Introduction

The Principles are at the core of the Charter: Deliver benefit for Londoners; Drive inclusive innovation; Protect privacy and security; Promote trust; Share learnings with others; Create scalable and sustainable solutions; and Be as open as possible. They mirror the structure of the Emerging Technology Charter for London and have been informed by LOTI’s outcomes-based methodology for data projects.

The Principles are designed to be a simple, transparent policy base that any organisation interested in sharing data in London can adopt for data-sharing activities. They will be a common reference point for public-private sector data-sharing initiatives, improving transparency of collective purpose while increasing efficiency by giving everyone the same strategic policy starting point. The Library of Resources will include a range of template documents; one of these a template MOU that any organisation can use to demonstrate formal adoption of these Principles.

The remainder of this document examines each of the Principles in turn, supplementing each Principle with supporting text about what it should mean in practice, together with links to supporting guidance and relevant documents.

Deliver benefit for Londoners

To address London’s most pressing challenges, 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. The insights derived from this access will help citizens of London and support the London Recovery Programme by encouraging public, private and third sector collaboration through data sharing and leading to better policy decision-making.

In particular, and as non-exhaustive goals, we encourage data sharing between organisations to deliver the following benefits to Londoners:

• Reducing London’s impact on climate change, improve air quality for those who live and work in the city and support London’s goal of being a zero carbon city by 2050.
• Restoring confidence in the city, minimise the impact on London’s communities and build back better the city’s economy and society following the Covid-19 pandemic.
• Narrowing social, economic and health inequalities and helping Londoners to flourish with access to support and opportunities across the city.
• Creating smarter neighbourhoods using data to unlock local social and economic benefits for all our communities. 

Drive inclusive innovation

There is no doubt that London is already one of the most innovative cities in the world.

In line with the National Data Strategy, the London Data Charter will help businesses and public entities of all sizes to innovate and explore opportunities using data, through facilitating its sharing among different organisations. Collaboration between businesses of all sizes, be they SMEs, start-ups, multinationals or public companies, with local authorities, government agencies and government departments, will translate into opportunities for cross-sector innovation. 

To drive truly inclusive innovation, digital exclusion across London must also be addressed. The Mayor of London’s 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 London Data Charter will also promote inclusivity and establish a level playing field for innovation. It will facilitate collaboration between innovators from differing levels and backgrounds to develop innovative solutions and technologies using London’s data. 

We encourage:

• Establishing regulatory sandboxes, data sharing pilots, data challenges and hackathons to stimulate rapid innovation using shared data in secure environments, where required.
• 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. 

Protect privacy and security

It is important that data sharing ensures personal information is protected and sensitive information is secure when sharing and collaborating. It is vital that the London Data Charter safeguards the privacy and security of data obtained from individuals and that participants apply the highest standards of data management and transparency. It is important to acknowledge that existing regulation, such as Data Protection Law, can enable trusted data sharing.

In particular, the London Data Charter supports:

• Being clear about purpose and what information is being collected and with whom it is shared so as to enable transparent communications at source.
• Effective de-identification and aggregation techniques to prevent unintended disclosures of personally identifiable information of individuals.
• 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 sensitives.
• Rigorous data management techniques ensuring appropriate retention periods, access rights and data stewardship.

Promote trust

Trust among all stakeholders, including the public, is essential for the success of any data sharing initiative which promotes the importance of ​“open and trusted ways of working”. This point is also noted in the Emerging Technology Charter. For the London Data Charter, trust means three things: Transparency; Ethics and Accountability.

Transparency

We encourage:

• Using 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 assessing their risk in an open way.
• 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. 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 throughout its life.

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. 

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:

• 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 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.

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 that will really make a difference on the ground for the people of London. 

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. 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. 

Solutions will be adaptable and of benefit to all Londoners, supporting economic growth and improving how we live and work. They will also be replicable across different areas of government and society, 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 imminent economic and social recovery after Covid-19, but also on forming innovative, durable policies to shape the future of the city. 

The London Data Charter also echoes the National Data Strategy’s creation of a Data Sustainability Charter and focus on sharing data to achieve environmental sustainability. Environmentally sustainable solutions will evolve through the sharing of rich datasets between energy providers, local authorities and citizens, playing a 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. 

Be as open as possible

Data availability sits at the heart of the National Data Strategy. The strategy is clear, however, that by ​“data availability”, they mean an environment that facilitates ​“appropriate” data access.

The government response to the strategy states that the government is considering the extent to which government intervention can provide a horizontal enabler of better data availability. In particular, the government is looking at the roles that standards, financial incentives and data intermediaries might play in enabling data sharing.

One key element in any data sharing arrangement is the purpose of such arrangement and the consequent identification of the data that will be shared. 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. In particular, 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.

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 privacy enhancing technologies (PETs) that allow data to be interrogated without the data itself being shared or disclosed.

Beyond these concerns, 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.

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. As mentioned above, mitigants might include the use of a data intermediary or PETs.