The London Data Charter - the principles

Introduction

The London Data Charter is underpinned by seven Principles:

1. Deliver benefit for Londoners
2. Drive inclusive innovation
3. Protect privacy and security
4. Promote trust
5. Share learnings with others
6. Create scalable and sustainable solutions
7. Be as open as possible

The Principles were developed by the BusinessLDN Data Working Group and first adopted in June 2021, informed by LOTI’s outcomes-based methodology for data projects.

The Principles are a common foundation that any organisation interested in sharing data in London can use as a base for data-sharing activities. They are a shared reference point for public-private sector data sharing initiatives, helping to demonstrate collective purpose and increase efficiency by giving everyone the same strategic policy starting point. It is designed to work in tandem with the Emerging Technology Charter for London.

This page examines each of the Principles in turn, supplementing each Principle with supporting text about what it should mean in practice.

1. principle: DELIVER BENEFIT FOR LONDONERS

To address the Mayor’s priorities for London the city needs to make better use of the vast amount of data and analysis held by the private and public sector. Opening up access to a wide range of data sets will create social and economic opportunities to benefit businesses, local authorities, charities, citizens and many more. Encouraging public, private and third sector collaboration through data sharing will create insights that can support better policy decision-making.

We encourage data sharing between organisations to reduce London’s impact on climate change, improve air quality, restore confidence in the city, narrow inequalities, create smarter neighbourhoods and unlock social and economic benefits, including with data sharing pilots focussed on EV charging, Skills, Retrofit and Carbon data, in particular.

2. PrinCIPLE: DRIVE INCLUSIVE INNOVATION

London is already one of the most innovative cities in the world. The GLA London Data Store, SafeStats the High Streets Data Service  the Green Infrastructure  map and the Infrastructure Mapping Application  allow public access to a wide range of datasets already. The GLA has set up a new Data for London Advisory Board and begun work on a new data sharing platform and a city-wide data strategy.

The London Data Charter will create cross-sectoral opportunities to innovate with data, through encouraging data sharing in a collaborative way between businesses of all sizes, local authorities, government agencies and government departments.

Yet if this innovation is to be truly inclusive, digital exclusion across London must also be addressed. The Digital Access for All mission encourages a ​‘whole city’ approach to address digital exclusion which is reflected in the London Data Charter. Data shared under the Charter will help us to understand where people are most at risk of digital exclusion and enable organisations to deliver innovative, community centric and data-driven solutions in response. The Charter will also promote inclusivity by facilitating collaboration between innovators from differing levels and backgrounds. 

The BusinessLDN Data Working group already has a policy of involving early-stage professionals and researchers to join the group as substitute members representing their organisations. In addition, we encourage:

• Participation from businesses, local authorities, the general public, research institutes and academic institutions to find ways to use data to promote innovation.
• Organising drop-in sessions for innovators with different skillsets and areas of expertise to enable and expedite innovation using shared data. 

3. principle: PROTECT PRIVACY AND SECURITY

Recent high-profile data breaches  are a useful reminder that personal and/​or sensitive data must be protected and kept secure in any collaborative data sharing exercise. It is vital that the London Data Charter safeguards the privacy and security of data obtained from individuals and that participants have rigorous and transparent measures in place to achieve this. Such measures will allow data to be collected and shared on a wider scale, which will serve to not only benefit the participants and Londoners more widely but will also lay the foundations for and develop the public’s trust in their data being shared securely and appropriately.

Being aware of and complying with the existing law and any relevant regulatory guidance is the first step in enabling trusted data sharing.

In particular, the London Data Charter supports:

• Being clear about the purpose and intended benefits of data sharing, including exactly what information will be collected and with whom it will be shared, to streamline the data collection process and enable transparent communications at source.
• Compliance with the ICO’s Data Sharing Code of Practice that came into force on 5 October 2021.
• Effective de-identification and aggregation techniques to prevent unintended disclosures of personally identifiable information of individuals.
• The use of privacy enhancing technologies (PETs), as defined in the National Data Strategy, to provide an additional layer of protection and enable trust.
• Robust information security measures in line with industry standards to create an infrastructure protecting information where necessary and addressing commercial sensitivities.
• Comprehensive data governance practices including the establishment of an oversight and accountability framework and common privacy and security standards that all participants must meet.
• Rigorous data management techniques ensuring appropriate retention periods, access rights and data stewardship.
• Establishing common expectations around data sharing and privacy to ensure that data privacy and security are a key consideration for participants at all times.

4. principle: PROMOTE TRUST

The need for trust in institutions, especially when it comes to data sharing, has never been greater. For the London Data Charter, the development of trust, not just between the parties involved in data sharing, but with the public generally, means three things: Transparency; Ethics and Accountability.

TRANSPARENCY

We encourage:

• Using Government or industry approved standards and plain language wherever possible and including glossaries of specialist terms and explanatory resources. 
• Being as open as possible about what is proposed and how it will be achieved.
• Where data or documents are confidential, giving a clear justification for this.
• Where new technologies are engaged, being open about the potential harms and explicit about how risk is assessed and weighed against benefits.
• Carrying out consultation and engagement and listening to the answers.
• Keeping everyone informed through the lifetime of a project.

ETHICS

Ethics begins – but does not end – with legal compliance. The National Data Strategy stresses the need for ​“a clear and predictable legal framework for data use” but other areas of law are relevant here including procurement of new technologies, data regulation, human rights and equalities- particularly when it comes to technologies that facilitate pervasive surveillance. However, ethics is about more than compliance. While there is no universally accepted definition of data ethics, the Open Data Institute’s Data Ethics Canvas defines it as ​“a branch of ethics that evaluates data practices with the potential to adversely impact on people and society – in data collection, sharing and use”. The ODI goes on to say that it involves ​“good practice around how data is collected, used and shared” and the Data Ethics Framework identifies three overarching principles: Transparency, Accountability and Fairness.

