Background with rationale
It is commonplace in policy discussions concerning administrative data linkage to presuppose that the data referred to is government services data. But this is not always the case. Much of the data public services hold is now collected via intermediaries, such as Non-Government Organisations, operating under service contracts with one or multiple government departments. Nor are these the only administrative data holdings applicable to clients of government services. There are also vast private administrative data holdings – including utility data, and consumer behaviour data.
Creating and amending legislation that governs public service practices in this domain is increasingly made complex when private companies partner with governments agencies on policy development and evaluation work.
Understanding the concept of public data for public good in light of this expanded sense of administrative data opens the door to deeper questions about the role linked data can play in government decision making.
The paper problematizes how legislation governing the linking of government administrative data is scoped and discusses how public service work can be affected by the opaque communication networks that increasingly span the public-private sector divide.
After contextualising the challenge of legislating for administrative data linkage in the current work of the Office of the National Data Commissioner (ONDC) in Australia, this paper tests aspects of the proposed legislation against the extent to which it permits the possibility of ‘data laundering’.
The presentation demonstrates the need for greater sophistication in the specification of data linkage and sharing legislation in service of the public good.
This paper indicates that contemporary practices governing the linkage of government administrative data holdings is porous to the aims of extra-governmental organisations and may benefit by better incorporating legislative structures that govern private analytical services entities.