UK Government Open Standards Consultation – CETIS Response

Earlier this year the UK Government Cabinet Office published what I thought was a rather good set of proposals for the role of open standards in government IT. They describe it as a “formal public consultation on the definition and mandation of open standards for software interoperability, data and document formats in government IT.” There are naturally points where we have critical comments but the direction of travel is broadly one that CETIS supports. The topic of mandation is, however, one to be approached with a great deal of caution in our view.

Our full response, which should be read alongside the consultation document (which includes the questions), is available for your information.

The consultation has now been extended to June 4th 2012 following the revelation of a conflict of interest; the chair of a public consultation meeting in April was found to be also working for Microsoft. This is the latest in a long series of concerns about Microsoft lobbying reported in Computer Weekly and elsewhere. I am actually encouraged by the Cabinet Office response both to FoI requests linked to meetings with Microsoft and to this recent revelation; they do seem to be trying to do the right thing.

New Draft British Standard – Exchanging Course Related Information

The two parts of a draft British Standard (BS), “BS 8581 – Exchanging course related information – Course advertising profile” have recently been released for public comment on the British Standard Institute “Draft Review” website.

This standard is heavily based on the XCRI-CAP 1.2 specification, which has been developed and piloted over the past few years with support from JISC and CETIS, and would create a British Standard that is consistent with the European Standard “Metadata for Learning Opportunities – Advertising” (EN 15982, also to be adopted as BS) but extends it and provides more detail suited to UK application.

The two parts for public review, which closes on April 30th 2012, are:

Registration is required to access the drafts and comment.

Background information and details of implementations of XCRI may be found on the XCRI-CAP website.

Information Principles for the Public Sector – the Case of Principle 4

In December 2011, Version 1.0 of “Information Principles for the UK Public Sector” (pdf) was published by the Cabinet Office. The principles have been endorsed by both the CIO and CTO councils within government. What surprised me is how good this document is.

The approach taken recognises that the principles will be implemented in diverse ways according to the context. It is well written and full of material which strikes me as being widely applicable (not just to government bodies) in addition to containing a number of points that indicate a progressive attitude to information. In particular, “Principle 4 – Information is Standardised and Linkable”, gives me cause to nod with approval.

The standards message is not, of course, a new one for The Government; it is the inclusion of “linkable” in a principle that will be applied across government activities which is. This is not simply “linked data is cool” expressed in Civil Service Speak; the principle is deeper than that and speaks to me of a possible paradigm shift in the way [collected] data is understood.

Under Implications for Information Strategy, it recommends “a framework for linking information is established” and goes on to say:

“Aspects to consider include:

  • Unambiguous identification of items (eg using authoritative reference data, or URIs)
  • Classifying items and the relationships between them.
  • Linking of items (eg potentially using the open standard web mechanisms governed by the W3C)

Consideration should be given to both internal linkages to other information sources within the organisation, and also to external linkages to other information sources across government.”

In essence, I see this as being indicative of a shift away from conceiving of data as “stuff in databases” and towards “distributed data on the network”. I see this as being a Really Big Deal and significantly more sophisticated than the piecemeal publication of data seen so far (even on, which remains an important innovation).

By itself, of course, Principle 4 achieves nothing but two recent events and the Principle add up to suggest that this is not just a pipe-dream.

The first event, which is a culmination of several priors, was the initiation of the in-elegantly, but accurately. named “Interim Regulatory Partnership Group: Project B, Redesigning the higher education data and information landscape”. While this project is only at present deliberating on a feasibility report, a bit of imagination of where this might go with some inspiration from the Reports and Documents (e.g. the “HE Information Landscape Study“, pdf) leads towards making more use of distributed collected data. Maybe I am making a leap too far but a combination of reducing data collection burden with principles of collect-once-use-many-times inevitably leads to linking data between (among others) UCAS, the Student Loans Company and HESA since it is inconceivable to me that we would not  have a multi-party landscape.

