On 22 July the Centre for Data Ethics and Innovation (CDEI) published a report 'Unlocking the value of data: Exploring the role of data intermediaries', which was commissioned by the Department for Digital, Culture, Media and Sport (DCMS) to support the National Data Strategy (NDS). While the report's scope includes all data, not just personal data, some of the issues raised are relevant to data protection. The report states that responsible and efficient data sharing and access are key to realising the NDS's goals, and its aim is to to:
- consider the role of data intermediaries in supporting responsible data sharing; and
- explore the activity of existing intermediaries across different sectors and considers the role they could play in the future.
The report is divided into 5 sections:
1. What are data intermediaries? This section identifies 7 types of data intermediary, who may be a controller or a processor, depending on the circumstances:
- Data trusts
- Data exchanges
- Personal information management systems (PIMS)
- Industrial data platforms
- Data custodians
- Data cooperatives
- Trusted third parties
2. Exploring issues in data access and sharing: this section identifies issues which may prevent optimal data sharing, and the potential role of a data intermediary in overcoming these barriers, for example collating data from different sources into a single accessible application.
3. Empowering individuals and businesses in data access and sharing: this section identifies opportunities to improve individuals' and businesses' control and choice over who has access to data about them, including:
- Personal information management systems (PIMS), also known as personal data stores or data lockers; and
- Providing individuals and businesses with more choice over data-driven products and services, e.g. extending the Open Banking system to other sectors, including energy, communications and pensions
4. Enabling analysis through data access and sharing: this section covers:
- Data sharing in the public interest, e.g. in response to the COVID-19 pandemic;
- Data sharing in commercially-sensitive environments, e.g. electric vehicles, to drive innovation;
- Data sharing to enable independent auditing of data-driven technologies – this addresses the concern about the potential for bias in algorithmic decision-making. See our article Artificial intelligence key updates for a summary of recent developments.
5. Looking to the future for data intermediaries: this section includes 3 use cases:
- preventive medicine, considering the benefits and risks of sharing data which tends to be siloed across healthcare, financial services, retail, wearable technologies, and social media platforms;
- preparing workers for the future of work, considering changing employment needs, due to developments in robotics and machine learning; and
- enabling the UK economy to meet its Net Zero targets by combining knowledge over carbon emissions, enhancing access to essential climate data and supporting innovation focused on tackling climate change.
If you would like advice on any aspect of data sharing, including data mapping or drafting or reviewing data sharing agreements, please contact one of our data protection specialists.