Good Governance - Effective Use of IT

Written evidence submitted by Open Source Consortium (IT 63)

In the light of the emphasis of all participants placed upon the the role of open standards, the Open Source Consortium (OSC) should like to submit a third set of evidence to the Inquiry by the Public Administration Select Committee into the way in which Government develops IT policy and the strategy for its implementation.

Introduction

Cabinet Office is currently conducting a survey [1] , of "Open Standards" due to finish by 20 May 2011.

However, this survey is being conducted seemingly without understanding what is or is not a standard in either a strict sense or according to previously published policy on open standards. Further the survey appears to have been created without reference to relevant cross-cutting policy such as that relating to accessibility of web content.

We are concerned that this is a survey:

ñ as it is not a consultation there is no obligation to meet the requirements of a government consultation including the requirement to publish survey responses or publish a government reply.

Consultations are a formal engagement process emphasising openness as contained in the official guidance [2] including when not to consult [3]

"Clearly, if there is no scope for consultees to influence the policy, a formal consultation exercise should not be launched"

The informality of the process is confirmed by the survey itself:

Ø the front page states: "The results from this survey will be reviewed by the Chief Technology Officers Council and their conclusions will be published on the Cabinet Office website in the Autumn. Bear with us while we work through your suggestions and please understand that we’ll have to prioritise our responses."

Ø the last page states: " Thank you for taking time to complete this survey. We'll take your feedback on board and consider it in the development of a new Technical Standards Catalogue for the UK public sector."

We are concerned that this survey includes proposals to amend what appeared to be settled policy on open standards:

ñ The survey redefines the status of the definition of an "open standard" provided by OGC in January 2011 [4] as part of its policy and standards framework [5] . Having redefined the definition as a draft the survey invites participants to comment on it.

The OGC definition of an open standard provides a basis for what the government considers a valid standards reference.

We are concerned that the survey does not define "common standard". Without a definition of common standard no mechanism is provided for determining in what manner common standards differ from open standards.

ñ The recently published Government ICT Strategy [6] , in the section "Interoperability enabled by open standards" contains no mention of open standards instead stating:

"The use of common standards can make ICT solutions fully interoperable to allow for reuse, sharing and scalability across organisational boundaries into local delivery chains"

We are concerned that the survey reflects a seeming failure to understand the importance of careful referencing of standards:

ñ this failure can be highlighted by considering the treatment of two International Standards - informally known as "Open Document Format (ODF)" and "Office Open XML (OOXML)".

The first is cited using a dated reference ("ISO/IEC 26300:2006"), while the second has an undated reference ("ISO/IEC 29500"). ISO convention means that the first cites a specific version while the undated second automatically binds the reference to the latest version.

We are concerned that the survey proposes to include a number of file formats that are proprietary and have never been standardised including:

.doc, .ppt, .xls, .rtf, .nsf, .gif (there are others)

We are concerned that the survey makes reference to draft standards that are far from ready for use while failing to properly reference more appropriate standards:

ñ the survey includes HTML 5 which is a W3C project expected to lead to a W3C recommendation [7] by 2014 or 2015. At present it is simply a partial draft. HTML 4.01 and XHTML 1.0 recommendations from W3C are in wide adoption (in preference to the ISO standard).

We are concerned that the survey seemingly confuses applications with the underlying file format:

ñ Portable Document Format (.pdf) is an ISO standard (currently ISO 32000:2008). Acrobat Viewer is just one proprietary software application for reading .pdf files, there are many alternatives. [8]

We are concerned that this survey appears to have been prepared without proper consideration of cross-cutting policy relating to web content and accessibility:

ñ The survey proposes using W3C Web Content Accessibility Guidelines (WCAG) for web content. WCAG 2.0 is a W3C recommendation in December 2008 [9] so it is unclear why WCAG 1.0 has been included.

ñ The survey makes no mention of BS 8878:2010 [10] which referenced the government’s e-Accessibility Action Plan [11] (itself updated as recently as January 2011) . The plan which provides a basis for developing accessible online services including recommendations for:

Ø i nvolving disabled people in the development process and using automated tools to assist with accessibility testing ;

Ø t he management of the guidance and process for upholding existing accessibility guidelines and specifications.

ñ The survey points to the Central Office of Information Standards and Guidelines [12] which hasn't been updated either to mention the e-Accessibility action plan or the Equality Act 2010 [13] managed by the Government Equalities Office . [14]

April 2011


[1] http://www.cabinetoffice.gov.uk/content/uk-government-open-standards-survey

[2] http://www.bis.gov.uk/policies/better-regulation/consultation-guidance

[3] http://www.bis.gov.uk/policies/better-regulation/consultation-guidance/when-to-consult

[4] http://www.ogc.gov.uk/documents/PPN_3_11_Open_Standards.pdf

[5] http://www.ogc.gov.uk/procurement_policy_and_application_of_eu_rules_procurement_policy_notes.asp

[6] http://www.cabinetoffice.gov.uk/content/government-ict-strategy

[7] such recommendations would meet the definition of “open standard” in OGC PPN 3/11 reference supra

[8] http://en.wikipedia.org/wiki/List_of_PDF_software

[9] http://www.w3.org/TR/WCAG20/

[10] http://shop.bsigroup.com/ProductDetail/?pid=000000000030180388

[11] http://www.culture.gov.uk/publications/7798.aspx

[12] http://coi.gov.uk/guidance.php?page=188

[13] http://www.legislation.gov.uk/ukpga/2010/15/contents

[14] http://www.equalities.gov.uk/equality_act_2010.aspx