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Finland

Open Data and AI Policy (FI0033)

Overview

At-a-Glance

Action Plan: Finland Action Plan 2019-2023

Action Plan Cycle: 2019

Status: Active

Institutions

Lead Institution: Ministry of Finance

Support Institution(s): NA

Policy Areas

Access to Information, Automated Decision-Making, Digital Governance, E-Government, Open Data

IRM Review

IRM Report: Finland Design Report 2019-2023, Finland Implementation Report 2017-2019

Starred: Pending IRM Review

Early Results: Pending IRM Review

Design i

Verifiable: Yes

Relevant to OGP Values: Access to Information

Potential Impact:

Implementation i

Completion: Pending IRM Review

Description

The commitment and measures on open data contribute in particular to the OGP initiatives of transparency and technology & innovation. The measures are in line with the Act on Data Management in Public Administration, data policies and implementation thereof.

Open data:
The public sector promotes government openness by opening public interfaces if there are no specific reasons to keep them restricted. The process will prioritise the most influential data resources. Easy-to-use, developer-friendly interfaces that follow the outlines of standard architecture will be developed to access public administration data resources. The data available on the interfaces will be recorded using standard procedures into a machine-readable and -interpretable format in order to make it easier to benefit from. The guidance needed in order to open the data and create the interfaces will be provided. A successful user experience of the data and its easy accessibility will lower the threshold of using the data and increase its usage. As a result, data producers will be more motivated to improve the quality and usability of data and data resources. The objective of this is to achieve a virtuous circle in which the quality of data will be improved and it will provide benefits, and the benefits of open data will spread far and wide inside the society, also when companies join to become producers of open data. These measures will acknowledge the outlines and development measures of European Union within this theme, including the Open Data Directive (EU/2019/1024), also known as the PSI directive.

The requirements concerning data protection and the data confidentiality regulation will be taken into account when plans are made for opening up data.

The project will be completed in a cross-administrative effort of cooperation, so that the cumulation of data will not put the data security of public administration at risk.
Quality criteria: Quality criteria intended to facilitate the utilisation of data will be prepared.
Quality improvement measures following the quality criteria will be primarily applied to the most significant data resources in the data opening process. Setting quality criteria and the extent of their validity will be planned to make up part of putting the quality criteria into practice.

Ethical guidelines: A general set of guidelines on the ethical use of artificial intelligence will be prepared in order to ensure that the artificial intelligence will not utilise directly or indirectly discriminatory operational models in the AI systems.
The measures to open public sector data will promote a data and AI policy that is ethically, financially and socially sustainable. Meta data that contributes to data resources management of high quality will also contribute to the creation of unified information resources required by machine-learning and AI in our linguistic area and, subsequently, the realisation of linguistic rights in an indirect manner.

Special groups will be consulted and the standards laid down in international human rights conventions and UN recommendations on the ethics of AI as well as data security questions will be acknowledged as a part of the preparatory process.

IRM Midterm Status Summary

4. Open Data

Main Objective

“The commitment and measures on open data contribute in particular to the OGP initiatives of transparency and technology & innovation. The measures are in line with the Act on Data Management in Public Administration, data policies and implementation thereof.”

Milestones

  • Open data: The public sector promotes government openness by opening public interfaces if there are no specific reasons to keep them restricted. The process will prioritize the most influential data resources. Easy-to-use, developer-friendly interfaces that follow the outlines of standard architecture will be developed to access public administration data resources. The data available on the interfaces will be recorded using standard procedures into a machine-readable and -interpretable format in order to make it easier to benefit from. The guidance needed in order to open the data and create the interfaces will be provided.
  • Quality criteria: Quality criteria intended to facilitate the utilisation of data will be prepared. Quality improvement measures following the quality criteria will be primarily applied to the most significant data resources in the data opening process. Setting quality criteria and the extent of their validity will be planned to make up part of putting the quality criteria into practice.
  • Ethical guidelines: A general set of guidelines on the ethical use of artificial intelligence will be prepared in order to ensure that the artificial intelligence will not utilise directly or indirectly discriminatory operational models in the AI systems. The measures to open public sector data will promote a data and AI policy that is ethically, financially and socially sustainable. Metadata that contributes to data resources management of high quality will also contribute to the creation of unified information resources required by machine-learning and AI in our linguistic area and, subsequently, the realisation of linguistic rights in an indirect manner. Special groups will be consulted and the standards laid down in international human rights conventions and UN recommendations on the ethics of AI as well as data security questions will be acknowledged as a part of the preparatory process.

Editorial Note: For the complete text of this commitment, please see Finland’s action plan at https://avoinhallinto.fi/assets/files/2019/09/ENGLANTI_Avoin-hallinto_IV_toimintaohjelma_FINAL_240919-1.pdf.