The second, more recent, event was the occasion of a discussion with a member of the Technical Support Service of the Information Standards Board for education skills and children’s services (ISB TSS) from which I understand the intention is to assign URIs to entities in the standards the ISB TSS creates. Only a small step but…

My take-home message on all of this: nothing will happen very quickly but the gradual permeation of an understanding of the implications of distributed data on the network will make possible conversations, decisions and interventions that are currently rather difficult and the drivers behind Project B are also drivers that will, I hope, accelerate this process.

UK Government Open Standards Survey

The Government Chief Technology Officers’ Council has recently begun an online survey of open standards.

This covers views on the meaning of “open standard” as well as relevance of specific standards.

Obviously, CETIS people will be responding but I’d like to encourage everyone with an interest in open standards to do so. I will be keeping an eye out for what might have been missed from the survey. Be warned, however, it might take some time if you have interests spanning several standardisation areas.

British Standards in ICT for Learning Education and Training – What of it?

The British Standards Institute committee IST/43 – ICT for Learning, Education and Training (“LET”) – has been in existence for about 10 years. What does IST/43 do? What follows is my response as an individual who happens to be chair of IST/43.

In the first few years, IST/43 had a number of sub-groups (“panels”) involved in the creation of British Standards. It was a time when there was a lot of activity worldwide and many new groups created. What became clear to many people in IST/43 was that a much larger number of stakeholders had to be marshalled in order to achieve sucess than we had thought. In essence: we generally have to work at international scale if focussed on standards specific to LET and otherwise appropriate generic web standards. At present there are no standards under development in IST/43 and all previous panels have been disbanded.

So: where does this leave IST/43? In addition to creating British Standards, IST/43 is the shadow committee for European and international standardisation in ICT for Learning, Education and Training. These are known as TC353 and SC36 respectively. IST/43 effectively controls the vote at these committees on behalf of the United Kingdom. Full European Standards are called “European Norms” (ENs) and automatically become national standards. International standards created in SC36 do not automatically become British Standards; IST/43 decides one way or the other.

I will continue with a summary of current work programmes in TC353 (European) and SC36 (international) and indicate for each work item what the current position of IST/43 is. If you are interested in any of these areas, whether agreeing or disagreeing with the position that IST/43 takes as the “UK position”, you can nominate yourself for membership of the committee (email addresses at the end). Strictly speaking, it is an organisation that nominates; committee members represent that organisation. Comments below on the members of the committee should generally be understood to be representative of nominating organisations.


Work item:

BS EN 15943 Curriculum Exchange Format (CEF) Data Model


This work, which allows for the exchange of subjects/topics covered in a curriculum, originated from work undertaken in the UK with support from BECTa and has had active support from IST/43 during its standardisation. Voting on the final standard is underway (Feb 2011).

Work item:

BS EN 15981 European Learner Mobility Model


Members IST/43 and others in their nominating organisations have been significant contributors to this EN, which matches the requirements of the Bologna Process and European Union treaties on recognition of qualifications across the EU. A formal vote on the final draft standard will end in February 2011.

Work item:

BS EN 15982 Metadata for Learning Opportunities (MLO) – Advertising


Members IST/43 and others in their nominating organisations have been significant contributors to this EN, which harmonises a number of nationally-developed specifications for exchanging course information (XCRI in the UK). A final draft has recently been submitted to the secretariat of TC353 and should be out for ballot later in 2011.


There are three broad classes of activity in SC36: those that create full International Standards (denoted “IS”), those that produce lower-status Technical Reports (denoted “TR”) and study periods. Study periods are not enumerated below.

WG1 Vocabulary

Work items:

ISO/IEC 2382-36:2008/Cor.1:2010(E)
ISO/IEC 2382-36:2008/Amd.1:2010(E)


ISO/IEC 2382-36 is “Information technology — Vocabulary — Part 36: Learning, education and training”. These are corrections and amendments. There is little interest from IST/43 but a “yes” was registered at the last vote.

WG2 Collaborative technology

Work item:

ISO/IEC 19778-4 (TR), Collaborative technology – Collaborative workplace – Part 4: User guide for implementing, facilitating and improving collaborative applications


There is no participation from IST/43.

