We welcome the opportunity to respond to the consultation on the Centre for Data Ethics and Innovation. We found the document to be clearly written and easy to understand. It should set a standard for all publications from the Centre for Data Ethics and Innovation.

We think there is a current and urgent question that needs to be answered by the Centre: where does leaving the European single market position the UK in terms of data ownership and protection? Building international relations to understand data policies globally becomes even more important within this context.

1.Do you agree with the proposed role and objectives for the Centre?

We are broadly in agreement with the proposed roles and objectives for the centre.

We note that there is no reference to working with the Department for Education, nor for any work which involves schools. We believe that data ethics needs to be included in the teaching of digital skills and computer science across schools and Higher Education as well as being studied by all children as part of citizenship lessons.

The consultation states that “identifying global opportunities to collaborate on cross-jurisdictional questions of data and AI governance and to formulate governance measures that have international traction and credibility” will be a role for the Centre. Given the transnational nature of the private enterprises that are currently at the forefront of data and AI usage and development we see this as being a cornerstone of the Centre’s work. Without governments’ capacity to enforce the measures advised by the Centre the impact of its work will be severely reduced.

2.How best can the Centre work with other institutions to ensure safe and ethical innovation in the use of data and AI? Which specific organisations or initiatives should it engage with?

As a regional forum that promotes the release, re-use and integration of open data to benefit communities, businesses and public services we believe that West Midlands Open Data Forum are an organisation that the Centre should engage with.

We would suggest that the Centre could work with the following institutions and organisations who have a specific interest/speciality in working with data:

  • The Open Data Institute Leeds.
  • The Leeds Institute for Data Analytics.
  • Open Data Manchester.
  • Open Data Services Co-Op
  • Satori Lab
  • Data Orchard

As data is embedded into all business areas, it would be useful to engage at a strategic level with standards bodies such as BSI, CEN/Cenelec etc to look at the influence data ethics could/should have on new standards or as an improvement of existing standards.

In addition we believe that the Centre should have a significant outreach programme that involves working with organisations and citizens who do not have a specific speciality in working with data, including civil society organisations.

3.What activities should the Centre undertake? Do you agree with the types of activities proposed?

The types of activities proposed logically follow the aims and objectives of the Centre. We detect a weaker language in the activities related to building capacity in data users and international collaboration.

4.Do you agree with the proposed areas and themes for the Centre to focus on? Within these or additional areas, where can the Centre add the most value?

With respect to the transparency theme – the focus here appears to be the transparency of the methods used to process and analyse data. We would like to see this extended so that the theme incorporates the whole of the data lifecycle, starting from when decisions are made about which data are collected.

5.What priority projects should the Centre aim to deliver in its first two years, according to the criteria set out above?

These are two suggestions that we think could be amongst your priority projects in the first two years.

  • Develop a community of non data experts and organisations to consult with and appoint representatives from these groups to the board
  • Understand the current use of AI within the public sector, its transparency (or lack of) and how accountable it is to the people who are directly affected by the decisions made

6.Do you agree the Centre should be placed on a statutory footing? What statutory powers does the Centre need?

We agree that the Centre should have statutory powers to have real impact.

7.In what ways can the Centre most effectively engage stakeholders, experts and the public? What specific mechanisms and tools should it use to maximise the breadth of input it secures in formulating its actions and advice?

We believe that the Centre should be hosted outside of London.

To support wider engagement with stakeholders, we recommend that the Centre engage with the data research and development programmes of media/data journalism organisations such as the BBC Shared Data Unit, and Bureau Local.

To maximise practical awareness, implementation and input, the Centre should consider having a presence within significant regional/industry data innovation programmes where the access, sharing and use of data, and development of data skills is being addressed as part of an integrated programme of activities.

Nesta’s Seven Principle’s of Public Engagement should be one source of guidance that the Centre should use when considering the mechanisms and tools it uses in this area.

8.How should the Centre deliver its recommendations to government? Should the Centre make its activities and recommendations public?

This is the question that gives us the most cause for concern, primarily by its very asking.

Yes, the Centre should make its activities and recommendations public. Further than that it should provide clear explanations of its activities and recommendations as these are key to making its work as accessible as possible.

The Centre should seek collaborations on its work that are conducted in the open.

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