ODI Leeds' response to the National Data Strategy

The National Data Strategy has been on the tip of tongues since June 2019, with a multitude of reactions and responses from organisations far and wide, including the Open Data Institute, the Open Knowledge Foundation, Nesta, Open Contracting Partnership, Full Fact, mySociety, the Royal Statistical Society, plus many many more. After a series of workshops and engagement events, the strategy became available to read on 9 September 2020 and immediately went into a period of open consultation asking for responses from pretty much anyone.

Given the extraordinary circumstances of 2020, and the inequalities that have entered the spotlight with devastating impact, the National Data Strategy needs to be radically innovative and forward thinking. It needs a much greater consideration of data 'sovereignty' - the ownership of data, the right to collect data, and the right to withdraw consent to use data that affects citizens, organisations, departments within government, even worldwide countries. Below is the overview of an ODI Leeds submission to the consultation, crafted by Tom Forth, Paul Connell, and others whilst also working closely with our amazing sponsor network.

Why should local government data on waste collection interact with a franchised train companys timetable? How could any strategy relevant to both hope to provide any useful detail or guidance to either?

Thinking through those two questions is why it is not obvious that the UK should have a national data strategy.

This UK National Data Strategy is an important first argument for one. Its tone is a welcome balance of positivity, optimism, and caution. It recognises the importance of data across business, society, and government to increase productivity, improve lives, and strengthen our country. It forms a strong basis for the wider discussion that it invites throughout.

The case studies are strong. Transport for Londons excellence in the collection, use, and safe release of data is world leading. It is the result of decades of hard, controversial, and innovative work. Much of this innovation was enabled by local sovereignty and associated opt outs from national standards and laws.

The NHS health records are unrivalled internationally in their coverage of a large and diverse population. They are the foundation for significant scientific and industrial strengths that other countries will be unable to emulate for decades, if ever. It has also enjoyed significant autonomy from direct central government control. It enjoys public trust as a result.

The ONS and the ONS Data Science Campus have proven themselves excellent at innovating and interacting with people, governments, businesses, and institutions right across the UK. Again, much of this achievement is founded in their distance from government and their exemption from central government standards and control.

The first major concern in light of these three examples is that the strategy does not consider sovereignty. Specifically it seems to advocate the central ownership of (and hints at the central imposition of) data standards, ways of working, and interoperability requirements. The potential upsides as measured by efficiencies of scale and reduced duplication of effort are obvious and large. The costs in terms of lost resilience, less opportunity for innovation, costs of complying with rules, and greater distance between government and the people do not seem to be considered.

These costs were obvious before 2020. Covid-19 has made them unmissable.

Beyond the Covid-19 response, this trade-off is widely discussed in the devolved nations and in the regions of England. We have already mentioned the success of TfL with data, a success which was enabled by local sovereignty and exemption from national standards and laws. The clearest manifestation of this opt out is that Londons Oyster card does not use the ITSO national standard for public transport smartcards as used elsewhere. This decision and its ability to move more quickly contributed to its success.

The second major concern is that the strategy underplays the challenges facing the UK as a result of the UK leaving the EU. We should not underestimate how Brexit will impact the data economy, the way we work, and all parts of the country. The UK government will work most effectively with partners throughout our country and the world if it is seen to understand the challenges we face.

The third major concern is that the strategy does not seem to identify a critical weakness in the UKs national data infrastructure. Specifically that the UK lacks an open postal address system, leaving both business and government services behind other countries.

Our full response goes into much more detail and answers the specific questions of the consultation, but there are clear themes running throughout. Decentralisation of data will be crucial, allowing for faster innovation at local levels and greater productivity without interference and other barriers. As COVID-19 has highlighted a number of issues and challenges for the data community, this could be an opportunity for a strategy that is built for a nation, not a single place.

You can read the ODI Leeds submission in full via this Google Doc and the consultation is accepting responses until the end of 2 Dec.