WG3 Learner information

Work item:

ISO/IEC 29187-1 (IS), Identification of Privacy Protection requirements pertaining to Learning, Education and Training (ITLET) – Part 1


There is no participation from IST/43.

Work items:

ISO/IEC 20006-1 (IS), Information Model for Competency — Part 1: Competency General Framework and Information Model
ISO/IEC 20006-2 (IS), Information Model for Competency — Part 2: Proficiency Information Model
ISO/IEC 20006-3 (TR), Information Model for Competency — Part 3: Guidelines for the Aggregation of Competency Information and Data

ISO/IEC 24763 (TR), Conceptual Reference Model for Competencies and Related Objects

ISO/IEC 20013 (TR), e-Portfolio Reference Model


This collection of work items is of interest to IST/43 and has attracted new committee members during the last year or so. Substantial engagement and commenting on drafts has occurred and it has been proposed to convene a panel under IST/43 to coordinate UK engagement and make voting recommendations to IST/43.

The Conceptual Reference Model is near completion but the other work items are in the earlier stages of drafting. At present there are areas where consensus has not yet been reached in addition to a substantial amount of work being required in drafting and editorial.

Work items:

ISO/IEC 29140-1 (TR), Nomadicity and Mobility Part 1 – Part 1: Nomadicity Reference Model
ISO/IEC 29140-2 (TR), Nomadicity and Mobility – Part 2 – Learner Information Model for Mobile Learning


There is no participation from IST/43.

WG4 Management and delivery of learning, education and training

Work items:

ISO/IEC 19788-1 (IS), Metadata for Learning Resources – Part 1: Framework
ISO/IEC 19788-2 (IS), Metadata for Learning Resources – Part 2: Dublin Core Elements
ISO/IEC 19788-3 (IS), Metadata for Learning Resources – Part 3: Basic Application Profile
ISO/IEC 19788-4 (IS), Metadata for Learning Resources – Part 4: Technical Elements
ISO/IEC 19788-5 (IS), Metadata for Learning Resources – Part 5: Educational Elements
ISO/IEC 19788-6 (IS), Metadata for Learning Resources – Part 6: Availability, Distribution, and Intellectual Property Elements


The essence of “Metadata for Learning Resources” (MLR) is an international standard that over-arches Dublin Core metadata (which is already an ISO standard in an older version than the Dublin Core Metadata Initiative currently recommends) and IEEE LOM (Learning Object Metadata).

Opinions on the MLR work vary in the UK and it has been the subject of many discussions over the last few years. A series of comments and criticisms have been submitted to the working group on part 1 and dealt with to the satisfaction of IST/43 such that a “yes” vote was registered for the final vote on part 1. Parts 2 and 3 are at earlier stages and have also attracted recent “yes” votes (although “abstain” has been registered in the past when no views were presented to IST/43). It does not follow that “yes” votes will be registered for all parts.

Work items:

ISO/IEC 12785-2 (IS),  Content Packaging – Part 2: XML Binding
ISO/IEC 12785-3 (IS),  Content Packaging – Part 3: Best Practice and Implementation Guide


This work is effectively standardising IMS Content Packaging. IST/43 supports the work and has adopted Part 1 (the information model) as a British Standard (BS ISO/IEC 12785-1:2009). Extended comments have been submitted into the working group.

WG5 Quality assurance and descriptive frameworks

Work items:

ISO/IEC 19796-1 (IS), Quality Management, Assurance, and Metrics – Part 1: General Approach
ISO/IEC 19796-2 (IS), Quality Management, Assurance, and Metrics – Part 2: Quality Model
ISO/IEC 19796-4 (TR), Quality Management, Assurance, and Metrics – Part 4: Best Practice and Implementation Guide
ISO/IEC 19796-5 (TR), Quality Management, Assurance, and Metrics – Part 5: Guide “How to use ISO/IEC 19796-1″


The position taken by IST/43 on these pieces of work is largely passive; there is not strong interest but they are recognised as being of potential interest to some in the UK and it is believed that they are not in conflict with UK requirements. Parts 1 and 3 have been adopted as a British Standard.