Commitment Analysis

This commitment seeks to enhance public access to information by improving the quality and usability of open data. It also aims to foster the ethical use of artificial intelligence (AI) systems and prevent the use of discriminatory operational models in AI systems.

Open data has been an ongoing priority in Finland’s OGP action plans. During previous action plans, Finland launched a national open data portal (avoindata.fi) and developed guidelines for open data publication and use, as well as open data capabilities in new IT systems. As part of the current action plan, the government is starting a new open data project (2020-2022), which involves, among other goals, formulating strategic objectives for opening up and using public data, developing quality criteria for open data, and establishing an interoperability platform along with tools to support the semantic interoperability of open data. [57] As the commitment focuses on releasing more and better-quality public data, it is relevant to the OGP value of access to information.

Finland generally performs well on open data. The Act on the Openness of Government Activities [58] lays out the basic legal framework for publishing government data and further measures have been taken through government open data programs. During the third action plan (2017-2019), the publication of high-value open datasets, such as public procurement data, improved government openness in a major way. [59] The third action plan also sought to expand the access to information principle to publicly funded enterprises, but the implementation was delayed due to legal obstacles. [60] However, the Ministry of Justice published a report outlining possible models for amending the law [61] and the government program adopted in December 2019 envisages continuing to broaden the scope of the law. The new EU Open Data Directive, which Finland needs to transpose to its national law by 2021, also encourages EU member states to extend open data publication requirements to public undertakings and private companies providing services of general interest. [62]

Finland’s national open data portal currently has more than 1700 datasets from 793 publishers [63] and 6700 monthly visits. [64] Stakeholders say the portal works very well, [65] although some organizations prefer to publish data on their own repositories. [66] The European Data Portal’s (EDP) 2019 Open Data Maturity survey ranks Finland 9th in Europe. [67] However, in the 2019 OECD’s OURdata index, Finland’s scores decreased in data availability and government support to reuse. According to the OECD, this decrease was due to a reduction in stakeholder engagement and lack of government’s attention to fostering data reuse outside the public sector. [68] Teemu Ropponen from Open Knowledge Finland (OKFI) notes that one of the key problems is the lack of continuous dialogue mechanisms between open data providers and users, which would help data providers better understand the value of their data and adapt their data publication efforts to users’ needs. [69]

Finland also has room for improvement regarding accessibility of key datasets. A 2018 report by Transparency International Latvia and OKFI found that only five out of 10 key anti-corruption datasets could be accessed through the central open data portal. [70] In addition to lobbying data, which will be addressed in Commitment 3, the public currently lacks access to beneficial ownership data. [71] Furthermore, the government has not proactively opened all relevant data on the COVID-19 pandemic. OKFI raised the issue and filed several Freedom of Information requests asking the National Institute for Health and Welfare (THL) to publish the source codes of the models the government used for forecasting the progress of the pandemic in Finland. [72] THL eventually only published the models after the Chancellor of Justice [73] began investigating the issue [74] and the Prime Minister called for respecting the principle of openness in publishing data related to government decisions. [75] However, THL rejected the FoI requests to publish the source code of the models. [76] According to Teemu Ropponen (OKFI), the crisis has revealed the need to increase government officials’ awareness of the benefits of government openness. Due to the adoption of the General Data Protection Regulation in 2018, public officials have generally become more cautious about opening data for fears of breaching privacy regulations. [77]

If implemented as planned, this commitment could improve the quality and accessibility of datasets with high economic and societal value. The government plans a comprehensive package of measures, from agreeing on common strategic objectives and quality criteria to providing guidelines and tools for enabling data interoperability. The new EU Open Data Directive will likely strengthen the impact of these activities, as it involves defining high-value datasets at the EU level by 2021, which all member states need to publish as open data. The data categories defined as having high value also include information on company ownership. This may give an impetus to the Finnish Government to also open beneficial ownership data. According to Riitta Autere from the Ministry of Finance, the government will engage stakeholders in defining additional priority datasets at the national level to promote the use of public data in decision making, business, research, and civic engagement. [78] However, the current plans do not include any activities to promote the actual use of the published data or a dialogue between data providers and users. Since stakeholders see the lack of two-way communication as a major gap, the overall impact of this commitment on access to information will likely remain minor. To fill this gap, the government could consider implementing the Helsinki region’s “Helsinki Loves Developers” (Hel<3Dev) model at the central government level. Hel<3Dev is an initiative providing an open platform for discussion and co-creation between data providers and users, comprising a dedicated website, Facebook discussion group, and regular meetups. [79] OKFI highlights this as a successful case of bringing data holders and users together around shared goals. [80]

