02.01.2010
data sharing, Open Government, privacy, Processes, security, transparency
Following up on my comments and thoughts about the Open Government Directive and Data.gov effort, i just posted five ideas on the “Evolving Data.gov with You“ website and thought i would cross-post them on my blog as well…enjoy! r/Chuck
1. Funding – Data.gov cannot be another unfunded federal mandate
Federal agencies are already trying their best to respond to a stream of unfunded mandates. Requiring federal agencies to a) expose their raw data as a service and b) collect, analyze, and respond to public comments requires resources. The requirement to make data accessible to (through) Data.gov should be formally established as a component of one of the Federal strategic planning and performance management frameworks (GPRA, OMB PART, PMA) and each agency should be funded (resourced) to help ensure agency commitment towards the Data.gov effort. Without direct linkage to a planning framework and allocation of dedicated resources, success of Data.gov will vary considerably across the federal government.
2. Strategy – Revise CONOP to address the value to American citizens
As currently written, the CONOP only addresses internal activities (means) and doesn’t identify the outcomes (ends) that would result from successful implementation of Data.gov. In paragraph 1 the CONOP states “Data.gov is a flagship Administration initiative intended to allow the public to easily find, access, understand, and use data that are generated by the Federal government.”, yet there is no discussion about “what data” the “public” wants or needs to know about.
The examples given in the document are anecdotal at best and (in my opinion) do not reflect what the average citizen will want to see–all apologies to Aneesh Chopra and Vivek Kundra, but I do not believe (as they spoke in the December 8th webcast) that citizens really care much about things like average airline delay times, visa application wait times, or who visited the Whitehouse yesterday.
In paragraph 1.3 the CONOP states “An important value proposition of Data.gov is that it allows members of the public to leverage Federal data for robust discovery of information, knowledge and innovation,” yet these terms are not defined–what are they to mean to the average citizen (public)? I would suggest the Data.gov effort begin with a dialogue of the ‘public’ they envision using the data feeds on Data.gov; a few questions I would recommend they ask include:
- What issues about federal agency performance is important to them?
- What specific questions do they have about those issues?
- In what format(s) would they like to see the data?
I would also suggest stratifying the “public” into the different categories of potential users, for example:
- General taxpayer public, non-government employee
- Government employee seeking data to do their job
- Government agency with oversight responsibility
- Commercial/non-profit organization providing voluntary oversight
- Press, news media, blogs, and mash-ups using data to generate ‘buzz’
3. Key Partnerships – Engage Congress to participate in Data.gov
To some, Data.gov can be viewed as an end-run around the many congressional committees who have official responsibility for oversight of federal agency performance. Aside from general concepts of government transparency, Data.gov could (should) be a very valuable resource to our legislators.
Towards that end, I recommend that Data.gov open a dialogue with Congress to help ensure that Data.gov addresses the data needs of these oversight committees so that Senators and Congressmen alike can make better informed decisions that ultimately affect agency responsibilities, staffing, performance expectations, and funding.
4. Data Quality – Need process for assuring ‘good data’ on Data.gov
On Page 9 of the CONOP, the example of Forbes’ use of Federal data to develop the list of “America’s Safest Cities” brings to light a significant risk associated with providing ‘raw data’ for public consumption. As you are aware, much of the crime data used for that survey is drawn from the Uniformed Crime Reporting effort of the FBI.
As self-reported on the “Crime in the United States” website, “Figures used in this Report are submitted voluntarily by law enforcement agencies throughout the country. Individuals using these tabulations are cautioned against drawing conclusions by making direct comparisons between cities. Comparisons lead to simplistic and/or incomplete analyses that often create misleading perceptions adversely affecting communities and their residents.”
Because Data.gov seeks to make raw data available to a broad set of potential users; How will Data.gov address the issue of data quality within the feeds provided through Data.gov? Currently, federal agency Annual Performance Reports required under the Government Performance and Results Act (GPRA) of 1993 require some assurance of data accuracy of the data reported; will there be a similar process for federal agency data made accessible through Data.gov? If not, what measures will be put in-place to ensure that conclusions drawn from the Data.gov data sources reflect the risks associated with ‘raw’ data? And, how will we know that the data made available through Data.gov is accurate and up-to-date?
5. Measuring success of Data.gov – a suggested (simple) framework
The OMB Open Government Directive published on December 8, 2009 includes what are (in my opinion) some undefined terms and very unrealistic expectations and deadlines for federal agency compliance with the directive. It also did not include any method for assessing progress towards the spirit and intent of the stated objectives.