Work items:

[not yet approved] Quality Standard for the Creation and Delivery of Fair, Valid and Reliable e-Tests


This item has not yet been voted on by participating members of SC36 but the work item proposal is well developed and has been championed by a member of IST/43. This will be a proposal from the UK to SC36. See also a previous article I wrote.

WG6 Supportive technology and specification integration

Work items:

ISO/IEC 24725-1 (TR), supportive technology and specification integration – Part 001: Framework
ISO/IEC 24725-2 (TR), supportive technology and specification integration – Part 002: Rights Expression Language (REL) – Commercial Applications
ISO/IEC 24725-3 (TR), supportive technology and specification integration – Part 003: Platform and Media Taxonomy


There is no participation from IST/43.

WG7 Culture, language and individual needs

Work items:

ISO/IEC 24751 Part-9 (IS): Access for All Personal User Interface Preferences
ISO/IEC 24751 Part-10 (IS): Access for All User Interface Characteristics
ISO/IEC 24751 Part-11 (IS): Access For All Preferences for Non- digital Resources (PNP-ND)
ISO/IEC 24751 Part-12 (IS): Access For All Non-digital Resource Description (NDRD)
ISO/IEC 24751 Part-13 (IS): Access For All Personal Needs and Preferences for LET Events and Venues (PNP-EV)
ISO/IEC 24751 Part-14 (IS): Access For All LET Events and Venues Description (EVD)


This work has many roots in older IMS work on accessibility and the revisions are being fed back into IMS. Access for All has been actively contributed to be a member of IST/43, although his continued participation is in jeopardy due to lack of funding. Other members of IST/43 support the work but are unlikely to have the capacity to directly contribute.

Work item:

ISO/IEC 20016-1, ITLET – Language Accessibility and Human Interface Equivalencies (HIEs) in e-Learning applications: Part-1: Principles, Rules and Semantic Data Attributes


There has been little participation from IST/43. A “no” vote with strong comments was agreed at the last IST/43.

Any work where “no participation” is stated will attract abstain votes without comment from IST/43 and is unlikely even to be discussed at committee meetings.


Although the above indicates that there is currently no work on a British Standard in IST/43, the committee has discussed a new work item to create a British Standard that implements “BS EN 15982 Metadata for Learning Opportunities (MLO) – Advertising” along with an XML binding and vocabularies for use in the UK. This completes a cycle where the work of the JISC-funded XCRI projects was contributed into the EN process; the EN represents a core common language that each member state can conform with and extend for its local needs. Once the EN is approved, an “acceptance case” will be presented to BSI for this new work.

For more information:

This article is my own words and, although I believe it to be accurate, I ask readers to recognise that it is not approved by IST/43.

Anyone interested in joining IST/43 should contact the committee chair (me, or committee secretary (

Workshop on Global eBusiness Interoperability Testbed Methodologies

I just caught an announcement of a new CEN Workshop that looks rather interesting from an interoperability point of view.

“The Global e-Business Interoperability Test Bed project (GITB) focuses on methodologies and architectures that support e-business standards assessment and testing activities from early stages of eBusiness standards implementation, to proof-of-concept demonstrations, to conformance and interoperability testing.” – from

The business plan is ambitious, to say the least, but even modest advance in technical terms could have significant practical benefit. I certainly see the future of interoperability standards in education being meshed with achievements of global eBusiness interoperability as well as global web standards.

Biometrics Code of Practice – Draft for Comment at the British Standards Institute

A draft for public comment of a new “Publicly Available Specification” (PAS) is available until October 5th. PAS’s are not full standards and have not been through the same level of (time-consuming) consensus-assurance as such.

The full title is “Code of practice for the planning, implementation and operation of a biometric system” and it is otherwise known as PAS92:2010. This PAS looks like a helpful guide to a complex legal, technical and ethically-contentious area (I am no expert to comment on its accuracy).

Comments may be made via the BSI drafts website, specifically for PAS92 at You will need to register.

