NEWS

PSI Alliance statement on Commission HVDs roadmap

25 August 2020

The PSI Alliance is grateful for the opportunity to comment on the Implementing act on a list of High-Value Datasets. After taking part in the validation workshop at July the 28th we want to outline one key principle of the HVD definition:

We welcome Article 14 of the directive 2019/1024 regarding HVDs, in particular that specific high-value datasets shall be:

(a) available free of charge, subject to paragraphs 3, 4 and 5;
(b) machine readable;
(c) provided via APIs; and
(d) provided as a bulk download, where relevant.

However, we want to remind the Commission and public authorities that all public datasets subject to the revised Open Data Directive are of value and should not be ignored just because they are not classified as a HVD and subject to the Implementing Act.

In particular, we want to highlight that ‘normal’ PSI datasets should also be subject to the following:

Charging
According to Article 6 the re-use of documents shall be free of charge, but recovery of the marginal costs may be allowed.

Machine readable format
Article 5 says that documents shall be made available where possible and appropriate, by electronic means, in formats that are open and machine-readable.

APIs and bulk download
According to Recital 32 and Article 5.5 dynamic data shall be made available via APIs.

During the process of creating the HVD list and especially during the workshop many datasets were mentioned and discussed, but nobody mentioned that to all of these datasets the PSI directive applies directly since 2015. The Member States are obliged to make these datasets reusable, at least following a request, according to Article 4 of the directive. It may be that these datasets are not totally free of charge at the beginning or machine readability is lacking, but at least they should be available for reuse.

Conclusion:

The question regarding all the datasets mentioned in the validation workshop is not whether to release or not to release, but only in which way they should be released, i.e. as HVDs or as “normal” PSI. We urge the European Commission to communicate this fact to the representatives of the Member States.

PSI Alliance statement on Commission HVDs roadmap

25 August 2020

Recommendations for effective implementation

26 September 2019

The Commission estimated in the Impact Assessment that the total direct economic value of PSI is expected to quadruple from a baseline of EUR 52 billion in 2018 for the EU28, to EUR 194 billion in 2030. Only with unbiased and effective implementation and a desire to overcoming barriers to reuse, can this become a reality.

Following the entry into force of the recast of the Open Data and PSI Directive, the PSI Alliance would like to make the following recommendations for the implementation of the Directive.

High Value Datasets

As the High Value Datasets are an important step forward, the list of datasets should enter into force as soon as possible,
and certainly before the end of the implementation period.

There are further categories that hold important socio-economic benefits for EU citizens should be included as soon as possible. For example, “Legal and Administrative data”, as it not only contributes to a competitive legal tech sector but also to the protection of fundamental rights such as the right to a fair trial.

Categories of dataset included into the HVD list should not be questionable by the Member States due to privacy concerns. In case of datasets containing personal data, the Commission should conduct impact assessments to ensure data protection and a final balancing of interests as per Article 14.2.

General Principles

Member States shall ensure that accessible documents that do not fall under the exemptions in Article 1(2), shall be re-usable for commercial or non-commercial purpose

Applicants have a right to the release of applicable datasets, it should not be seen as a gift from the public authority or public undertaking.

Public authorities and public undertakings should support the demand side by ensuring that reusers know about their rights and have effective means of redress in case of rejection of their requests to access public sector information.

Member States must be required to clamp down on discrimination – it is still commonplace for private re-users not to have access to
the same data as state owned competitors, in particular areas such as transport.

A public online consultation on the access to public sector information in Member States, as well as a review of existing exclusive arrangements to reuse public sector information should be launched by the Commission.

Artificial Intelligence

If we want a European to be a leader in artificial intelligence, then we need sufficient availability of data for training purposes. Training data and validation data is absolutely essential to the development of any machine learning model.

Comprehensive datasets are also key to ensure that datasets are representative, and therefore lead to unbiased and ethical algorithms using AI.

The prospects for economic growth are considerable thanks to the provisions in the revised PSI Directive, but only if the authorities take advantage of the opportunities in the Directive.

Recommendations for effective implementation

26 September 2019

PSI Alliance presents to Member State Expert Group

15 May 2019

The PSI Alliance was invited to present to the PSI Group of national experts, hosted by the European Commission in Luxembourg. We gave the opinion of reusers for the forthcoming implementation.

We argued that the inclusion of High Value Datasets is an important step forward, the list of datasets should enter into force with the end of the implementation period.

There are further categories that should be included as soon as possible, for example „Legal and administrative documents”.

In case of datasets containing also personal data impact assessments of the Commission according to Article 13 (2) should cover also data protection matters and a final balancing of interests. A dataset included into the list should not be questionable by the Member States due to privacy concerns.

Beside High Value Datasets, on the General Principle, we argued that Member States shall ensure that accessible documents, that do not fall under the exemptions according to Article 1(2), and should be be re-usable for commercial or non-commercial purpose.

We made the case that applicants for data have a right to release of those datasets, it´s not a present!

And that “Demand Side” should be supported - potential re-users often don´t know anything about their rights, public administrations should better inform them.

We also gave practical examples where there are still stumbling blocks, and how discriminating practices should be avoided, for example up to now private re-users don´t have access to the same mobility data as state owned competitors, for example reasons for delay and cancellations.

Finally, on artificial intelligence, we argued that one prerequisite for developing AI solutions is the sufficient availability of data for training purposes. Training data and validation data is absolutely essential to the development of any machine learning model.

According to the European Commission a European approach on AI will boost the European Union’s competitiveness and ensure trust based on European values.

If the European Member States seriously want to boost AI solutions, the sufficient supply of PSI data for these purposes will be one cornerstone.

PSI Alliance presents to Member State Expert Group

15 May 2019

Roundtable - implementing the PSI Directive

24 April 2019