Socitm has responded to the Cabinet Office's consultation on open standards. We are grateful to Roger Marshall who has compiled the response with input from Socitm members.
Criteria for open standards
this definition of open standard compare to your view of what makes a standard
The definition is practical and covers the essential elements without
Some general comments on the report:Open source is not open standards (Ch. 1 confuses the two); Open
standards does not require standardisation; Open data is not about open source,
but it is about non-proprietary; Encouraging SMEs is good, but bucking the
market to follow a political direction won't work; High cost of public sector
IT is not universal (c.f. local government), neither is it primarily the result
of open source/standards - it is poor and non-transparent planning,
procurement, execution and ownership policy/practices, and we don't see enough
changing to address this; The best IT is driven from desired outcomes being
clear with IT in alignment, not from stronger principles about inputs; There
needs to be stronger compliance, standards and standardisation, but you have to
be so careful not to end up with a centrally planned, inflexible result.
(Open) standards mandating has a poor track record of success and
can lead to unintended and surprising consequences (poor take up, stifled
innovation, higher costs, supplier lock-in). Health is the area which comes to
mind. At the same time, there needs to be much stronger compliance around the
IT Strategy in some areas. Central Government Departments still think they can
do their own thing (large and small) or simply bow to supplier pressure (the
market must know best, the private sector is better than us, we don't have the
skills anymore). A good example is Public Services Network and Health. There
should be no debate about this one; and work should be focussed on how we
integrate and break down barriers, not investing time in justification of the
status quo in the interests of big suppliers (or 'all can change, but not me/my
the Government be inhibited from doing if this definition of open standards is
adopted for software interoperability, data and document formats across central
Simply adopting the definition should have no effect.It is how that definition is applied in
procuring and developing systems that will potentially have an impact.The impact should be entirely positive so
long as exemptions, where "there are clear business reasons why this is
inappropriate", are strictly limited.
businesses attempting to break into the government IT market, would this policy
make things easier or more difficult - does it help to level the playing field?
The policy should assist new entrants to the government IT market
by removing some of the advantages enjoyed by incumbent suppliers.However,it is not sufficient in itself to level the playing field and other policies
are needed to encourage new entrants, particularly SMEs.
mandating open standards for use in government IT for software
interoperability, data and document formats affect your organisation?
No direct effects.
effect would this policy have on improving value for money in the provision of
Increasing competition and choice in the public sector software
and services market, which this policy should facilitate, should improve value
for money in the provision of government services.Such benefits will take time to be realised,
however, as suppliers develop their products and skills and purchasers adapt
their policies. It is important that government takes a long term view and
adopts a convergence strategy, taking account of legacy issues and network
policy support innovation, competition and choice in delivery of government
Yes, in that it will draw in a wider variety of systems and
service providers, including SMEs with innovative service solutions.
way do software copyright licences and standards patent licences interact to
support or prevent interoperability?
The copyright or patent gives a market advantage to its holder,
particularly if they can change the product at will.This restricts interoperability because other
potential suppliers will be unwilling to enter a market where the copyright or
patent holder can exploit their position to limit competition.
adopting (Fair) Reasonable and Non Discriminatory ((F)RAND) standards deliver a
level playing field for open source and proprietary software solution
There is no commonly-understood definition of (F)RAND.They would need to satisfy the requirements
that licences be royalty-free, non-discriminatory and non-assertable.
selecting open standards which are compatible with a free or open source
software licence exclude certain suppliers or products?
The policy should not exclude any suppliers as by definition they
are all able to use open standards and open source software.Suppliers should then compete on a level
playing field based on the merits of their proposal rather than the ownership
of proprietory rights. Some products may
be excluded but the policy should allow for them to be included in proposals if
there is no other economic way of meeting a business requirement in the short
term.Such a policy must require the
supplier to converge to open standards and retire non-compliant software during
the life of the contract.
promise of non-assertion of a patent when used in open source software
alleviate concerns relating to patents and royalty charging?
