In parallel with the public consultation on the revision of the European Interoperability Framework, the Commission has also been running a public consultation on “Sharing and Reuse Guidelines”. Both consultations can be found here. There has not been much publicity about this second public consultation, which is a pity because the document makes for interesting reading.
Under the predecessor versions of the ISA² programme, the Commission has for many years now encouraged and supported the sharing and reuse of IT building blocks for public services, as well as collaboration between public administrations in developing, deploying and maintaining such building blocks. It has done so via the provision of an infrastructure for sharing, reuse and collaboration (Joinup) and by the publication of a large number of studies and guidelines.
In that context, the Commission developed a set of guidelines that have recently been subject of a public consultation. OpenForum Europe has responded to this consultation and this blog post gives our analysis of the document.
The draft document is clear in its objectives, and provides sensible guidelines to public administrators and IT solution providers. The structure of the document and the grouping of the guidelines around communication, legal, technical and organisational issues makes sense. The document is easily readable and the language is understandable for non-experts.
But there are many ways in which to make this document even better:
- Although the word “collaboration” figures in the sub-title of the document, this collaboration is evidently not considered to be at the same level as “sharing” and “re-use”. The document seems to be written for a world consisting of producers of IT solutions – be they private companies or public administrations that compete with private industry in the eGovernment market – and customers (other public administrations).
- In that sense, most of the “sharing” advice to the producers of IT solutions is oriented towards supporting these producers to promote their products.
- The authors seem to forget that public administrations do not exist with the purpose of developing IT solutions (building blocks), but rather of providing services to citizens and businesses.
- While it is true that identifying common needs may promote sharing and reuse, any IT project that does not start to fulfil a very concrete need expressed by one or more public administrations (as opposed to perceived needs of potential customers) is doomed to be costly, and may very well fail to be usable. In the same context, while it is often advantageous to take internationalisation principles into account in IT projects, it does not make sense for all projects, certainly not in mono-lingual member states.
- Reading recommendation 4.2 – the first time that “collaboration” is mentioned in the document – one has the impression that no real collaboration between equals is promoted, but – at best – that the “owners” of IT solution should consider allowing others to contribute, whilst ensuring that they keep all ownership rights. Very few open source projects have been successful in using such an asymmetric distribution of ownership rights.
- In recommendation 4.3, the suggestion to use open source licences should be explicit. Doing so will open software produced for public administrations and paid for by public money to as many users as possible.
- When open source software is mentioned in recommendation 5, this is in the context of procuring (open source based IT solutions). It is a pity that the power of open source software to bring communities together and to allow communities and the IT solutions they develop to evolve over time in a very organic way, responding to real needs when they appear or change over time, is apparently not recognised or (at least) not acknowledged.
- When speaking about business models that facilitate sharing and reuse, it should not be forgotten that collaborative projects and joined development represent the best way to optimise the probability of sharing and reuse.
- While recommendation 9.2 (about Total Cost of Ownership (TCO)) is of course very true, this recommendation is not relevant in the context of sharing and reuse.
- Under recommendation 9 (“Adopt business models that facilitate sharing and reuse”), there is a recommendation for central bodies to provide financial support for projects with a high potential for sharing and reuse. This recommendation may very well suggest that public administrations when procuring or producing IT solutions should favour reuse and sharing over and above fitness for purpose and value for money.
- The next recommendation – to encourage public administrations to pool resources – is very relevant but again, taking the example of many successful open source projects, such pooling does not need to imply any form of centralisation of the creation of complex control structures.
- And finally, recommendation 10 – about restrictions to sharing – is of limited value. Security by obscurity can never be a goal, and legal restrictions to sharing are barriers to overcome if best use is to be made of public funds. It is suggested that this recommendation be dropped.
And finally, a small suggestion that should at zero cost provide much more visibility to all the good work which the Commission has already achieved in this area: for every reference to an existing Commission document or guideline, simply provide (either as a replacement or perhaps via a footnote or end-note) a link to that same document or guideline as published online, so that the reader, with a single click, can have direct access to all these documents and guidelines. After all, isn’t that what the world-wide web is supposed to be all about?