers. As noted in SN BAM, management of providers related to a particular statistical production process is part of Production. Wider activities to build and maintain understanding and support among providers can be considered Strategic. Once these activities are categorised correctly, 3.6 might be 95% about consumers and 5% about providers. For the sake of GAMSO being strong and “to the point” regarding relationships with the user community, however, it is recommended this category focus only on consumers. It is proposed the title be changed to simply Manage Consumers (or similar). 3.6 - Description - Comment 1 (AH) SN BAM makes specific reference to services offered by the organization. GAMSO simply mentions “Manage cross product user support”. Given an increasing emphasis on offering data services in addition to (and in preference to) tradition packaged “products”, could the description of 3.6 include reference to supporting users in regard to corporate dissemination services? (Within ABS - and it appears more broadly – most modern dissemination services are “cross cutting” by nature. It is unusual, typically not well matched to user needs, and typically inefficient, to offer a dissemination service which can only access outputs from a single statistical production process.) 3.6 - Description - Comment 2 (AH) An ABS member of the team that developed SN BAM notes that statistical literacy was considered by that team to be primarily part of 1.3 (Strategy : Influence and Collaborate). While the exact term wasn’t used, statistical literacy was considered part of “Build & maintain external statistical excellence” (in an external context) within 1.3. Cultivating statistical literacy is a strategic activity. Given some readers may be interested in specifically that activity, GAMSO could add a specific dot point to 1.3? In addition, the dot point “support use externally” in regard to the category 2.4 (“Support capability implementation”) may include an applied focus on ensuring the external user has sufficient statistical literacy to harness/implement the capability effectively. It is proposed the dot point on statistical literacy be deleted from 3.6. Given some readers may be specifically interested in this activity, GAMSO could add a specific dot point to 1.3? Production Nadia Mignolli, ISTAT GAMSO SN BAAM Production Review Manage o Evaluate Production o Gather evaluation inputs Conduct evaluation Agree an action plan Plan o Secure project approval and funding Plan project tasks, timetable, budget and resources Plan quality and performance metrics and targets Monitor o Monitor project quality and performance Monitor project budgets and timetables Identify emerging risks and issues Report on project progress Adjust Develop corrective actions Revise project plan Communicate corrective actions and revised expectations Although it is understandable that GAMSO main target is to be entirely compliant with the GSBPM in the Production BA Business line, this should not prevent from considering activities to be performed by any National Statistical Institute/Office, i.e. all the activities listed in the grouping called “Manage” in the BAAM. Conversely, the activities listed in GAMSO “Evaluate” affect only those of BAAM “Implement” that are already in execution at that stage. They do not include all those activities concerning the operational planning of “Implement” activities: these are peculiar of Project Management and cannot be considered negligible (see “Plan” in BAAM “Manage”). BAAM “Manage” affects both “Develop” and “Implement” that can also be modified according to evidences resulting from “Manage”. Summing up, “Manage” should be considered as a core strategic phase within the “Production” Business Line and should be maintained as overarching with respect to “Develop” and “Implement”. It deals also with quality issues and management. Production Develop o Build Build collection instrument Build or enhance process components Build or enhance dissemination components Production Develop o Build Assemble and configure system components This can be considered as a minor difference, since the description of “Build” as a whole in both models is not substantially different. However, as done in BAAM, it should be stressed that the real building actions are managed within the Business Line “Capability”. Eurostat feedback: We recognise that the Production section has been taken from GSBPM and that modification of its content is not in the scope of GAMSO. We would like however to remark that it seems the use of mix-mode data sources does not seem to be taken into account. Statistical institutes should in the future use as much as possible admin data / big data together with surveys in a combined way, in order to reduce costs, provided that fit-forpurpose quality is delivered on time. We realise this is not the right forum for discussing aspects related to GSBPM, but we would like to draw attention to this fact for future discussions. Issues arising from absolute alignment with GSBPM (Alistair Hamilton) Several ABS reviewers raised issues arising from the proposed absolute alignment of Production activities in GAMSO with GSBPM. Key points from the feedback are summarized below. While GSBPM includes a broader scope than just “direct collection” (surveys and censuses), its categories and descriptions implicitly place most prominence on this mode of collection. In 1. contrast, however, there is a common tendency for modernization programs (which GAMSO is intended to support) to seek to shift the balance away from direct collection. Para 8 of GSBPM says GSBPM follows the logical sequence of steps in most statistical business processes. Modernisation aims for “statistical business processes” which are more dynamic and (even) less linear than was the case previously. Addressing the complete "logical sequence of steps" described in GSBPM for a single "statistical business process" may become less pervasive in future. o 2. o Some “statistical business processes” may focus strongly on Collect, with the expectation a range of other “statistical business processes” (not always known in advance) will then process, analyse and disseminate the content that has been collected. Other “statistical business processes” may focus on “Analyze and Disseminate” in a responsive manner to meet specific needs. Such processes may do very little in their own right in regard to “Collect” and “Process” in the traditional sense. GSBPM does not preclude the above possibilities. GSBPM appears, however, to place most prominence on o o cases where there is a “traditional” “line of sight” which runs through Specify Needs, Design, Build, Collect, Process, Analyse and Disseminate for a single statistical business process, rather than more dynamic sourcing and dissemination of content that meets specified needs. GSBPM tends not to give prominence to modern directions in regard to Analyze (eg story telling) and Disseminate (eg provisioning content for dissemination via dynamic services) activities. As noted by Istat, wording of GSBPM tends to over emphasize “Build” rather than 4. “Assemble/Reuse” - although it does not preclude the latter. 