Regarding the responsible use of AI, the Ministry of Finance initially planned to prepare guidelines to support the ethical use of AI solutions. [81] Although existing law protects equality and non-discrimination, [82] the government’s first AI Program [83] in 2017 produced a report which called for the adoption of ethical guidelines for developing algorithms and architectures to avoid biases and adverse effects on human dignity and equality. [84] Due to the COVID-19 crisis, the ministry has postponed development of the ethical guidelines for the time being. [85]

The Finnish Center for Artificial Intelligence (FCAI) Society, an interdisciplinary group of experts on AI, considers the adoption of ethical guidelines as useful but not sufficient to ensure the ethical development of AI. [86] They see a need for adopting new methods of data collection and use, provision of more high-quality open government data, revision of regulations, funding for long-term interdisciplinary research on the risks of AI, better AI awareness among government employees, and involvement of the public in discussions around AI. According to the FCAI Society, it is important to involve critical perspectives from civil society in the regulatory design. To enable this, the government should provide CSOs with the necessary resources to participate. Moreover, the FCAI Society believes a more balanced view of AI is needed: while AI entails risks, it could also be an enabler of open government goals such as understandability, participation, and transparency, and could help detect discriminatory practices. The Society, therefore, recommends the government to provide CSOs access to high-quality open government data and tools to use the data for developing AI solutions. They also recommend the government investigates how to provide access to background data behind algorithm-based decisions. In further work on AI ethics, the government could consult the ethical guidelines of the EU High-Level Expert Group on Artificial Intelligence [87] and follow a sandboxing approach to test ideas before going forward. [88]

  1. describing an administrative issue or tool? (E.g., “Misallocation of welfare funds” is more helpful than “lacking a website.”)
  2. Status quo: What is the status quo of the policy issue at the beginning of an action plan? (E.g., “26 percent of judicial corruption complaints are not processed currently.”)
  3. Change: Rather than stating intermediary outputs, what is the targeted behavior change that is expected from the commitment’s implementation? (E.g., “Doubling response rates to information requests” is a stronger goal than “publishing a protocol for response.”)

Starred commitments

One measure, the “starred commitment” (✪), deserves further explanation due to its interest to readers and usefulness for encouraging a race to the top among OGP-participating countries/entities. Starred commitments are considered exemplary OGP commitments. To receive a star, a commitment must meet several criteria.

  • Potential star: the commitment’s design should be verifiable, relevant to OGP values, and have transformative potential impact.
  • The government must make significant progress on this commitment during the action plan implementation period, receiving an assessment of substantial or complete

These variables are assessed at the end of the action plan cycle in the country’s IRM Implementation Report.

[57] Ministry of Finance, Opening up and using public data, https://vm.fi/en/opening-up-and-using-public-data
[60] Ibid.
[62] Directive (EU) 2019/1024 of the European Union and of the Council of 20 June 2019 on open data and the re-use of public sector information, http://data.europa.eu/eli/dir/2019/1024/oj
[63] Dataset counter, https://www.avoindata.fi/fi, as of 26 April 2020.
[65] Interview with Teemu Ropponen, Open Knowledge Finland, 2 June 2020.
[66] Email from Jouni Tuomisto, Open Knowledge Finland, 19 May 2020.
[68] OECD Open, Useful and Re-usable data (OURdata) Index 2019, http://www.oecd.org/gov/digital-government/ourdata-index-policy-paper-2020.pdf
[69] Interview with Teemu Ropponen, Open Knowledge Finland, 2 June 2020.
[70] Transparency International Latvia, Open Knowledge Finland (2018), Open data and the fight against corruption in Latvia, Sweden and Finland: FINLAND, https://delna.lv/wp-content/uploads/2018/11/OD4AC_FI_Final6.pdf
[71] The report also found gaps in public procurement data but these seem to have been solved recently. Public procurement data on the national portal, https://www.avoindata.fi/data/fi/dataset/tutkihankintoja-data and analytical visualizations, https://openprocurement.fi
[72] Interview with Teemu Ropponen, Open Knowledge Finland, 2 June 2020.
[73] The Chancellor of Justice supervises that authorities, civil servants, and bodies performing public tasks comply with the law and fulfil their assigned obligations. See https://www.okv.fi/en/ for more information.
[74] Helsingin Sanomat, Oikeuskansleri pyytää selvitystä korona­tietojen panttaamisesta – ”Perus­lähtökohtana on viranomais­toiminnan avoimuus”, 14 May 2020, https://www.hs.fi/politiikka/art-2000006507477.html
[75] Helsingin Sanomat, Pääministeri Marin kehottaa luovuttamaan korona­koordinaatio­ryhmän asiakirjoja – STT kertoi aiemmin, että suuri osa tiedoista oli salattu, 23 May 2020, https://www.hs.fi/politiikka/art-2000006516664.html
[77] Interview with Teemu Ropponen, Open Knowledge Finland, 2 June 2020; email from Jouni Tuomisto, Open Knowledge Finland, 19 May 2020.
[78] Email from Riitta Autere, Ministry of Finance, 1 June 2020.
[79] More information on the initiative is available on the Helsinki Region Infoshare website, https://hri.fi/en_gb/support/how-to-use-data/helsinki-loves-developers/
[80] Interview with Teemu Ropponen, Open Knowledge Finland, 2 June 2020.
[82] Emails from the Ethical Board of FCAI Society, 8 May 2020, and Riitta Autere, Ministry of Finance, 1 June 2020.
[84] Government report on information policy and artificial intelligence (2018), https://vm.fi/documents/10623/7768305/VM_Tiepo_selonteko_070219_ENG_WEB.pdf
[85] Email from Riitta Autere, Ministry of Finance, 1 June 2020.
[86] Email from the Ethical Board of FCAI Society, 8 May 2020.
[87] High-Level Expert Group on Artificial Intelligence, Ethics Guidelines for Trustworthy AI (2019), https://ec.europa.eu/newsroom/dae/document.cfm?doc_id=60419
[88] Email from the Ethical Board of FCAI Society, 8 May 2020.