It should do, but legal advice on the licence terms should be
different rationale be applied when purchasing off-the-shelf software solutions
than is applied when purchasing bespoke solutions?
The rationale should be the same but there may be different
practical issues such as the need for testing of interoperability or standards
of standards for software interoperability, data and document formats, is there
a need for the Government to engage with or provide funding for specific
There are numerous separate purchasing organisations for IT within
Government and the wider public sector.They should be given guidance on preferred standards and assistance with
interfaces and interoperability, as was the case with the e-GIF standards.This will require government funding and
support. Make a start with adequate, three year funding of the Local Government
e-Standards Body (LeGSB).
any are other policy options which would meet the described outcomes more
The government should consider investing in open source reference
implementations. These could provide multiple benefits: they can be used
directly by government organisations that wish to implement a solution
compliant with a standard; they can be "bundled" by suppliers as part
of a larger service provision; they can be used to test interoperability with
other solutions; small service-oriented companies can provide related services,
such as customisation and configuration; and they make it much easier to switch
suppliers, as the new supplier can continue to use the same software.
Open standards mandation
criteria should the Government consider when deciding whether it is appropriate
to mandate particular standards?
In general, there should be a "light touch" to mandation, as it
could stifle innovation and improvements in efficiency. The criteria should be
based on business need, both now and (to the extent that this can be predicted)
in the future.Thus, for example, where
an IT system is stand-alone and unlikely ever to require interoperability with
other systems, mandation can be avoided.Alternatively, there is a growing need to join-up services across the
public, private and third sectors and to adopt "shared services" between
organisations, which would imply more rather than less mandation.The widespread adoption of "cloud" services
could present problems in this regard, as could the massive future growth in
the "internet of things".
effect would mandating particular open standards have on improving value for
money in the provision of government services?
In the medium and long term, value for money is certain to be
any legal or procurement barriers to mandating specific open standards in the
UK Government's IT?
Not that we are aware of.
mandation of competing open standards for the same function deliver
interoperable software and information at reduced cost?
If the standards are widely used then there should not be a
problem.The number of competing
standards for the same function should be kept to a minimum to avoid additional
costs in interoperability and testing.
mandation of open standards promote anti-competitive behaviour in public
No, quite the opposite, it will reduce anti-competitive behaviour.
mandation of specific open standards for government IT software
interoperability, data and document formats affect your organisation/business?
The effect should be entirely positive in reducing procurement and
operational costs. It would be easier to spread the message of the value of
standards; Socitm could increase awareness in 400+ local authorities.
the Government best deal with the issue of change relating to legacy systems or
incompatible updates to existing open standards?
Development plans or technical roadmaps for existing systems
should specifically take account of the open standards policy.Where incompatible changes or updates are needed
there must be a clear plan for later convergence and specific exemptions should
be granted on a case by case basis.
should trigger the review of an open standard that has already been mandated?
There should be a regular review of mandated standards to ensure
that they are still meeting the criteria set and are actually being used by the
government and wider public sector.A
board will be needed to decide what new standards to mandate and the same body
can be responsible for review.
the Government strike a balance between nurturing innovation and conforming to
In general, innovation should not be adversely affected by the
existence of standards.However, in some
cases the innovation may precede the setting of standards for a particular
technology.In those cases the policy
needs to be flexible.
the Government confirm that a solution claiming conformity to a standard is
interoperable in practice?
This is one of the factors to be considered when evaluating
proposed solutions.In some cases the
testing by standards bodies should provide the necessary level of assurance; in
others, for example interoperability with existing bespoke systems, it may be
necessary to arrange for independent testing as part of the evaluation
process.Use of the relevant standards
will be referred to in contractual documents, providing another level of
any are other policy options which would meet the objective more effectively?
- Is the
proposed UK policy compatible with European policies, directives and
regulations (existing or planned) such as the European Interoperability
Framework version 2.0 and the reform proposal for European
the open standards policy be beneficial or detrimental for innovation and
competition in the UK and Europe?
It should benefit both innovation and competition, in any
there any are other policy options which would meet the objectives
described in this consultation paper more effectively?