Statements

null Working group report on the development of public sector data management regulation

Ministry of Finance set up a working group to look into the development of information management legislation in November 2016. The working group completed its task by publishing a report in October 2017. The report proposes further preparation of the information management legislation, including preparation of a common Act on public administration information management. In the view of the working group, the new Act would replace at least the current Act on Information Management Governance in Public Administration (634/2011), the Archives Act (831/1994), part of the Act on Electronic Services and Communication in the Public Sector (13/2003), as well as part of the Act on the Openness of Government Activities (621/1999).

CSC supports the objectives of converging specific laws into a general law, embracing the full life cycle of information and information management proposed in the report. CSC also supports opening data and its reuse, on the other hand, raises specific concern regarding the operational preconditions of science and research.

CSC views that the report does not properly take into account the securing of the confidentiality of information. CSC is concerned about the proposed changes in the regulation of security classifications. The current lowest classification, Restricted Access, is good and should not be changed to "Public with Consideration".  The suggested new elusive concept of the minimum level of IT security must be defined in a more coherent and comprehensive way in order for it to be implemented in an efficient and transparent way.

CSC notes that interoperability between data management systems requires open APIs, common information components, ontologies, glossaries, code sets, terminologies, and definitions. CSC supports the MyData approach in personal data and emphasizes the importance of citizens' rights such as freedom of speech and protection of confidential information.

CSC hopes national and international initiatives, such as the Open Science Initiative (ATT), Research Data Alliance (RDA), EUDAT, and the European Open Science Cloud (EOSC) will be taken into account in the forthcoming legal drafting.