Minimizing Disclosure Risk in HHS Open Data Initiatives. 4. Supplemental Guidance on the Implementation of M-13-13 “Open Data Policy – Managing Information as an Asset”


This document, which was issued in August 2013, provides additional, in-depth information to agencies on how to carry out the objectives of the Executive Order and OMB Memorandum M-13-13. Most importantly, this document provides a list of minimum goals that must be met by agencies to fulfill these policy requirements. Minimum requirements for an Enterprise Data Inventory (goal 1) include: submitting a schedule to OMB of how the agency plans to identify all their data; posting all datasets in machine-readable format to; and updating the inventory schedule on a quarterly basis. To assist agencies with their inventories, OMB and the General Services Administration have provided a data inventory tool called CKAN. Minimum requirements for a Public Data Listing (goal 2) include publishing all data that are described in the inventory metadata as public and publishing the data listing at www.[agency].gov/data.json. The memorandum also highlights the availability of two additional tools. The minimum requirements to engage with customers (goal 3) are establishing a mechanism for customer feedback and describing the process for review of customer feedback. Tools are provided for this purpose as well. The policy requirements for documenting non-releasable data (goal 4) include simply describing and publishing the process by which the safety of releasing the data is determined. Finally, the only requirement for clarifying the roles and responsibilities for promoting efficient and effective data use (goal 5) is to report the point of contact for each these roles via the E-Gov website.

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