I would like to offer a simple framework that the Data.gov effort can use to work (collaboratively) with federal agencies to help achieve the objectives laid out in the directive. The framework includes the following five questions:
- Are we are clear about the performance questions that we want to answer with data to be made available from each of the contributing federal agencies?
- Have we identified the availability of the desired data and have we appropriately addressed security and privacy risks or concerns related to making that data available through Data.gov?
- Do we understand the burden (level of effort) required to make each of the desired data streams available through Data.gov and is the funding available (either internally or externally) to make the effort a success?
- Do we understand how the various data consumer groups (the ‘public’) will want to see or access the data and does the infrastructure exist to make the data available in the desired format?
- Do we (Data.gov and the federal agency involved) have a documented and agreed to strategy that prepares us to digest and respond to public feedback, ideas for innovation, etc., received as a result of making data available through Data.gov?
I would recommend this framework be included in the next version of the Data.gov CONOP so as to provide a way for everyone involved to a) measure progress towards the objectives of the OMB directive and b) provide a tool for facilitating the dialogue with federal agencies and Congress that will be required to make Data.gov a success.
29.12.2009
Analysis, Data, data sharing, Open Government, transparency
I just finished commenting on Data.gov on the NIEM LinkedIn Group and thought I would share what I wrote here on my blog.
I just finished watching a rerun episode of Tough Love on VH1 and I know some of you will think this is a bit odd, but the show led me to some thoughts about how to give the Data.gov project some focus and priority.
You’re probably wondering what Data.gov has to do with eight beautiful women looking for marriage and long-lasting love, but believe it or not, the show and Data.gov have a lot in common.
In this particular episode of the show, the “boot camp” director was focusing on communication skills. He made it very clear to the ladies that communication is very important in making a good first impression with a would be suitor. In the show he counseled the ladies that if they wanted to make a good impression, the ladies would need to:
- Listen carefully to what their date is telling them about what’s important to them;
- Make the conversation about “them” on first contact and avoid bragging about yourself; and
- Resist the urge to reveal too much information about their own respective private lives.
While I will avoid speaking to the validity of this counsel as it applies to love, I would like to suggest that these three rules are also quite relevant in our efforts to have a more transparent, open and collaborative government.
Along these lines, I offer the following three suggestions for Data.gov’s first (transparent, open and collaborative) date with America:
- Ask the public (and Congress) what they specifically want to see on Data.gov and the forthcoming dashboard; all apologies to Aneesh Chopra and Vivek Kundra, but I do not believe (as they spoke in the December 8th webcast) that citizens really care much about things like average airline delay times, visa application wait times, or who visited the Whitehouse yesterday. I particualry suggest they work with Congressional Oversight Committees to make Data.gov a tool that Congress can (and will) use.
- Make Data.gov about demonstrating the good things that Federal agencies do that directly impact the general public. It’s no surprise that most agencies do a poor job of explaining to citizens what they do. I suggest reviving the OMB Performance Assessment Rating Tool (PART) Program (which appears to have died on the vine with the new administration) and use the performance measures in the Program Results/Accountability section to better communicate the relevant value these agencies deliver to citizens.
- Focus Data.gov data sources and the desire for openness on the critical few measures and metrics that matter to the public. Avoid the urge to just “get the data posted” – not many people will care about how many kilowatt hours of hydroelectric power the Bureau of Reclamation is counting, how many FOIA requests the Department of Justice received, or the Toxic Release Inventory for the Mariana Islands. Information sharing is most successful when it is directly relevant with the person (or agency)with whom you are sharing.
I’ll let you know if the next episode is as enlightening as this was. 😉
r/Chuck
28.12.2009
Analysis, Budget, Data, Information sharing, transparency
I just took a look at the OMB Data.Gov Concept of Operations, and while I don’t want to sound like a party pooper, but I am very concerned about the Data.gov effort. We appear to be moving full speed ahead with the technical aspect of making data available on data.gov without really thinking through the policy, politics, resource, and other non-technical aspects of the project that could really hurt what could be a very valuable resource.
A few concerns I have include:
1. None of the Data.gov principles in the CONOP address the “real-world effects” we hope to achieve through data.gov–from an operational programs perspective. All seven principles in the CONOP address “internal” activities (means). We need to address success in terms of what citizens will realize through the Data.gov effort.
2. The entire Data.gov effort appears to be driven out of context from any government performance planning and evaluation process. Shouldn’t the need for data transparency be driven by specific strategic management questions? Where are the links to the President’s Management Agenda? Agency strategic plans?