In reality, the ethical issues will be different for each project and should be an issue for consideration prior to implementation, both as the project develops and at its end.

ACCOUNTABILITY

Accountability is particularly important when it comes to public-private sector data collaborations, because of specific legal obligations to disclose information and record decisions, and because those decisions are, as they should be, more open to public scrutiny. In practice, we encourage:

• Consultation, not just at the beginning of a project but throughout when important decisions are taken.
• Transparent assessments of risks and unintended impacts, whether related to data sharing or the use of emerging technologies or both.
• Keeping full and accurate records of decisions made and the reasons for those decisions. 

5. principle: SHARE LEARNINGS WITH OTHERS

The amount of data available is increasing, as is the range and variety of data sources. The technology that can be used to analyse this data is developing at pace. This combination of factors has the potential to turn data into a powerful tool to inform policy development, whether by providing a sound evidence base or through the reliable predictive modelling of potential outcomes. At the same time both private and public sector organisations are learning how to manage the collection, storage and sharing of data in a way that creates maximum benefits for organisations and individuals. 

The data and the technologies are already pervasive; there is a significant opportunity to make the learnings available to everyone, too. Organisations that sign up to the Principles and engage in data-sharing initiatives will be encouraged to share what they learn – including a circularity of approach based on the LOTI four-step data methodology:

We encourage:

• Establishing regulatory sandboxes, data sharing pilots, data challenges and hackathons to stimulate rapid innovation using shared data in secure environments, where required.
• Providing transparent feedback on what worked and what did not, and on what improvements were made, so that the whole community can benefit from it. 
• Sharing methodologies, impact and risk assessments and template documents so that we can build an online resource of trusted materials and practice.
• Participating in workshops and offering support to emerging projects. 

London is a world-leading smart city, but it is not alone. There are communities large and small, local, national and international, who are grappling with the task of maximising the benefits of collaborative data initiatives while minimising risk and harm. We can all learn from each other and this is why the London Data Charter will include links to the GLA and the London Datastore, and other smart cities, smart communities and relevant policy bodies such as the ODI, the Ada Lovelace Institute and the Turing Institute.

6. principle: CREATE SCALABLE AND SUSTAINABLE SOLUTIONS 

A data sharing model is just a model. It is the creation of scalable and sustainable solutions using this shared data, together with the new London Data Platform, that will really make a difference on the ground. 

Instead of simply ​‘growing’ solutions by injecting them with cash and resources, the London Data Charter will promote scalability and sustainability through an open, collaborative and trustworthy approach. 

To generate real scalable solutions using the data shared by public and private organisations, the knowledge gained must be shared with other businesses, local authorities and the wider public. We must also be prepared to learn from other cities and communities on their own digital journeys.

Solutions will be adaptable and of benefit to all Londoners, supporting economic growth and improving how we live and work. They will be replicable across different areas of government and society and used across different neighbourhoods and boroughs to target that area’s specific needs. 

The London Data Charter will also establish sustainable solutions to support and enable innovation in London in both the short and the long term. Efforts will be concentrated not only on promoting London’s resilience to challenging economic times ahead, but also on forming innovative, durable policies to shape the future of the city. 

The London Data Charter promotes in particular data-driven solutions that are also environmentally sustainable, and the sharing of datasets between energy providers, local authorities and citizens, both of which will play vital role in London’s aim to be a net-zero carbon city by 2050.

We encourage:

• Collaborating to cultivate resilient and long-term solutions to exploit opportunities and tackle challenges as and when they arise, both now and in the future.
• Developing replicable and reusable solutions that can inform public policy, private sector solutions and consumer behaviour, and be adapted to benefit all businesses and citizens in all areas of London. 
• Developing environmentally sustainable solutions using shared data, avoiding unnecessary data duplication, retention and processing that could produce unnecessary carbon. 

7. principle: BE AS OPEN AS POSSIBLE

Data availability is key to the success of any data sharing initiative. For us, a successful data sharing exercise has a clear purpose and identification of the datasets involved. Various tools such as the ODI’s Data Ecosystem Mapping tool can be used to assist with this.

While ​“open by default” may be an appropriate measure in the context of public sector data being made available to the public, a more nuanced approach is needed to facilitate engagement with and within the private sector. Alongside the issues of regulatory and legal compliance, there may be commercial sensitivities that will need to be addressed before the sharing of certain data is practicable. And there may be instances where an organisation is more willing to share data with an independent third party in the form of a data intermediary, than it is with, for example, a competitor.

Some concerns may be capable of being addressed by way of PETs that allow data to be interrogated without the data itself being shared or disclosed. The surest way of guaranteeing the availability of data and of sustaining data-sharing initiatives, is to focus on what the initiative is designed to achieve and on the potential benefits that that initiative will bring. Where data is being kept confidential, that should be justified in a transparent way. In particular we encourage:

• A clear and thorough analysis of the issue(s) that the data-sharing initiative is designed to address, focusing in particular on:
  • The benefits that the initiative is intended to bring, at societal, organisational and individual levels.
  • The perceived barriers that may prevent the sharing of data, including not only the need to comply with data protection and competition laws, but also any commercial sensitivities that may impact upon the willingness of potential participants to share data.
• Once benefits have been identified, an analysis as to whether those benefits are shared equitably between participants. An equitable sharing of benefits will contribute to the ongoing sustainability of the initiative.
• Where barriers are identified, an analysis of any mitigants that can be employed to reduce or remove those barriers. Where confidentiality is essential, it should be justified.