“Openness” – Ideology or Rationality?

There seems to be a lot of talk of “open this”, “open that” and “open the other” these days: open source, open standards, open data, open access, open educational resources, open process… I sometimes get a sense of “open” being the new moral high ground but do not accept that an ideological basis for publicly-funded activity is adequate. This is not to say that I object to an ideological basis for personal action. This posting is a sandwich of under-cooked polemic on this topic inside some wholemeal bread.

While at the 2010 JISC Innovation Forum, I heard arguments that I would definitely place in the “rationality” category, particularly in a a session entitled “The Impact of Open”. This gave me heart as it indicated both that JISC is taking seriously the need to explain why “open” appears so frequently in its initiatives and because reactions to it indicated that the centre of gravity of conversation on “openness” is moving towards evidence and mechanism.

Why do I Object to Ideology?

To reiterate, my objection is to: “an ideological basis for publicly-funded activity”.

I also personally agree with propositions such as: “if public money is spent to effect ‘X’ then members of the public should have access to ‘X’, limited only if  ‘X’ as a rivalrous good (e.g. health-care).” i.e. I believe this is an appropriate starting point, a default position in the absence of a case to the contrary.

The problem with ideologies is that they are prejudice presented as common sense. Consequently they are imposed through power-struggle and lead to alienation. War and a pendulum of changing political fashion are the wasteful consequence.

Clearly, we do need to operate as a society on the basis of shared values but the problems arise when ideologies include values at a level of detail beyond the very broad or build-in attachments to particular means. It is my view that we cannot go into much detail at all if attempting to describe common values. For example, “the purpose of government activity as a regulator and executive for public spending is to increase health, wealth and happiness of the people it represents”. This general idea seems to have been present since the enlightenment, for example in the writing of the hugely-influential John Locke, and found expression as “life, liberty and the pursuit of happiness” in the US Declaration of Independence and developed into Utilitarianism. I particularly like Stafford Beer‘s use of the term “Eudemony”, an echo back to ancient Greek ethics and an indicator that “happiness” is not understood in a hedonistic sense. I would also like to extend the meaning of “liberty” US Declaration of Independence to emancipation in a more general sense – freedom from the consequences of ignorance, from drudgery, and other forms of limitation – and move into the realm of Jürgen Habermas, who sees social theory as a fundamentally emancipatory endeavour. (I really should read “The Structural Transformation of the Public Sphere”)

Prejudice, faith, belief, ideology, … (etc) are problematical because they do not provide us with the means to optimise benefit (eudemony, health-wealth-and-happiness); they do not address the mechanisms that we can trigger to effect change. They lack a theoretical basis. Such a basis also gives us an opportunity to understand the bounds;  an understanding of the  point at which we should draw-back from the application of a policy or principle is necessary in the interests of efficacy?

It should be clear that, if mechanism and theory are taken into account, asking about “openness” and public policy is not a single question but a prompt to ask questions in a range of contexts. It also requires us to make decisions about how we measure health-wealth-and-happiness. Radically-new models can be advanced and predictions made of whole-system benefits but it is probably better to consider the evolutionary paths; the world is a complex place with limited scope for imposition of master-plans and a historical record of disaster. Temper dreams with strategic thinking.

The Shadow of Legacy

The past naturally casts a shadow over the way we understand the world and the systems in place (NB: a general interpretation of “systems” is meant here). Sometimes we continue to operate in certain ways when there are better approaches. In a sense, the organisations and systems we have will always be partially obsolete as they arise out of a response to dynamic pressures. With an understanding of mechanism and theory, we are in a position to question the fitness for purpose of these organisations, institutions, systems etc… The risk of “pathological autopoiesis” (Stafford Beer in “Brain of the Firm”), literally killing yourself by trying to maintain yourself unchanged, is real for those who do not seek answers to such questions.

For example, the model of scholarly publishing we have arose from pressures in the past that made it viable and valuable then but at risk of pathological autopoiesis and an impediment today. Journals are only an instrument of scholarship (let us assume that scholarship has merit). See the reference in my closing section.