3. There are more than 200 Congressional Committees with varying degrees of oversight of over a similar number of agencies in the Executive Branch. How will Data.gov impact Congress’ efforts to monitor (oversee) agency performance? What will happen when there is a disparity between a) what an agency says it’s doing, b) what oversight committee(s) say they are doing, and c) how the public views that agency’s performance based on data posted on Data.gov?
4. Transparency, Participation and Collaboration (TPC) are the buzz words of the month, but what does that really mean? The opening sentence of the CONOP states “Data.gov is a flagship Administration initiative intended to allow the public to easily find, access, understand, and use data that are generated by the Federal government.” Do we really expect the general public to access and analyze the data at Data.gov? If so, do we really understand how the public will want to see/access the information? More importantly, are we (agencies) fully prepared to digest and respond to received public feedback?
5. Who will pay the agencies to support data transparency? Do we really understand the burden involved in achieving open government? The last thing federal agencies need is another unfunded mandate.
6. Finally, how do we know the data that’s made accessible via Data.gov is good data (correct)? The GPRA required OIG review and certification of agency data published in annual performance reports. What can we expect in the way of quality from near-real-time access to agency performance data? Will we require the same data quality process for data feeds posted on Data.gov? Will agencies be funded to do it right?
I provide similar commentary on this issue and an analysis of the recent Executive Order in a December 17th blog posting here: https://www.nowheretohide.org/2009/12/17/open-government-directive-another-ambiguous-unfunded-and-edental-mandate/
Don’t get me wrong, I am all for open government, but let’s do it right. Let’s give the techies a couple of days off and let’s take a good hard look at the non-technical issues that could really hurt this effort if they’re not properly addressed.
Your comments and thoughts welcomed.
Thanks…r/Chuck
09.03.2009
data sharing, fusion center, Information sharing, intelligence center, law enforcement, privacy, Processes, security
Time Magazine just released “Fusion Centers: Giving Cops Too Much Information?” – another article in a long line of articles and papers published over the last few years by many organizations describing how fusion centers are a threat to our personal privacy. In the article, they quote the ACLU as saying that
“The lack of proper legal limits on the new fusion centers not only threatens to undermine fundamental American values, but also threatens to turn them into wasteful and misdirected bureaucracies that, like our federal security agencies before 9/11, won’t succeed in their ultimate mission of stopping terrorism and other crime”
While I disagree with their assertion that “legal limits” are the answer (we already have lots of laws governing the protection of personal privacy and civil liberties), I do think that more can be done by fusion center directors to prove to groups such as the ACLU that they are in-fact operating in a lawful and proper manner.
To help a fusion center director determine their level of lawful operation, I’ve prepared the following ten question quiz. This quiz is meant to be criterion based, meaning that ALL ten questions must be answered “yes” to pass the test; any “no” answer puts that fusion center at risk for criticism or legal action.
Fusion Center Privacy and Security Quiz
- Is every fusion center analyst and officer instructed to comply with that fusion center’s documented policy regarding what information can and cannot be collected, stored, and shared with other agencies?
- Does the fusion center employ a documented process to establish validated requirements for intelligence collection operations, based on documented public safety concerns?
- Does the fusion center document specific criminal predicate for every piece of intelligence information it collects and retains from open source, confidential informant, or public venues?
- Is collected intelligence marked to indicate source and content reliability of that information?
- Is all collected intelligence retained in a centralized system with robust capabilities for enforcing federal, state or municipal intelligence retention policies?
- Does that same system provide the means to control and document all disseminations of collected intelligence (electronic, voice, paper, fax, etc.)?
- Does the fusion center regularly review retained intelligence with the purpose of documenting reasons for continued retention or purging of outdated or unnecessary intelligence (as appropriate) per standing retention policies?
- Does the fusion center director provide hands-on executive oversight of the intelligence review process, to include establishment of approved intelligence retention criteria?
- Are there formally documented, and enforced consequences for any analyst or officer that violates standing fusion center intelligence collection or dissemination policies?
- Finally, does the fusion center Director actively promote transparency of its lawful operations to external stakeholders, privacy advocates, and community leaders?
Together, these ten points form a nice set of “Factors for Transparency” that any fusion center director can use to proactively demonstrate to groups like the ACLU that they are operating their fusion center in a lawful and proper manner.
As always, your thoughts and comments are welcomed…r/Chuck
Following up on my comments and thoughts about the Open Government Directive and Data.gov effort, i just posted five ideas on the “Evolving Data.gov with You“ website and thought i would cross-post them on my blog as well…enjoy! r/Chuck