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New Voluntary Code: Guidance for Sharing Data Between Organisations

Published on
8 Jan 2016
Written by
Alison Holt FIITP, M.Inst.D, CITP

Many organisations are coming up with their own internal policy and guidelines for data sharing. However, for data sharing between organisations to be straight forward, there needs to a common understanding of basic policy and practice. During her time as an OII Visiting Associate, Alison Holt developed a pragmatic solution in the form of a Voluntary Code, anchored in the developing ISO standards for the Governance of Data. She discusses the voluntary code, and the need to provide urgent advice to organisations struggling with policy for sharing data.


Image: “Five Data Privacy Principles from Mozilla (Put on a museum wall) 2014” by Ann Wuyts (Flickr).

Collecting, storing and distributing digital data is significantly easier and cheaper now than ever before, in line with predictions from Moore, Kryder and Gilder. Organisations are incentivised to collect large volumes of data with the hope of unleashing new business opportunities or maybe even new businesses. Consider the likes of uber, Netflix, and Airbnb and the other data mongers who have built services based solely on digital assets.

The use of this new abundant data will continue to disrupt traditional business models for years to come, and there is no doubt that these large data volumes can provide value. However, they also bring associated risks (such as unplanned disclosure and hacks) and they come with constraints (for example in the form of privacy or data protection legislation). Hardly a week goes by without a data breach hitting the headlines. Even if your telecommunications provider didn’t inadvertently share your bank account and sort code with hackers, and your child wasn’t one of the hundreds of thousands of children whose birthdays, names, and photos were exposed by a smart toy company, you might still be wondering exactly how your data is being looked after by the banks, schools, clinics, utility companies, local authorities and government departments that are so quick to collect your digital details.

Then there are the companies who have invited you to sign away the rights to your data and possibly your privacy too – the ones that ask you to sign the Terms and Conditions for access to a particular service (such as a music or online shopping service) or have asked you for access to your photos. And possibly you are one of the “worried well” who wear or carry a device that collects your health data and sends it back to storage in a faraway country, for analysis.

So unless you live in a lead-lined concrete bunker without any access to internet connected devices, and you don’t have the need to pass by webcams or sensors, or use public transport or public services; then your data is being collected and shared. And for the majority of the time, you benefit from this enormously. The bus stop tells you exactly when the next bus is coming, you have easy access to services and entertainment fitted very well to your needs, and you can do most of your bank and utility transactions online in the peace and quiet of your own home. Beyond you as an individual, there are organisations “out there” sharing your data to provide you better healthcare, education, smarter city services and secure and efficient financial services, and generally matching the demand for services with the people needing them.

So we most likely all have data that is being shared and it is generally in our interest to share it, but how can we trust the organisations responsible for sharing our data? As an organisation, how can I know that my partner and supplier organisations are taking care of my client and product information?

Organisations taking these issues seriously are coming up with their own internal policy and guidelines. However, for data sharing between organisations to be straight forward, there needs to a common understanding of basic policy and practice. During my time as a visiting associate at the Oxford Internet Institute, University of Oxford, I have developed a pragmatic solution in the form of a Voluntary Code. The Code has been produced using the guidelines for voluntary code development produced by the Office of Community Affairs, Industry Canada. More importantly, the Code is anchored in the developing ISO standards for the Governance of Data (the 38505 series). These standards apply the governance principles and model from the 38500 standard and introduce the concept of a data accountability map, highlighting six focus areas for a governing body to apply governance. The early stage standard suggests considering the aspects of Value, Risk and Constraint for each area, to determine what practice and policy should be applied to maximise the value from organisational data, whilst applying constraints as set by legislation and local policy, and minimising risk.

I am Head of the New Zealand delegation to the ISO group developing IT Service Management and IT Governance standards, SC40, and am leading the development of the 38505 series of Governance of Data standards, working with a talented editorial team of industry and standards experts from Australia, China and the Netherlands. I am confident that the robust ISO consensus-led process involving subject matter experts from around the world, will result in the publication of best practice guidance for the governance of data, presented in a format that will have relevance and acceptance internationally.

In the meantime, however, I see a need to provide urgent advice to organisations struggling with policy for sharing data. I have used my time at Oxford to interview policy, ethics, smart city, open data, health informatics, education, cyber security and social science experts and users, owners and curators of large data sets, and have come up with a “Voluntary Code for Data Sharing”. The Code takes three areas from the data accountability map in the developing ISO standard 38505-1; namely Collect, Store, Distribute, and applies the aspects of Value, Risk and Constraint to provide seven maxims for sharing data. To assist with adoption and compliance, the Code provides references to best practice and examples. As the ISO standards for the Governance of Data develop, the Code will be updated. New examples of good practice will be added as they come to light.

[A permanent home for the voluntary code is currently being organised; please email me in the meantime if you are interested in it:]

The Code is deliberately short and succinct, but it does provide links for those who need to read more to understand the underpinning practices and standards, and those tasked with implementing organisational data policy and practice. It cannot guarantee good outcomes. With new security threats arising daily, nobody can fully guarantee the safety of your information. However, if you deal with an organisation that is compliant with the Voluntary Code, then at least you can have assurance that the organisation has at least considered how it is using your data now and how it might want to reuse your data in the future, how and where your data will be stored, and then finally how your data will be distributed or discarded. And that’s a good start!

alison_holtAlison Holt was an OII Academic Visitor in late 2015. She is an internationally acclaimed expert in the Governance of Information Technology and Data, heading up the New Zealand delegations to the international standards committees for IT Governance and Service Management (SC40) and Software and Systems Engineering (SC7). The British Computer Society published Alison’s first book on the Governance of IT in 2013.

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