Friday, 31 August 2012

Data Sharing in the Public Sector

The debate that has been raging for the last 5 years in UK local government has largely centred around setting up the one 'Golden Record' for citizens and usually surfaces at the time a new CRM system is being proposed. It is not unusual for a local authority to have more than 50 different systems containing information about a citizen.

In a recent assignment I was involved with an authority admitted it had 26 different systems that recorded information about the same group of citizens.This is not uncommon: What isn't so common is a clear understanding of what can and can't be done under current UK Law. There are still service managers that swear blind that they can't 'share' Council Tax data despite the Information Commissioners guidance in 2007 that said they can.
I am often asked by council's to 'rule' on what they can and can't share and usually there are a number of different answers.
  • Can I share Council Tax information? - Well that's a YES
  • Can I 'share' Electoral Roll information? - That could be a maybe. It's a maybe because share and processing information are two different things in UK law (and most elsewhere too.)
  • And how can some Councils 'share' data to, for example, validate Single Person Discounts (and in some cases outsource his process to a third party

Well it all comes down to 4 main issues in my opinion:
  • The Law - Does the council have the specific legal right to share this data. And because local authorities have many statutory powers, there are lots of laws that govern these powers so crucially examining the right piece of legislation is key.

  • The purpose the shared data is going to be used for - If this is a statutory purpose then its likely to be OK, but getting a solid legal opinion on this is vital. Some public sector organisations are using the ICO's Privacy Impact Assessment Tool (PIA) to guide them through this process instead of 'sleepwalking' into a disaster. Remember the ICO is not against data sharing and isn't trying to catch councils out, as long as they have done the due diligence on the impact on citizens of what they are about to do. Some councils have even built the PIA into their project management methodology alongside environmental impact assessment and benefits realisation.

  • Is consent needed - again the ICO sets out clearly when consent is and is not required.

  • And the real challenge - changing the culture of the organisation from 'we can't share because' to 'how can we share'. And this in my opinion is at the heart of the barriers that get thrown up every time a council is trying to 'do things better'

This cultural barrier has been built over many years and reinforced by the many professionalisms that have been the mainstay of public services. Often people will train for 5 years to become a planner, a benefits assessor, or an environmental officer and they don't take too kindly to the 'new way of working' that sees all the expertise move into the Customer Service Centre were anyone with a bit of training and a good set of call guides can answer 80% of the queries the public has. (Although I have some sympathy as I have seen quite a few of these Transformation Projects go horribly wrong.
So getting all of the stakeholders to agree what can and can't be shared at the start of project is to my mind the key ingredient. We all know the technology can do whatever we want it to do so surely it must be 'the people'?

One last example that illustrates this, and highlight the benefits that could be gained if a different approach is taken. One local authority client had 9,000 unpaid Penalty Charge Notices (PCN's) for on street parking offences where the documents had been returned 'Gone Away'. These documents are sent to the address the DVLA has for the registered keeper. Of those 9,000 cases a third of the people still lived in the same council area, but just hadn't told DVLA, and 1,000 were tenants of the council. So the housing department knew where they were but the parking department didn't. Just collecting these 3,000 PCNs from people who still lived in the council area brought in an additional  £250,000.

There are some good places to continue this discussion. You can try my blog at http://e-mpirical.blogspot.co.uk/ or visit our website at www.e-mpirical.com  Also try the Data Connects Linkedin group