Back in September 2021 we launched the Declaration for Responsible and Intelligent Data Practice – a shared vision for data in Greater Manchester.
It was co-designed over a period of 18 months with data practitioners and experts, plus all sorts of other people from public, private, academic, civil-society and voluntary organisations within Greater Manchester and beyond.
Its 23 principles, grouped under eight themes, are a guide for those that commission, design and use data and digital systems, to help them understand how we can create more equitable and inclusive data practice, for the benefit of residents, the environment and future prosperity.
A lot has happened since the idea for a declaration was first mooted in 2019 – COVID-19, the invasion of Ukraine and the spiralling cost of living, along with changes in relevant legislation and growing unease about AI.
Much of what is included in the Declaration was meant to feel enduring – but it was created as a living document – and with this in mind, over the coming months, we will be looking at how the Declaration might be updated for these present times.
The Declaration’s data practice principles are below. Let us know your thoughts and if you would like to be involved in any upcoming workshops by contacting us at declaration@opendatamanchester.org.uk.
Declaration for Responsible and Intelligent Data Practice
Common data practice principles
1) We understand that data and digital systems are tools and not a replacement for humanity, we consider what these tools can and can’t do, and how they can enhance the everyday lives of those that live here.
2) We uphold that everyone has the right to respect for private and family life, home and correspondence, as stated in the Human Rights Act 1998, and that this is a foundational principle for the design of any system of data collection, sharing or processing.
3) The public sector, business, academia, voluntary and civil-society organisations that operate within Greater Manchester collect, use, share and store data in ways that are deserving of the trust of the people of Greater Manchester, as well as each other.
4) The region embraces the opportunities that data and digital bring, while actively trying to prevent the risks and harms that may emerge, by building an ethical digital and data ecosystem that supports the aspirations of the people of Greater Manchester, and prioritises the value that is given back to the region.
Collecting and using data
5) We recognise that, as organisations that collect and process personal data, we are custodians of it and have a legal, moral and ethical duty of care in its handling, including:
i) when personal data is collected, the lawful basis for the collection and processing of that data is accessible and open to review. We recognise that in some circumstances there are other lawful bases that are more appropriate than consent. If consent is the basis for collection and processing, the person giving consent is informed as to the purpose of this consent and gives it freely, and this consent can be withdrawn at any time, with the corresponding data repatriated to the individual and deleted from those systems;
ii) when services and systems are developed and used by Greater Manchester organisations, they collect only the minimum data needed (data minimisation) to perform a predefined task;
iii) that the systems that collect and process data will have strong privacy protection, adopting a privacy-by-design approach, with security and privacy-enhancing techniques being foundational to system design. This also extends to the ongoing operation, maintenance and decommissioning of the system; and
iv) that personal data derived from third-party sources be given the same consideration as data collected and processed by signatory organisations, with proper assessment of such data undertaken prior to its use.
Good governance
6) Good governance is essential for building and maintaining trust. Therefore, appropriate, open and transparent systems of governance should be developed, which have meaningful representation from people and communities involved in and affected by data use. Where necessary, support should be offered to those that may need help to represent their views.
Respect for all
7) In designing digital and data services and systems for Greater Manchester, we take into account the diversity of people who live and work here, and engage them at appropriate points in the data design process. We recognise that by doing so, we make better services, products and decisions.
8) All organisations collecting and using data understand that biases and assumptions exist within data and digital systems, and these must be actively acknowledged and assessed so that unintended consequences can be mitigated or prevented.
9) By default, organisations should make it clear and visible when and where they are collecting data about individuals, and this should be done at the point of collection, wherever possible. Organisations should explain and allow scrutiny of how data is captured, processed, shared and stored. This should be easily accessible and written in simple, jargon-free language.
10) When we design and procure new data and digital systems, we are aware of the human impact associated with the extraction of the raw materials that these systems are built from, and the treatment of those that build them.
System design
11) Innovation and experimentation are central to improving ways of working, and the development of new services and products. To create and enable a vibrant, creative and innovative region we should harness this energy, while understanding that these endeavours should be driven by user need.
12) When designing systems, steps should be taken to assess and mitigate against unexpected, undesirable and harmful outcomes, and if necessary, delayed until these issues are resolved. However, we also understand that reticence is a risk and thought should be given to how we account for opportunities not taken.
13) Where complex analytical processes are used for automated decision-making, such as artificial intelligence and machine learning, we commit to assessing these processes so that the outcomes from them are fair and accurate, and the code and processes are made available for scrutiny where necessary. If these processes or the outcomes derived from them cannot be explained, they shouldn’t be used.
Procurement
14) The public sector within Greater Manchester should be a leader in ensuring ethical, effective, efficient and transparent use of data. The sector must use the power that it has in procurement and decision-making to ensure that businesses operate appropriately and to the same standards when they are bidding for work, partnering or implementing systems of data collection and processing.
15) The risks of vendor lock-in, proprietary data standards, closed-source computer code and external data ownership are understood. Accordingly, procurement regimes should favour solutions that provide Greater Manchester residents and the region’s democratic bodies with as much control over data as possible, offering open and interoperable data standards, reconfigurable and open-source code, and an accommodation for transitioning from one solution to another at the end of, or cessation of, contracts.
Sharing knowledge
16) We need to demystify how data is collected and processed within Greater Manchester, offering training and support for organisations, communities and individuals to learn more about the opportunities and challenges of data use, as well as an appreciation of legal, moral and ethical rights, as well as how these can be asserted.
17) We believe that data knowledge and skills should be available to all, with consideration made for accessibility and the barriers for participation that may exist for underrepresented groups.
18) We are a collaborative region and we should aim to be more than the sum of our parts. Challenges should be shared, and the knowledge, skills and wisdom of people and organisations that are based here should be embraced, and used, to drive and develop new ideas, services and thinking.
19) Those involved with the collection, transmission, analysis, storage and deletion of data, and those making decisions based upon that data, should be supported to become knowledgeable and confident practitioners. Best practice should be shared widely and celebrated, enabling others to adopt and build on that practice.
20) In a connected world, knowledge and new ideas about data practice can develop anywhere. Greater Manchester, as an outward-looking, global region, should embrace this interconnectedness, drawing on knowledge and practice wherever it exists, and sharing back its successes and learnings in a spirit of openness and unanimity.
Open data
21) Organisations understand the value of publishing good-quality open data and commit to publishing it where practical. This means using appropriate licenses, standards where available, and ensuring data is released in a timely, accurate and comprehensive way.
22) Additionally, data that underpins government decision-making, or supports democratic processes, should be made available as open data by default, enabling the public and civil society to engage with democratic processes in a fully informed manner.
Environmental impact
23) In a time of climate emergency, we understand the environmental impacts of digital and data technologies – from the raw materials used in initial production, through ongoing maintenance and energy consumption when in use, to end-of-life disposal. Impacts should be measured and mitigated against where possible, and obsolete systems and infrastructure be redeployed, re-purposed or recycled where practical.