Data and Intelligence Network: ethics framework

Sets out the principles our network will adhere to when running data and intelligence projects so we can deliver insight on the pandemic and wider data issues at pace while keeping ethics at the forefront of our thinking.


Ways of Working

The D&IN is dynamic and changing to adapt to the needs of the emergency. The aim is to provide cross-sectoral leadership and governance that will set out its operating model including provisions for governance and information governance; setting out where responsibilities lie for decisions and the implications of those decisions. It will require secure use of technology, transparent and effective information governance and, perhaps most important, will identify and secure people with the range of skills required to undertake the work effectively and at pace. This includes the skills to address the moral or ethical dilemmas that will face us, particularly if we operate at pace and do so while protecting people's human rights and personal freedoms and recognising the unequal impact of Covid-19.

Inevitably developing a more collaborative way of working is iterative; with this Framework as one piece of the governance framework that will be developed by the D&IN. It will be important that those people with the skills and understanding of using data for public benefit are actively involved at all levels of the DIN's governance. For those people who are providing ethical input and are operating at speed the processes need to be in place to provide sufficient and clear information on which to base ethical advice, sufficiently early in the process to be able to properly influence the design of the project, problem or bid. That means considering ethics at the inception of a project and having access to advice in the 'engine room' both of the problem owner and of the D&IN, in order for that advice to be able to influence the framing of the problem and solution.

As the D&IN is operationalised a workbook will be developed to provide step-by-step guidance for the use of the Ethics Framework within that wider operating model. But it is important to stress that this is not a tick-box exercise. The ethics advisers involved need to have experience, confidence and competence along with a clear authority to offer effective, timely and transparent ethical advice. So, while ethics is and should be closely linked to information governance there will be times when the ethical and moral questions will determine the scale or scope of project work or whether or not the relationship between the public and private interest is being properly taken into account. They therefore need to be sufficiently independent to provide clear advice. During the initial phases of the D&IN set up this advice is being provided by members of the D&IN with knowledge in this area. As the D&IN moves into effective operation there needs to be dedicated ethical advice available to the D&IN centrally and to the project teams. The D&IN is made up of people in a range of organisations, it is also worth noting that these are also likely to be the organisations who will be owners of the problems or delivery agents. Which means that the identification of roles and responsibilities in both the governance of the D&IN itself and in each of the projects or programmes delivered by the D&IN is vital, including having access to ethical expertise. The existing compliance structures like the Public Benefit and Privacy Panel have been revised to take account of the pandemic and will continue to operate, overseeing the granting of permission for the use of data and intelligence Transparency of these arrangements will be important for public trust as will clear external monitoring and scrutiny.

The D&IN will identify priority projects requiring the use of combined data, identify the analytical capacity and secure location for the work to be carried out and ensure the safe use of the outputs. It will maintain a dynamic catalogue of data sources.

Contact

Email: data.intelligencenetwork@gov.scot

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