3. While ABS recognises that absolute alignment with GSBPM is currently proposed as a “non-negotiable” characteristic” for Production activities within GAMSO, we also note that Istat and Eurostat have comment that – in various ways - this “non-negotiable” means GAMSO does not address as explicitly, and as clearly, as it might some of the trends in statistical production activity which tend to be of increased prominence when modernising. If absolute alignment is non-negotiable then perhaps the feedback received suggests the next review of GSBPM could be (eg) in 2016 rather than waiting until (eg) 2018. Absence of “Production: Manage” category (variation from SN BAM) (AH) Istat notes that “4.3.1 Evaluate” spans significantly less than “Manage” in SN BAM. ABS agrees that considerable effort is often expended in o o Operational planning for a particular cycle of a particular statistical business processes 1. This planning does not change the Design of the statistical business process, it merely ensures all the logistics (eg human resource, timelines, dependencies) are in place for the upcoming cycle of Collect, Process, Analyse, Disseminate. Monitoring and managing activities within the cycle and responding dynamically (eg “crisis management”) when unexpected issue arise 1. Activities undertaken when managing a crisis can, and should, be differentiated from learning from the experience, and considering ongoing improvements to Design for future cycles, as part of Evaluate. The first sentence for Broad Area 4 (Production) for GAMSO says These activities cover all steps necessary to manage, design and implement statistical production processes or cycles… This is not wording from GSBPM. Adjusting this wording, therefore, would not create an inconsistency with GSBPM. In fact, the current wording may represent an inconsistency with GSBPM. The “missing” aspect of what SN BAM is describes under “Production: Manage” could be considered Project Management of the statistical business process. GSBPM describes Project Management as an overarching process rather than placing it in the Evaluate phase. While many over-arching processes from GSBPM are now represented elsewhere in GAMSO, “management” activities that o o relate to statistical business process overall, but do not relate solely to one of the eight phases in GSBPM should be accommodated within Production. If “Manage” is not added into “Production” in GAMSO then the first sentence for Broad Area 4 should be reconsidered lest it lead readers to conclude o o the eight lowest level categories in Production in GAMSO somehow include project management of a statistical production process, where this would be inconsistent with GSBPM. Origins Jean-marc Museux Eurostat feedback: It would be good to position GAMSO in relation to other standards/initiatives: The document mentions what the relationship between GAMSO and GSBPM is. It would be valuable to state also what its positioning is compared to GSIM. This could at this stage simply take the form of a short paragraph, whose content would presumably be very similar to what has already been written on GSBPM vs. GSIM Alistair Hamilton We have a minor editorial comment on the text quoted below. The first sentence related to GSBPM is relatively long and complex. For ease of reading “GSBPM” rather than “It” is proposed to start the second sentence. To ensure full coherence with the GSBPM Version 5.0, which has been adopted as a "cornerstone" standard for the vision of standards-based modernisation promoted by the High-Level Group for the Modernisation of Statistical Production and Services. GSBPM It was agreed after a lengthy and broad consultation process within the international statistical community, and has been adopted by over 50 statistical organizations worldwide. Purpose David Barraclough Nothing specific on the proposal (which I think is clear and now I know what paradata is!), though it could be useful to add an simple introductory diagram showing the relationship between GAMSO, GSBPM, and GSIM and the principle actors/use cases. Klas Blomqvist A comparason has been made between GMSO an Statistics Sweden's Process Chart. The detailed comments can be found in the attatched document. Statistics Swedens Process Chart vs GBAM english.docx Jean-marc Museux Eurostat feedback: There is an overall support to extend GSBPM beyond the traditional production activities. This is visible in many of the contribution of Eurostat at the off set of HLG initiative (see for instance contribution of W Radermacher to the first HLG workshop in 2011) The model looks like an inventory of activities, and the dynamic between these activities and results / outputs, as well as interaction between the different components, is not visible. Given that the model represents much needed extension of the GSBPM to management processes, maybe the acronym could be changed and the A of activities replaced by M of management, if this is the ambition of the model of course. But this change might imply a total re-thinking of the detailed elements. One of the main weakness of the current model is that it does not properly integrate activities related to quality management, This element hardly figures in GAMSO: it is included in the "Manage Capability" activity. It seems that this positioning is counter-intuitive, borderline wrong and does not give a high enough prominence to quality management, which is an important activity in several statistical organisations. The "evaluate" activity is embedded under the box production / review only, while a PDCA approach should underpin the overall model. The choice of organisational design seems to be missing Juan Munoz-Lopez After a review of the model, I would like to suggest the following: 1.1 Change “Determine organizational goals” for “Determine vision, mission and strategic goals” 1.2 Add “General coordination and alignment”, “General organization policies” and “Publication of policies, guidelines, and normative documents”. 1.3 Coordination of the national statistical system: The organization and coordination of other organizations which produces statistics which must be integrated in a national system. 