The UK government recently published two big documents: a framework for its National Data Strategy (NDS) and a report by the UK Government Office for Science (GOS) on the future of citizen data systems around the world.
The government started work on them about two years ago. I provided input to both documents. They have ended up roughly as people expected, given the UK’s particular political context. The ministerial foreword for the NDS says that it is “unashamedly pro-tech”. The GOS report is more nuanced.
The strategy aligns with the government’s need to recover from the Coronavirus pandemic, respond to technological change and establish its future course after leaving the EU. The current UK Government is strongly in favour of using technology and data to help with these challenges, although there are doubts about whether their leadership really gets how to do it.
The strategy describes itself as being about all information stored on computers and, if it is delivered, would impact all sectors of the economy and society with the exception of health and social care (which is due to get its own data strategy), geospatial (which already has its own data strategy), and the police and state surveillance agencies (who have had a strategy for a few years now).
That is a lot of ground to cover and a lot of potential impact.
I have concerns about strategies that stretch that broad, we cannot look at everything through the lens of data and data experts, but given data’s current prominence in government policy circles it was to be expected.
There is an open consultation on the strategy. The first few questions focus on the pillars and missions of the strategy.
To help me with my thinking, and perhaps those of other policy people and technologists, here are some initial thoughts on:
- the need for clearer aims
- the need for a pillar of citizen engagement
- the mission to unlock the value of data
- the international mission
At this point I have deliberately not included thoughts on bias and inclusion, cities, ethics, open data, data protection, human rights or the planned integrated data platform for government.
For those who do not know me I have experience with policy and delivery with the public and private sectors in multiple countries, like to make technology work for people, and choose to remain optimistic that that can happen.
Do read these thoughts with that perspective in mind.
The framework needs to have clearer aims and a pillar of engaged citizens
The Government Office for Science report on the future of citizen data systems recommends that the UK is clear about its aims and encourages the public to be active and engaged. This is an important element to support both the agility and the humanity that will be needed over the coming years of technological change.
Unfortunately this is not something that the framework manages to achieve. This is probably the most significant gap.
Data is not an area where technocracy should rule. There are political decisions to be made about the priorities, winners and losers.
During the last two years it has been great to see more debate about politics and technology including from trade unions and think tanks from across the political spectrum. Their work looks at data through different lenses than the usual ones of engineering, protection and innovation. But the strategy is not clear on the political choices it is making.
The document has a vague set of opportunities and uses terms that it does not clearly define such as “responsible innovation” “progressive values”, “UK values” and “pro-growth data regime”.
The ministerial foreword says that we need to ask “fundamental questions” about data, but the document does not clearly set out what these questions are, what tradeoffs exist, how the government intends them to be answered, or who by.
It says that the government “seeks to maintain the high watermark of data use set during the pandemic”. While there has been lots of good use of data in the response to the pandemic I suspect most citizens know that the evidence of it all being good is mixed at best. Being realistic about what was done during the pandemic might help build some of the trust that will be needed to deliver the strategy.
Overall the report is nearly 30,000 words long. It is better written and structured than most policy papers, but still a long way from being something that citizens can engage with.
As an expert I can make a reasonable stab at engaging with the framework, but as a citizen I would not be sure what it meant for me, my family, friends, work colleagues, a new business idea or my latest idea to help my community.
Rachel Coldicutt has done a great job trying to make the consultation relevant to the social sector, but this is also a challenge for other sectors and will be an ongoing task beyond the consultation itself.
Having clear aims and recognising that citizen engagement is a pillar of effective data use would make it easier to build both into the missions and ongoing delivery of the strategy.
You cannot unlock the value of data with a national framework to increase access to it
There are many predictions about how much data will be generated over the coming years and how much economic value and jobs this could create. The NDS repeats some of these in the description of its first mission to unlock the value of data.
This mission then focuses on a national policy framework for increasing access to data. This will prove to be both insufficient and too broad reaching. It risks reducing value and causing harm.
We need a more contextual approach that helps people, organisations, places and sectors work out if or how to use data to help them deliver their priorities.
Some examples from the worlds of postal addresses, finance, health and education.
Geospatial data, such as that held by the Ordnance Survey, OpenStreetMap and Google, is widely recognised as foundational data that can unlock value in most countries. It was a topic of discussion at the launch of the UK’s government data portal in 2010.
The 2013 Shakespeare Review for the UK government recommended a national data strategy that would, amongst other things, increase access to data held by government trading funds, such as Ordnance Survey. The 2017 Conservative Manifesto contained a commitment to open up geospatial data.
The 2019 UK geospatial strategy failed to follow through on that commitment even for one of the simplest datasets, postal addresses, despite several previous attempts that demonstrated that this was something that only the government could do.
