NAP3 Self-Assessment - Public Comments and Response 30 November 2021

Item and page	Public Comment	Change made to self-assessment
Page 3: last sentence in the Executive summary: ‘Work will continue beyond the end of NAP3 on those commitments that have not yet been completed.’	No information is provided in the report to substantiate this claim. Particularly in relation to Commitment 11, there is no information as to how this will happen, when it will happen and whether the same agencies and civil society participants will be involved. There is nothing about this on pages 33-35 re: commitment 11 or on page 38.	On page 3, we have adjusted that reference to say the following: NAP3 consisted of 12 commitments that originally involved 43 milestones. During the life of the plan, six milestones were added, and one was removed. This took the total number of milestones to 48 across the 12 commitments. At the end of the NAP3 period, 43 milestones were fully completed or underway. The eight that are underway have a plan in place for completion. The five milestones that have been delayed needed to change as a result of agencies learning more about the circumstances they were facing or the steps that would need to be taken to achieve the objectives of the commitment. Work will continue beyond the end of the NAP3 on those commitments that have not yet been completed; updates on progress against these commitments will be published in 2022. Footnote added on page 3: Further information on the implementation of the 12 commitments, including milestones still underway, is included from page 17 of this report. Revised text on page 35 is as follows: DIA has committed resources to a two-phased implementation plan involving: · Build and Release (phase 1) · Maintain and Develop (phase 2). Further details of this plan for Commitment 11 are included on the OGP NZ reporting page here. Details for other milestones that are underway or where there were some delays are also included on the OGP NZ reporting page.
Page 10: ‘An authoritative, machine-readable open dataset for all government organisations under Commitment 11 provides the foundation to access for digital services and information about government agencies, learn more about how government is structured and be able to reuse the open data.’	‘It is wholly inaccurate to use the present continuous tense word ‘provides’ for something that has not been built and does not exist after three years of work on the commitment. Suggest the following alternative: ‘When the unfinished work on Commitment 11 is completed, it should provide an authoritative, machine-readable open dataset of government organisations, for both government agencies and the public to use as the foundation upon which to build digital tools and services.”	Revised text on page 10 is: When the work on Commitment 11 is completed, it will provide an authoritative, machine-readable open dataset of government organisations, for both government agencies and the public to use as the foundation upon which to build digital tools and services.
Page 10: ‘Publishing the contracts awarded by the government that are currently published on the Government Electronic Tender Service (GETS) as open data under Commitment 12 similarly increases transparency through the use of data.’	Again, this statement is inaccurate. Commitment 12 was never about publishing the contracts (much as I wish it was, and this should be done in NAP4). Commitment 12 was merely about taking the data in the PDF documents recording the notice of a contract being awarded and publishing that small amount of information as open data. Suggest the following alternative: ‘Providing as open data the information currently published in PDF files of the notices of who has been awarded a particular contract that was tendered on the Government Electronic Tender Service (GETS), Commitment 12 will increase the usability of this data.	Revised text on page 10 is: Providing as open data the information published (in the form of individual notices) on who has been awarded a particular contract that was tendered on the Government Electronic Tender Service (GETS), Commitment 12 will increase the usability of this data.
Page 12: This was expressed in comments on the OGP website	This implies the comments were published on the main Open Government Partnership website, when they were published on the ogp.org.nz website. Suggest you change the text of the link to say ‘the NZ OGP website’ or ‘the OGPNZ website’.	Text changed on page 12 to “the OGPNZ website.”
Page 13: ‘The EAP provided an independent view to Te Kawa Mataaho Public Service Commission, agencies and New Zealanders.’	How did the EAP provide an independent view to New Zealanders? The EAP’s mandate was not to provide views to the public but to the Commission. The EAP held no public events of its own. It produced no separate reports that were aimed at the public. Publication of bare bones minutes 3 months after each quarterly meeting hardly constitutes providing ‘an independent view’ to the New Zealand public.	Revised text on page 13 is: The EAP provided an independent view to Te Kawa Mataaho Public Service Commission and other government agencies.
Page 16: ‘i. In 2019, the Ministry of Justice undertook targeted engagement on the Official Information Act’	No. The Ministry of Justice undertook a very poorly advertised public consultation. The only thing ‘targeted’ about it was its selection of who the Ministry invited in for an interview to supplement their opportunity to provide a written submission. The Ministry may have intended to only consult a few ‘targeted’ people to begin with, but the Commission should not perpetuate the Ministry of Justice’s misleading statement.	Revised text on page 13 and additional links to relevant sources are as follows: In 2019, the Ministry of Justice undertook targeted engagement by inviting submissions on the Official Information Act from individuals and organisations’. There was a link in the draft self-assessment to the Proactive Release of the advice provided to the Minister. We have also added a link to the closed public consultation page.
Page 34: Footnote 7 ‘In the summary on page 3 of this draft report, we have categorised “underway” milestones as “poised for completion/substantially completed” as the Commitments are poised for completion once decisions are made on ownership, governance and the ongoing maintenance process. This work will be completed after the expiry of NAP3.’	This is ‘rounding up’ of the progress made, in a way that is not fairly reflecting the significant work that remains to be done to turn this aspiration into a delivered product. The designation ‘underway’ is generous already, considering: • no paper has been produced on possible contenders for the appropriate open data standard to use for the dataset • no paper has been produced on a governance model or ongoing ownership of the data model and dataset • no draft of the data model of the ‘machinery of government’ has been produced • only a single piece of ‘narrative’ has been produced to try and secure active users of the dataset/API, and this needs to be substantially supplemented.	We have removed this reference and explained it more clearly on page 3. Revised text in footnote on page 35 is: The summary on page 3 of this draft report identified these four milestones as “having a plan in place for completion.” Further details of this plan for Commitment 11 are included on the OGP NZ reporting page here.
Page 38: Lessons learned	A key lesson that I hope has been learned, but which is not mentioned here, is that Te Kawa Mataaho Public Service Commission will need to develop and implement a training programme for officials in agencies responsible for delivering commitments. This is necessary so that the lead officials are trained in what the OGP is, its values and spirit, the importance it places on co-creation and partnership with civil society and the public, and how this connects to the ‘fostering a culture of open government’ value in the Public Service Act 2020. I experienced multiple changes of lead officials in the commitments I engaged with during NAP3, and while some were adequately aware of the OGP kaupapa, others were wholly ignorant of it and when asked, said they had received no training or guidance from the State Services Commission on the responsibilities of leading an OGP commitment. Higher quality delivery of NAP4 commitments, in conjunction with civil society and interested members of the public, will require these officials to be trained. I suggest this is something the EAP be asked to develop.	Revised text on page 39 is: Understanding the OGP context plays an important role in supporting the development and implementation of National Action Plans. While induction did take place at the start of NAP3, if changes of commitment lead occur mid-plan in future, an induction for new leads would be beneficial to ensure they have a good understanding of the OGP context.