Data access controls consultation – update

Consultation on changes to the NBN Gateway access controls and download functionality.

The initial phase of this consultation is now complete. There was an excellent level of participation in the survey – we received 93 online responses from 85 different organisations, including national recording schemes and societies, local record centres, conservation NGOs, local natural history societies, independent researchers, ecological consultants, statutory agencies and academic institutions.  Seventy-seven respondents were current data providers.

We would like to thank everybody who took part in this consultation – the feedback will be extremely valuable in shaping the future of the NBN Gateway.  In the main, the responses indicated an appreciation that the Gateway must evolve in order to provide acceptable performance and functionality for both data providers and data users.

We were greatly encouraged to find that virtually all of the proposals were supported by the majority of respondents.  Nevertheless, we are aware that certain elements of the proposals caused a lot of concern amongst some data providers.  Some of the proposed changes are very far reaching and it is vital to weigh up all the pros and cons before making any decisions. 

Next steps

We now plan to revise the proposals in the light of feedback received and to embark on a second phase of consultation, during which we will address specific concerns and provide further information to help you to visualise how the proposed new access controls would actually work.  This will include a series of screenshots available in January to illustrate proposed features such as a data download wizard and a more user-friendly system for managing access requests.  These will be followed in March by a functional prototype with test data, enabling users to interact with the proposed system and to provide further feedback and suggestions for improvement.

What may be included in the new system?

We anticipate that a new system of data access controls would incorporate at least some of the following elements, which were extremely favourably received during the survey:

• Increased regulation of data download and better reporting to data providers, e.g.:

• the requirement for users to be logged in before downloading data (approved by 93%).
• the requirement for users to state the category of use and the reason for data download (approved by 90% and 88% respectively).

• The ability to set access controls at the level of the individual record, with filters enabling access to be set geographically and taxonomically (approved by 83%)

• Specific comments in the survey show that many of you have already identified how important this will be in improving data flow between different sectors of the NBN.
• Many data requests are currently dealt with outside the NBN Gateway because the data provider prefers to give access only to the records of direct relevance to the user.  The proposed change should increase the number of requests dealt with through the Gateway, which is likely to be more convenient and efficient for most data providers.

• The ability to set time limits on access privileges (approved by 80%)
• Improved tools for managing access requests (approved by 84%)
• The ability for users to apply for enhanced access to a number of datasets with a single request (approved by 77%).
• The retention of a separate control to flag sensitive records (approved by 94%)

Which elements of the proposals caused concern?

The following elements of the proposal proved more contentious, and we are considering ways in which they could be modified to make them more generally acceptable:

• Introduction of a facility to download a whole dataset (27% are opposed, while 63% approve of this measure; 43% of which wholly approved).

• Whole dataset downloads could be regulated by enabling data providers to refuse any request to download a whole dataset, e.g. within 21 days from the date of request.

• All users will be able to download data, i.e. it will no longer be possible to set access to ‘view only’. (35% disapproved of this proposal, while 52% approved; 28% of which wholly approved).

• We would like to clarify that under this proposal data could only be downloaded at the access level set by the data provider for that user.  We also propose to introduce a 5km level of access to provide further flexibility on blurring access to data.
• We would be interested in receiving any suggestions for modifications either to the proposal or to the Gateway Terms and Conditions that would make this element more acceptable.

• Only two levels of access: public and full. (34% disapproved and 50% approved)

• This is a fundamental element of the proposal, which is required to deliver many of the most popular features.  However, we appreciate that it considerably restricts the options of the data provider, so we propose to improve the flexibility of our data import processes to enable the ‘public’ version of the data to be configured according to specific requirements, for example: 
• Recorder and determiner names and record attributes could be included or excluded from the ‘public’ access level, according to the wishes of the data provider.
• The ‘sensitive’ flag could be used to blur records to a non-sensitive level (e.g. 10km square) or to remove them from public view, according to the wishes of the data provider, without duplicate records appearing on the NBN Gateway.

In general, concerns raised by data providers focussed on the ‘public’ level of data access rather than the ‘enhanced’ access level granted by data providers to specific users.  Many of you thought that overall, the proposals would:

• Impact on revenue streams (36% of data providers)
• Be unacceptable to data contributors (44%)
• Increase the risk of misuse of the data (40%)
• Increase the risk of unauthorised commercial use of data (43%)
• Adversely impact on your capacity to provide interpretation of your data (21%)
• Make it difficult to regulate use of your data (38%)

Addressing concerns on misuse of data

The NBN Trust is working with data providers and partner organisations to address concerns about misuse of data, unauthorised commercial use of data and the consequent potential impact on revenue streams.  We are seeking legal advice on how to respond to infringements of the NBN Gateway Terms and Conditions, and striving to raise awareness of the Terms and Conditions amongst target user groups. 

We have already improved the presentation of our Terms and Conditions on the Gateway, and will be providing clearer guidance about data use on the new NBN website in the coming months.  We are also working closely with partner organisations such as the Association of Local Environmental Records Centres, the Association of Local Government Ecologists and the Institute of Ecology and Environmental Management to develop and promote best practice and compliance with NBN data exchange principles. 

Timescales

We will not run another online questionnaire survey, but will gather feedback throughout January to March 2012 via the NBN forums, meetings and correspondence with data providers, enabling us to reach a collective decision in April. Subject to agreement from data providers, the first version of a new system of access controls could be launched at the end of June. We hope this time frame will give data provider’s sufficient opportunity to consult with their recording community and to review their data access policies if necessary. We will be involving the Board of the NBN Trust in this process to gain the Board members’ approval for the proposed changes and to make sure they are aware of all feedback.

Thank you for your ongoing support and feedback in this important piece of work.