Australian National Data Service submission

3 March 2011

Response to the Office of the Australian Information Commissioner

Comments on the Draft Principles on Open Public Sector Information

The Australian National Data Service (ANDS) is pleased to have the opportunity to comment on the ten draft principles laid out in “Towards and Australian Government Information Policy” published by the Office of the Australian Information Commissioner.

Overall, ANDS is very supportive of the principles. In the main, our comments are limited to suggesting ways in which ANDS may be able to help with the implementation of these principles by virtue of activities which are currently in train or planned for in the future. In this submission we provide some of the context in which ANDS operates and what it does, followed by comments on those principles where ANDS can add value and substance.


ANDS ( was established to support the development of the Australian Research Data Commons, and, as such, shares many of the concerns of the Information Commissioner in establishing a firm policy base for the open publication and sharing of information. The Australian Research Data Commons supports the discovery and access to research data held in Australian universities, in publicly--‐funded research agencies and in government organisations for the use by researchers. Collectively, our domain might be referred to as ‘public sector information’ recognising that this is broader than just government organisations.

ANDS creates and supports infrastructure for the research and innovations sector; this sector is both a significant consumer as well as a producer of public sector information.

ANDS supports the construction of a range of ICT utilities to capitalise on and ensure greater use and reuse of existing data resources, as well as better management of new data generated in Australian research.

One way to access the contents of the Australian Research Data Commons is through Research Data Australia . This is a set of interlinked, user-friendly web pages that display rich descriptive information contributed by universities, research organisations and public sector organisations throughout Australia. While most searchers will seek information about data through web search engines, Research Data Australia is designed to add value by offering many ways of searching.[i]

In order to be a comprehensive portfolio of all data relevant to Australian research, Research Data Australia points to data collections from the public sector. ANDS is currently working with a number of public sector institutions to assist them to make their data more widely available. These include CSIRO, Geosciences Australia and the Australian Bureau of Statistics (as examples).

2. Comments on selected principles

Draft Principle 3 concerns the importance of robust information asset management frameworks; one aspect of this is information quality. ANDS is working with the Australian Bureau of Statistics in relation to its Data Quality Framework, which is currently designed to accommodate statistical data. ANDS is investigating the extension of the Framework to cover the other kinds of data created in the course of research.

Draft Principle 4 concerns the findability of information. ANDS supports the importance of providing high quality metadata in order to make information findable, and the Research Data Australia portal operated by ANDS is designed to harvest such metadata for potential users in the research and innovations sector. Policy coordination between ANDS and the Office of the Information Commissioner could help to “publish” public sector information routinely to the research community. In describing research data collections, ANDS has found the need to go beyond the information and approach of the Australian Government Locator Service (AGLS) metadata standard recommended in Draft Principle 4. We note that AGLS is the subject of revision by the Metadata Community of Interest established by the Australian Bureau of Statistics. ANDS is represented on this group and will work towards improvement of the current standard.

Draft Principle 8 concerns appropriate charging for access. ANDS notes that worldwide, there is a growing trend for such data to be provided free of charge and this is our default position too. ANDS has instigated an independent economic study of the cost and benefits of providing free access to data. This study will focus on organisations that have experience before and after the decision to freely publish some of their data holdings and which are therefore able to provide input to standard treasury (and other economic) modeling. Importantly, this study is focused on the costs and benefits experienced by individual organisations rather than sectors or the country as a whole (which have been the dominant kind of studies in the literature). Anecdotally, we have been told that the benefits (including economic) may be greater than expected by some organisations: we plan to describe and enumerate this with the help of several government organisations.

Draft Principle 9, Clear reuse rights, is supported by ANDS. ANDS seeks to partner with public sector agencies to promote a compatible approach, supported by a coordinated information licensing framework, across the different sectors of government, research and innovation. In this regard, The Government Information Licensing Framework or GILF is of significant interest to ANDS as its policy and license suite seems to align with the requirements of the research commons. It also appears to have existing momentum with some of ANDS’ key stakeholders in the government sector (GA, ABS, BOM). Accordingly, ANDS is keen to promote GILF as the logical basis of a national approach. ANDS is actively pursuing options and opportunities to extend the influence and utility of GILF into the research sector. Researchers need to integrate data from the research and innovations sector with data from government agencies. Therefore a harmonised approach to information licensing (based on the existing GILF) is highly desirable. Noting that our key stakeholders straddle State and Territory Governments, the Commonwealth Government as well as research institutions and the sector more generally, the realisation of GILF will require a national approach and ANDS is keen to progress this in practical terms.

Draft Principle 10, Engaging the community, is of particular interest to ANDS. ANDS recognises that there is significant use of public sector data by the research sector, and is keen therefore to encourage public sector agencies to make more of their data available. Agencies, at the same time, are willing to make data available but are not sure where to start. ANDS proposes to undertake a survey of Australian researchers to determine what public sector data they would like to see made available to help with their research and to provide that information back to the agencies concerned. In a recent article, Rethinking Open Data: Lessons learnt from the Open Data front lines, Nat Torkington suggests that building a user community around public sector data can be of significant benefit to agencies.[ii]His experience has been gained in New Zealand. He finishes the article with a number of suggestions for those making their data openly available for the first time, including “build your project around users”. In this way, the agency can maximize data usage and develop a community which will provide feedback for service improvement.

We thank you for the opportunity to offer this submission.

Attachment 1. Foreshortened list of principles (bold are commented upon in this submission)

1. Open access to information — a default position

2. Effective information governance

3. Robust information asset management frameworks

4. Findable information

5. Sound decision‐making processes

6. Transparent complaints processes

7. Open and accessible formats online

8. Appropriate charging for access

9. Clear reuse rights

10. Engaging the community

[i]Research Data Australia, still in early stages of development, can be viewed at