In short even though the necessary policy commitments for increasing access to geospatial data were in place at several points over the years, there has been an inability to deliver on those commitments.
Government could make a stronger intervention than a policy framework, for example by creating a legislative framework for access to data as myself and others once suggested, but I now expect that this will turn out to be both insufficient and too broad.
The open banking standard was designed to increase access to consumer data held by the major retail banks with the goal of increasing competition. After initial attempts at making it a voluntary initiative, the Competition and Markets Authority mandated compliance by the 9 largest banks.
It has had some successes but, to be as effective as it was, it needed to be designed within its particular context and with a broad range of expertise. As initiatives like open banking spread to other sectors the UK will need to design those initiatives in their context too.
Meanwhile the UK learnt that open banking did not, as originally planned, necessarily increase competition in the sector. It helped create a market for new fintech services, but competition for existing services came from new entrants like Monzo, Revolut and Starling. These organisations used data to help build their services, but access to existing data has not been the key to their success.
Finally, it is important to be aware that broad mechanisms for increasing access to data can reduce value and cause harm.
The most wide reaching example is the use of data by the online advertising industry, but there are many other examples which affect people in different ways such as the sharing of NHS and schools data with the UK’s immigration services, the Metropolitan Police Gangs Matrix, and anti-terrorism activities such as the Prevent programme. All of these activities rely on government policies for access to data.
A broad national framework could lead to more cases like these, for example would Islington council have been obliged to share data about people who sleep rough with the Home Office so that it can be used to enforce immigration policies? And, if so, how would this have impacted the services that Islington Council provides? What about a council in Scotland or Northern Ireland?
The unease that this data use creates in citizens leads to the concerns seen in Living with Data’s review of the public’s understanding of data practices.
Those concerns can lead to citizens and organisations that hold data but do not want it to be accessed and reused to resist in ways that make the data of increasingly poor quality, biased or misleading.
This does not just hinder the use of data in new services. It can harm data holders, existing services and the people that use them.
Rather than a national policy framework for increasing access to data, any mission to unlock value in data will need a more contextual focus that recognises data is just one tool amongst many others and that supports people, places, sectors and organisations to learn how data might, or might not, help with the problems they actually have.
The mission to champion the international flow of data conflicts with other government policies
The strategy has a mission for the UK to champion the international flow of data. It says:
“the UK now has a unique opportunity – as a world leader in digital and as a champion of free trade and the rules-based international system – to be a force for good in the world, shaping global thinking and promoting the benefits that data can deliver while managing malign influences“
The strategy does not recognise how this mission conflicts with other government policies and actions.
The UK has long regarded itself as one of the leading countries in technology, digital and data but in my own international work over the last few years most observers say that the UK has lost any edge it had to European countries, the USA and China. Perhaps this is due to the government’s focus on Brexit, or maybe it was never the leader that some people thought and this has slowly become more visible.
The GOS report on the future of citizen data systems shows quite how much effort other countries are spending to support innovation and to create new global standards for regulation. As Benedict Evans recently said “regulation is an export industry, and a competitive industry“. It is hard to see how the UK can compete at the necessary scale.
The UK is at risk of failing to secure a deal for free trade in data with the EU to replicate the one that it already has. There is “a lack of progress on …. protection of personal data” in the current trade negotiations. This will cause significant disruption for citizens, businesses and governments.
Meanwhile outside the world of data the UK government illegally suspended Parliament last year; is being criticised by many observers for the planned Internal Markets Bill which may breach international law; and has reportedly gone as far as exploring a floating border between the UK and France rather than uphold moral and legal obligations to treat humans compassionately and fairly when they seek asylum.
These are actions that I did not foresee when optimistically imagining how the UK could set its course after Brexit. I struggle to see the current actions as those of a nation that is a force for good in the world and, from my own experience, I can see how it will affect any work on international data flows by the UK government or its representatives.
Until the government changes these other policies then much of the effort that seems planned under this mission is likely to be wasted.
I would suggest that the UK needs to be in more of a listening mode internationally, at least until it has managed to get its footing again after both the pandemic and Brexit.
As I said at the beginning the UK National Data Strategy is large and broad and these are just some initial thoughts to help me work out if I can help push the NDS closer towards being useful in making data work for people. At the moment I fear that the NDS is too broad and too optimistic in what central government can achieve with data. That risks more wasted years for the UK.
Other thoughtful people are working on responses too. Some of those will be to the consultation, others to the activities that the strategy describes. My thoughts will hopefully help those other technology and policy people in their own work.
As usual I do apologise that these thoughts are a bit long-winded, I will offer my usual excuse that if I had more time I would write my thoughts more concisely.