ADR UK responds to the third consultation on UK National Data Strategy

This consultation sought the input of organisations and individuals to inform the development of ‘a pro-growth and innovation-friendly data protection regime that underpins the trustworthy use of data’.

The ADR UK partnership has responded to the Department for Digital, Culture, Media & Sport (DCMS) consultation on the UK National Data Strategy, ‘Data: A  new direction’.

This consultation, which opened in September alongside the publication of the Strategy and closed on 19 November, sought the input of organisations and individuals to inform the development of ‘a pro-growth and innovation-friendly data protection regime that underpins the trustworthy use of data’.

Our response focused on the first chapter of the consultation, ‘Reducing barriers to responsible innovation’.  Our comments focused topics  most relevant to ADR UK, including  research purposes, legitimate interests and anonymisation. Our response emphasised a the following key points:

  1. It is important that the public are engaged in this new direction for data in a meaningful way. The overall approach of the UK National Data Strategy would be strengthened by wider public engagement, participation, and communication.
  2. The public good arising from research using personal data and data linkage should be made more transparent. The legal underpinning of data sharing for research or statistics is already relatively clear; it is the social contract with the public that needs to be earned and maintained, irrespective of what we can do legally.
  3. The National Data Strategy should explicitly cover functional anonymisation. This relates to data being stored and used for research and statistics according to the ‘Five Safes’ (e.g., de-identified and in trusted research environments by qualified researchers) is accessed without explicit individual-level consent.

While we welcome efforts to provide clarity and reduce uncertainty in this complex area, we emphasise that the data protection regime needs to work for people as well as for business, economic growth, and innovation. This was highlighted in the Information Commissioner’s Office response, which we endorse. This includes increasing engagement and transparency about the public good of data used in research.

Read our full response to find out more about ADR UK’s thoughts on the published NDS Data: a new direction consultation.

Read our past responses to the second and initial National Data Strategy.

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