Commitments

  1. Improving Understandability and Inclusion of Government Information

    FI0030, 2019, Capacity Building

  2. Open Government Strategy

    FI0031, 2019, Capacity Building

  3. Register of Government Decision-Making

    FI0032, 2019, Anti-Corruption

  4. Open Data and AI Policy

    FI0033, 2019, Access to Information

  5. Supporting Everyone’s Possibility to Participate.

    FI0023, 2017, E-Government

  6. Clear Government Reforms and Services

    FI0024, 2017, Fiscal Openness

  7. Access to Information on Incorporated Public Services

    FI0025, 2017, Access to Information

  8. Access to Information Knowledge in the Public Administration

    FI0026, 2017, Access to Information

  9. Publishing State Procurement Data to Citizens

    FI0027, 2017, Access to Information

  10. Regional Reform Information

    FI0028, 2017, Infrastructure & Transport

  11. Training Regional Administration in Open Government Principles

    FI0029, 2017, Capacity Building

  12. Clear Administration

    FI0019, 2015, E-Government

  13. Government as an Enabler

    FI0020, 2015, Access to Information

  14. Open Procedures

    FI0021, 2015, Access to Information

  15. Engage Children, Youth, Elderly

    FI0022, 2015, Public Participation

  16. Enhancing the Openness of Preparatory Processes

    FI0001, 2013, E-Government

  17. Emphasizing Dialogue Skills in the Job Descriptions of Civil Servants

    FI0002, 2013, Capacity Building

  18. Strengthening Proactive Publishing and Communication

    FI0003, 2013, Capacity Building

  19. Promoting Participatory Budgeting

    FI0004, 2013, Fiscal Openness

  20. Increasing Openness and Customer Orientation in ICT and e-Services Development

    FI0005, 2013, E-Government

  21. Increasing the Number of Open and Online Meetings

    FI0006, 2013, E-Government

  22. Standard Language Titles and Resumes Will Be Drafted of the Government Proposals.

    FI0007, 2013, Capacity Building

  23. Visualization of Decisions

    FI0008, 2013, E-Government

  24. Training Will Be Organised for Civil Servants in Use of Clear Language and Plain Language In- Cluding Committing to Use of Terms Already Known.

    FI0009, 2013, Capacity Building

  25. The Comprehensibility of the Texts Produced by Public Administration Will Be Tested To- Gether with Citizens and Service Users.

    FI0010, 2013, Capacity Building

  26. Standardizing and Clarifying the Terms and Concepts Used in Public Administration and Ser- Vice Production.

    FI0011, 2013, Capacity Building

  27. The Comprehensibility of Customer Letters and Decisions Will Be Enhanced, Especially When Using Standard Texts.

    FI0012, 2013, Capacity Building

  28. Opening and Publishing New Data and Changing Existing Open Data Into a Machine- Readable Form.

    FI0013, 2013, Access to Information

  29. Clear Terms for Use of for Open Data and Knowledge

    FI0014, 2013, Access to Information

  30. Strengthening Skills Needed to Understand Combining Privacy and Open Data and Strength- Ening the Citizen’S Right to His/Her Own Personal Information “The Right to Be Anonymous”

    FI0015, 2013, Access to Information

  31. Tearing Down Barriers of Action of the Civil Society

    FI0016, 2013, Capacity Building

  32. The Proactive Presence and Accessibility of Civil Servants

    FI0017, 2013, Capacity Building

  33. Providing Tools and Training to Organizations

    FI0018, 2013, Capacity Building

Open Government Partnership