Professor John McMillan
Dear Professor McMillan
The Australian Bureau of Statistics (ABS) would like to thank the Office of the Australian Information Commissioner (OAIC) for the opportunity to comment on the Issues Paper: Toward an Australian Government Information Policy, and specifically on the 10 Draft Principles on Open Public Sector Information.
At the outset, we would like to express our strong support and endorsement for the concept of an Australian Government Information Policy.
It is pleasing to note the acknowledgement the Paper gives to the ABS as one of a number of agencies with responsibility for Government information policy and management through referencing the ABS Quality Framework, its adoption of Creative Commons and availability of tools such as CDATA Online and Betaworks being cited as examples of innovative ways in which ABS makes its data accessible to users.
We recognise that, for many government departments, policy development and program and service delivery are a higher priority than the management of information and as such, a number of departments may have limited experience in the management of their information as a strategic resource. They may therefore not be in a position to recognise the full public benefit that results from undertaking such management. As an agency with information management as a core function, the ABS formally offers its assistance to the OAIC with regard to taking forward improved management of government information across the Australian Public Sector
Based on our experience in the management of statistical information we strongly recommend that an Australian Government Information Policy should reflect the requirement that agencies recognise information as a strategic resource and asset. Government information should not just be passively managed but should be proactively enhanced (such as through expansion to content or improvement to quality or utility) in order to unlock the evidence base to maximise informed decision making and to better support related government initiatives such as Gov 2.0, FOI and Open Government.
The ABS has some concern that the Paper does not recognise the intrinsic importance of statistical standards (including metadata) in ensuring the quality, discoverability and accessibility of data. We recommend therefore, that the final Government Information Policy should more explicitly recognise the importance of statistical standards and should clearly recognise ABS' legislated responsibility in setting statistical standards and providing statistical leadership in the coordination of collection, compilation, dissemination and integration of official statistics.
Also of relevance to a Government Information Policy is the agreed recommendation from the 2010 NatStats Conference for the concept of a national statistics policy. Following key stakeholder consultation it is envisaged that such a policy would cover data collections regardless of source (administrative data, surveys, censuses etc) and would include agreed principles for creating and managing statistical data. This policy would be a subset of the broader Government Information Policy and would complement and facilitate it by providing active statistical information strategies for producers and users of official statistics. ABS would be pleased to discuss this further with the OAIC.
Comments specific to the Draft Principles on Open Public Sector Information
In general, ABS is supportive of the 10 Draft Principles and notes that they align well with the information management and access policies and practices of the ABS.
Principles 3 (Robust Asset Management Frameworks) and 6 (Transparent Complaints Processes) are supported without any specific comments. More specific comments to each of the remaining principles are provided as follows:
- Principle 1: Open Access to Information a Default Position is supported. ABS notes that while it is important that a Government Information Policy should mandate that there be standards for Government information, in a high level Policy it is not necessary to define what those standards should be
- Principle 2: Effective Information Governance is supported. The ABS would add that a national statistical policy would provide more effective information governance with regard to statistical information
- Principle 4: Findable Information. ABS considers that the concept of 'Findable Information' is too narrow and suggests that Principle 4 should be broadened to 'Discoverable Information'. To explain further, the term 'findable' implies that clients already know what information is available to them. The term 'Discoverable' makes it clearer that clients must be able to gain knowledge of information that was previously unknown to them. In order to maximise the utilisation of information it is critical for agencies to adopt robust data definitions and standards (metadata) to allow for data to be discoverable and comparable. ABS therefore recommends a high level of importance be placed on provision of metadata within Principle 4. We also recommend acknowledgment in Principle 4 that some government information will always remain confidential (e.g. personal information provided to ABS). It should also be noted that dynamic content (such as the dynamically created tables in a tool like Census Table Builder) cannot be indexed by search engines or appear in asset registers as such content doesn't exist as a separate entity until created
- Principle 5: Sound Decision-making Processes is supported. We note this Draft Principle introduces the concept of timeliness, though it is limited to the timeliness of decision making in agencies. Timeliness of access to information should be more broadly addressed in the OAIC Principles. The ABS Data Quality Framework includes timeliness as a dimension of data quality and provides practical questions to help assess timeliness. While a high level statement about timeliness is appropriate to the OAIC Principles, we recommend the subsequent Government Information Policy draw the concept out in more detail and expand it to adopt all seven elements of data quality - timeliness, relevance, accessibility, interpretability, coherence, accuracy and institutional environment
- Principle 7: Open and Accessible Formats Online is generally supported. However, ABS recommends this Principle be expanded and renamed 'Usable Information'. Usability refers to how easily users can learn to use information products to achieve their goals and how satisfied they are with the process. Open and accessible formats contribute to usability, but other attributes of usability as they relate to the online presentation of information should also be addressed in Principle 7. This includes the adoption of presentation formats which allow users to quickly learn and remember how to use information with minimal error and with a high level of overall satisfaction
- Principle 8: Appropriate Charging for Access is supported. We recommend that dot point 1 of this principle refers to the Australian Government Cost Recovery Guidelines
- Principle 9: Clear Reuse Rights is supported. This Principle could usefully reference Creative Commons licences as used by ABS and others
- Principle 10: Engaging with the Community is supported. ABS comments that any engagement should be genuine with a commitment on the part of government agencies to respond to the views of the community about what information is made available and how it is presented (with a particular emphasis on it meeting the community's needs in regard to usability)
The ABS is happy to discuss any aspect of this response with the OAIC and, in particular reiterates its interest in further discussing a national statistical policy and assisting the OAIC with regard to improved management of government information across the Australian Public Sector. If you would like to discuss any elements of this submission please contact Jeanette Cotterill on (02) 62527819.
We are happy for this submission to be made public and we will be placing a copy on your blog.
Deputy Australian Statistician
Australian Bureau of Statistics
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