In another vein, the prevalent political ideology of the 1980’s led to many public sector organisations seeking ways of raising income from the assets created with public money. As digital resources became available, they were locked behind paywalls. It was only in the closing year or so of the previous UK government that we saw any serious change as, for example, the British  Geological Society launched OpenGeoScience and the Ordnance Survey launched their OpenData. Thankfully the new coalition government seems to be supportive of open public sector data and I am optimistic that the members of the Public Sector Transparency Board will be influential in leading the government to rational rather than ideological policy.

There are  many other cases where I believe restricting access, introducing pay-walls, etc in attempts at achieving sustainability leads to overall inefficiencies and sub-optimal health-wealth-and-happiness. I lack the convincing evidence and theory so I will keep them to myself.

Where are the Torch-bearers?

I’d like to conclude by returning to the “The Impact of Open” session at the JISC Innovation Forum. The person who most impressed me was Rufus Pollock, an economist who has applied himself to the mechanisms of openness. Two recent papers consider different questions:

These are the most important papers I have come across in recent times, not least because so many politicians are economists. This is the way to make a difference. The first makes some interesting reading about the limitations imposed on filtering/reviewing efficiency by orthodox journal models. The second argues that public sector information needs a thoughtful regulatory framework and concludes that marginal cost pricing (effectively zero for digital information) for information supply will generally provide the largest social benefit.

Rufus principally considers utility and equilibrium in his models, although not neglecting dynamical considerations in the papers. This would be a particularly interesting area to model, although challenging as it would probably require an approach such as agent based modeling. I would particularly like to see something like SKIN, “Simulating Knowledge Dynamics in Innovation Networks” used to probe some of the “what if” questions for various openness scenarios. If only I was a man of independent means and not a wage-slave…

Future of Interoperability Standards – Technical Approaches

In anticipation of a workshop/discussion meeting we are holding on September 24th, I have produced a short position paper, “Suggested Principles for Structuring Standards” (PDF 580kB), to outline the approach I speculate we should take in future in creating specifications and standards for learning education and training.

Responses, alternative views etc are most welcome before, during or after the meeting. I hope other attendees contribute papers and expect to synthesise conclusions of the meeting shortly afterwards.

A Quality Standard for Creation and Delivery of Fair, Valid and Reliable e-Tests

A proposal has been made to the International Standardisation Organisation (ISO/IEC JTC1 SC36) for a New Work Item on a “Quality Standard for Creation and Delivery of Fair, Valid and Reliable e-Tests.”

To quote from the proposal:

Specific areas that could be covered within the standard include:

  • Roles and responsibilities – The key roles and skills required within the assessment process and life-cycle. e.g.,
    • senior management (responsibility for developing and supporting an e-testing strategy for the organisation);
    • psychometricians – those specialists responsible for creating the items and tests;
    • computer scientists – Computerization of the test delivery
    • coordination/operational management (implementation of the e-testing strategy and policies, and accountability for the e-testing process);
    • administration (responsibility for operational systems and processes);
    • technical support (responsibility for the technology), whether provided in-house or via a third party; and
    • working with the learner (maximising the potential for success through the etesting process).
  • Organisational requirements – Requirements to overcome the challenges and to realize the benefits of e-testing.
  • Coordinating the e-testing process – Administration, technical support, working with learners, invigilation/proctoring
  • The e-testing environment – general environment, security, workstation design and layout, hardware, software, peripherals and communications links (Can be drawn mainly from other standards including ISO23988)
  • Preparing for e-testing – registration, learner preparation, practice e-tests
  • Managing exceptions – planned/unplanned breaks, special needs/allowances, emergencies and irregularities
  • Data – transmitting learner data, data security, learner feedback and ‘certification’

This work-item has been co-proposed by the British Standards Institute committee “IST/43″, which is the means to representation of UK interest in ISO SC36 (broadly speaking, ICT in learning, education and training).

Anyone interested should contact either the chairperson or secretary of IST/43. Expressions of interest from potential new members are always welcome. Some information on past and present activity of IST/43 may be found on the BSI site.