Open North submitted its comment this morning, which I expect will show up on their page shortly. Here’s our comment:
The Action Plan’s commitments are significant and ambitious. However, it is important to consider not only what is in the plan, but what was left out. In a first section, we (Open North) recommend new commitments. In a second section, we recommend edits to existing commitments.
1. New Commitments
1.1. Open Communication
Open data and open science benefit from users having access to the people responsible for the data or research: to ask questions, confirm interpretations, discuss applications, report errors, find related work, or explore ways to add value to the data or research, for example. Open communication is foundational to open data and open science; it removes barriers to the reuse of published government data and research, much like an open data licence. Encouraging open communication supports every commitment. This human communication benefits from communications policies that support open and timely communication between data owners, scientists and the public. In tandem with the digital and pedagogical solutions discussed under other commitments, open communication helps maximize the impact of the Government’s open government initiatives.
[Proposed commitment:] “The Government of Canada will issue a government-wide directive on open communication to establish that data owners and scientists can speak freely with the public about their data and research, subject to applicable restrictions related to privacy, confidentiality, and security.“
1.2. Data Availability
Open data represents a “tremendous commercial opportunity,” as cited in the Action Plan. Businesses built on open data strongly rely on its continued availability; in cases where open data is mission critical, its sudden unavailability can cause the failure of business operations. Similarly, other levels of government, not-for-profit organizations, and charities rely on open data to plan their activities and measure their impact. Uncertainty about the continued availability of open data is a barrier to the commercialization and use of open data. In order to reduce uncertainty and promote the long-term viability of activities built on open data, the Government should adopt strategies for communicating the longevity of datasets and for handling the cancellation of data publication or data collection activities to minimize the impact on the operations of data users.
[Proposed commitment:] “The Government of Canada will complete public consultations with citizens, civil society and the private sector on how to ensure that open data of continuing value remains accessible and usable and continues to be collected.“
1.3. Open Contracting Global Principles
Under its Open Contracting commitment, the Government of Canada expresses support for the Open Contracting Partnership and its Open Contracting Global Principles. The Government should go one step further and endorse these principles, which open data leaders like the United Kingdom have already done.
[Proposed commitment:] “The Government of Canada will endorse the Open Contracting Global Principles.”
2. Existing Commitments
2.1. Implement Directive on Open Government
The Action Plan explains that departments and agencies will “be required to develop inventories of their data and information." These inventories should be made available to the public, thereby allowing the public to participate in prioritizing datasets for release, as has been done in the United States through Project Open Data and the United Kingdom through data.gov.uk. [Proposed edit:] Replace “Establishing and maintaining inventories of data and information holdings” with “Establishing, maintaining, and making available to the public inventories of data and information holdings”.
While we applaud the establishment of the Canadian Open Data Exchange to promote the commercialization of open data, the Directive on Open Government, on the other hand, should not be limited to maximizing the release of data and information “of business value.” Throughout the OGP’s documentation, no value – whether business, social, democratic or scientific – takes precedence over any other. The directive should therefore not privilege business value.
[Proposed edit:] Either replace “of business value” with “of business or social value” or delete the words “of business value”.
2.2. Mandatory Reporting on Extractives
We look forward to the opportunity to provide additional input during the public consultations. At this time, we will emphasize the importance of providing single-window online access to the mandatory reporting on extractives. Just as the Government has made all completed ATI requests available through a single search interface, and just as it plans to provide single-window access to budgets, expenditures, and contracting data, the government should do the same with reporting by companies in the mining, oil, and gas sectors. The Canada Revenue Agency is a world leader in providing single-window online access to standardized data on charitable organizations. Natural Resources Canada should follow its leads in providing single-window online access to the mandatory reporting on extractives.
[Proposed edit:] Add a new deliverable, “Provide single-window online access for searching and interacting with information on payments disclosed under the new legislation.”
We believe the above recommendations will make the Action Plan stronger and will more firmly establish Canada as a world leader in open government and open data.