Professor John McMillan AO Australian Information Commissioner Office of the Australian Information Commissioner Level 3, 25 National Circuit FORREST ACT 2603
Dear Professor McMillan,
Submission on OAIC Issues Paper
On behalf of the Department of Finance and Deregulation, I submit the following response to the OAIC’s Issues Paper 1: Towards an Australian Government Information Policy.
Yours sincerely
John Sheridan
Acting Deputy Secretary Australian Government Information Management Office Department of Finance and Deregulation
18 March 2011
CC Mr David Tune, Secretary, Department of Finance and Deregulation
Ms Jenet Connell, Deputy Secretary (Chief Operating Officer Group), Department of Finance and Deregulation
Issues Paper 1: Towards an Australian Government Information Policy
Submission of the Department of Finance and Deregulation
The Department of Finance and Deregulation (Finance):
recognises the value of information; and
supports the development of a comprehensive Australian Government Information Policy.
In this submission, Finance will provide both policy alignment comments and specific editorial comments on Issues Paper 1 as released.
Policy Alignment
Finance, through the Australian Government Information Management Office (AGIMO), provides advice and services to achieve more effective and efficient use of information and communication technology (ICT) by the Australian Government. These include supporting the Government’s ICT procurement reforms, improving the quality of ICT management in the APS, and enhancing the capacity of the APS workforce to deliver ICT programs. As the lead agency for implementing the Government 2.0 agenda, AGIMO supports the Government in being open, transparent and collaborative, and making online Government services more accessible. AGIMO also works with governments and other bodies at all levels to develop and maintain Australia's position as a world leader in e-government.
Finance proposes that, in the development of an Australian Government Information Policy (AGIP), the Information Commissioner consider:
information as both a Government asset and an agency asset
the underlying systems that manage and support/maintain public information
accountability and governance arrangements for:
the creation of information
the interoperability of systems that manage and support information;
the accessibility of operational information
the quality and integrity of information; and
the capacity to share information
the description of information in the context of Government Lines of Business[1];
the suitability of data for matching and mash-ups
the balance between privacy and convenience when identifying individuals and businesses across agencies
inclusion of a client experience scenario to identify what will be different from the client perspective because of the proposed policy; and
the ability of Government to understand and implement the policy without needing to make major capital investments or disruptive changes to business processes
Principles-based approach
AGIMO takes a principles-based approach in its information policies and frameworks, e.g. the National Government Information Sharing Strategy (NGISS)[2] and the Australian Government Architecture framework (AGA)[3]. AGIMO recommends using existing agreed principles in strategic information management policies where appropriate.
Finance believes that the principles in an AGIP and in the Government Enterprise Architecture being developed by AGIMO should align. AGIMO would welcome working with the OAIC to ensure consistency between related policies and frameworks.
Information creation and the impact of ICT development
Issues Paper 1 has a strong focus on the use and availability of information. Finance considers that it is also important to account for the creation of information and the systems that gather, store and process that information.
Decisions and actions taken at the time of information creation affect the ongoing usability and accessibility of that information. Information created without attention to standards or without an architecture that supports agility and availability will be difficult and expensive to use widely and innovatively.
In the AGA framework, Finance has developed a comprehensive and agreed listing of government services for use in descriptions of ICT activities. Finance proposes that the Information Commissioner consider using this list of services where it would add value to the AGIP.
The Government 2.0 Agenda
The work of Finance on the Government 2.0 Agenda includes significant focus on public sector information and how it can be made more readily available to the public for viewing and re-use. This goal is being pursued through both policy and service projects, including:
Publishing advice: AGIMO has begun discussion with OAIC’s IPS Project team on how advice can be provided to agencies that covers not just what should be published, but how it can best be published Finance proposes that this engagement continue with a goal of delivering advice that can be integrated into an AGIP
Data.gov.au and metadata: data.gov.au will make use of a range of metadata schemas/standards to make data sets easier to locate Finance proposes that an AGIP should recognise that the Australian Government Locator Service (AGLS) is not the only important metadata schema for government information – others to consider may include ANZLIC[4] for spatial data and SDMX[5] for statistical data. Finance further proposes that an AGIP be used to encourage agencies to publish datasets on data.gov.au
Editorial Comment
Pages 25 and 46 refer to the COAG Online and Communications Council, which will no longer exist under the proposed reforms of the Ministerial Council System[6].
Draft Principle 7 on page 57 refers to “Open and accessible formats online”. Finance recommends identifying the endorsed standard – the Web Content Accessibility Guidelines – as version 2.0 to limit the risk of confusion with the superseded version (1.0). Version 2.0 was, in fact, endorsed by the Australian Government in November 2009, but not announced as endorsed until February 2010. The first sentence of this point also seeks information in human-readable formats, but this appears to be an error, as it is later recommended as machine-readable formats. Finally, Finance suggests that ‘open’ formats are covered by Principle 1 and should not be mentioned here separately. Finance proposes this alternative wording:
7. Accessible formats online
The economic and social value of public sector information is enhanced when it is published online in formats that are machine-readable and conformant to the Web Content Accessibility Guidelines version 2 (WCAG 2.0), endorsed by the Australian Government in November 2009. Information should, so far as possible, be published in open and standards-based formats.
Further Engagement
AGIMO would be happy to further engage with OAIC as its work on the AGIP progresses. Discussions between OAIC and our Governance & Policy Branch would be of particular benefit to both agencies. OAIC is invited to contact the Assistant Secretary, Mr Scott Wallace, directly on (02) 6215 1581 or Scott.Wallace@finance.gov.au.
[1] Government Lines of Business (LoBs) represent the categories of government services for citizens, and the internal operations performed by government in providing services for citizens, independent of the agencies that perform them.