1.3 Strategic affairs management with non-statistics partners: There is the need to stablish relation with parties from different departments from the government, with the private sector, the academic sector and the civil society. Although in a strict sense they could be seen as users, strategic affairs goes beyond that, collaboration in national strategies, getting support for statistics projects, etc. 2.4 Clarify or split the topic, I’m not sure if the topic is about strategic planning, project management, methodological assistance, technical support, enterprise architecture design and implementation or a mix of them (or maybe those elements are missing in other sections of the document). 3.2 Split “Manage finances” into “Management of physical assets” and “General services management”, the reason is that finances is a field about money and accounting, and Management of physical assets and general services is about the procurement (buying), control, maintenance and disposition of the estate properties and instrumental assets (infrastructure, furniture, etc.). Production, I recognize that production translates the processes and sub-processes from the GSBPM v5, but I still haven’t found a process for the data and process quality management. I think that this is an important issue that still missing; in the model a found that 2.3 is related with this issue, but I think that it covers more the knowledge to do things than the actions to operate them. 3.4 Manage IT, I would list: Management of IT assets and services, IT security (see next observation), technological solutions development, research and prospective studies in the statistics applied IT field (maybe this last one would fit in 2.1), technological change management. 3.4 Information security might be separated from IT, IT is in charge of “informatics security” (or IT security), but Information security has a broader scope because it also deals with physical access control, paper documents management, assets protection, and so on. From my point of view this topic must be in a separate sub-process, like 3.X. 3.5 Add some additional comments (or maybe bullets) about the management of information versions, historical information (management of the archiving and the control of time series), common vocabularies, code lists, methodological rules, etc. 3.6 Add “Design of new products and services”, “Design of communication strategies” and “User satisfaction analysis” Alistair Hamilton The statement of purpose could be strengthened. The following additional and changed text - - or a variation on it - is proposed. Like the GSBPM, the GAMSO aims to provide a common vocabulary and framework to support international collaboration activities, particularly in the field of modernisation. While individual collaborations typically focus on modernising a particular aspect of production (as described by GSBPM), statistical production occurs within a broader context of corporate strategies, capabilities and support. GAMSO helps partners place collaborations in context, including understanding each other’s business drivers and objectives. In addition, GSBPM is becoming increasingly used for cost and resource management within organizations. GAMSO is also expected to fill such roles when there is a need to consider a wider context than just the activities directly related to the production of statistics. Structure Alistair Hamilton ABS has no comments on the structure at the very highest level as described in this section. Comments have been provided on the four individual sections which detail each of the four “broad areas” which exist within this highest level structure. Nadia Mignolli In general, Istat deems it very important to reach a higher alignement level between GAMSO and SN BAAM. Of course, this applies especially to levels II and III of the models. For further details, a scheme with some comments on the differences between GAMSO and SN BAAM is attached. The comments regard the Business Lines Production, Capabilty and Corporate Support. Istat_Comments on GAMSO_Janaury 2015.docx Jean-marc Museux Eurostat feedback The main concerns are twofold : 1) the distinction between corporate support and capability 2) The labeling of the GAMSO level 1 categories o o Firstly, we continue to find artificial the splitting between "Corporate support" and "capability". The current splitting is based on statistical versus non statistical capabilities. Ambiguities can arise because both concern the same type of activities (e.g. IT: support and development; People: skill management and support capability implementation). In addition, there seems to be conceptual differences in the approach taken for both areas. In corporate support the accent is put on the areas for activities (Finance, HR, Information, …) while in "capability" the accent is put of the identification, development and management activities irrespective of the area (data management, Innovation, …). This distinction and the difference of approaches need to be further explained in the proposed documentation. Secondly, the current labelling of activity areas: activity area 2 is called "Capability". "Capability" is a term that has a very specific meaning in the Enterprise Architecture context. Having a capability means being able to undertake an activity. "Capability" is future-oriented while "Activity" is static. Therefore "Capability" cannot be the name for an activity: it is simply a misnomer. This could be rectified by simply changing the name of the area with "Manage capabilities" or "develop capabilities". As these names are already used in GAMSO at lower levels, maybe "Capability improvement" or "Capability building" could be used. Limitations and Extensions Jean-marc Museux Eurostat Feedback: The model provided for a possible "local" extension of GAMSO is limited. The only two possibilities mentioned are to add an extra-layer or to add a more detailed level in the classification. We do not see why the possibility to add other activities at the same levels as those already defined should be excluded. This reduces the flexibility of the model and hampers its broad use in NSIs. Nadia Mignolli This figure suggests the possibility of adding an extra Business Line containing specific activities that meet the needs of local situations. This can be risky and the model can change completely its nature with a serious impact on its overall structure. On the contrary, it is more convenient to allow to insert additional specific activities at the most detailed level of each Business Line, so as to satisfy local needs, if any.