I. Purpose

In order to facilitate transparent government and enhanced communication with citizens, this policy will provide uniform guidelines for the proactive publication of City and County held open data. The policy details the guidelines for the proper management and protection of data residing on the City and County of Durham open data platform for reuse by the general public.

II. Policy

It is the policy of the City and County of Durham to ensure a consistent and consolidated approach to selecting, publishing and maintaining data on the open data platform. The Open Data portal is a single solution available to all City and County Departments.

III. Definitions

City - County Open Data – data generated and maintained jointly, openly shared, and available to the public in accordance with public records laws.

Data - a value or set of values that represents a specific concept or concepts. Data becomes information when analyzed and possibly combined with other data in order to extract meaning and provide context.

Dataset - A Dataset is a collection of data. Most commonly a dataset corresponds to the contents of a single database table, or a single statistical data matrix, where every column of the table represents a particular variable, and each row corresponds to a given member of the dataset in question.

Data Steward – Departmental staff member designated as a liaison between the department and the Open Data Team.

Open Data - Data made public and provided in a convenient, modifiable form such that there are no unnecessary technological obstacles to the use of the data. For purposes of this policy, open data is machine readable, available in bulk, and provided in an open format such as a .CSV file. Open data includes metadata associated with published datasets and archival materials that are digitized.

Open Data Team - a joint team consisting of the IT and departmental staff from both the City and County which works to support and sustain the open data platform under the leadership of both the City and County Chief Information Officers

Portals - a means, usually a technology application, for transmitting open data for use, reuse, and redistribution.

Principles of Open Data - principles that govern the approach that the City and County use to make Data open. See “Principles of Open Data” at the end of this document.

Restricted Data - all data that the City and County are restricted from disclosing under state or federal law; and all data that the City and County are permitted to withhold from disclosure under state or federal law and have elected to withhold from disclosure.

IV. Procedure

A. Oversight of the Open Data Program

Open Data Program Oversight – the City and County Managers have delegated oversight of the joint City - County Open Data Policy to the respective CIOs or their designees, who shall:

1. Manage the Open Data Team.

2. Maintain the Open Data Portal.

3. Consult with departments to determine what additional departmental Datasets would be added to the Open Data Portal.

4. Advise departments on best practices for Open Data-related projects and the requirements of this policy.

5. Assist in the implementation of Open Data projects.

6. Enforce this policy and create guidance to support the implementation of the Open Data program (see Open Data Team Responsibilities).

7. Approve publishing of all Datasets to be released.

B. Departmental Responsibilities

Work with the Open Data Team to determine what additional departmental Datasets would be added to the Open Data Portal, by taking the following actions:

1. Determine what data may be relevant to the public and prioritize the release of datasets based on those conclusions. Departments and the Open Data Team will consider factors such as the number of public records requests and programmatic interests, along with other methods that assess public demand for datasets.

2. Provide the name and contact information for a primary contact or Data Steward for each Open Dataset.

3. Approve extract, transform and load procedures for each Open Data set with the assistance of the Open Data Team.

4. Establish a Data refresh schedule and Data to be published with the assistance of the Open Data Team.

C. Open Data Team Responsibilities

1. Determine how the Data will be processed and prepared for publishing. This will involve establishing an extract, transform and load procedure with the Data Steward.

2. Provide an implementation schedule that includes an estimated timeframe for publishing each Dataset, a process for managing site Data, methods for posting information, and frequency of Data updates, based upon the input of the department generating the Data.

3. Open Data Team must comply with this Restricted Data Provision. The Restricted Data Provision establishes requirements for the protection of Data the City and County are required or permitted to withhold from disclosure under state or federal law.

4. Create and publish annual report reviewing the open data program. This report will provide an overview of activity related to the open data program and detail recommendations for improving the program and ensuring its sustainability. The annual report shall be published on the portal and be available for public comment for 30 days after it is published.

D. The Data Publishing Process

1. The Open Data Team is a long-term, single solution source available to all City and County Departments. The Open Data Team will work as the primary partner to any department needing assistance and guidance to publish and release data. Data readiness assessment: informal discussion between Open Data Team lead and Data Steward or Data Steward’s representative.

2. Data inventory: Listing of the datasets produced that comply with Open Data policy and data restriction policy. This listing will be made available on the data portal.

3. Data staging: Data is mined using Open Data Team resources. The Data are then checked for personally identifiable information and staged on the Data Portal as a restricted Dataset. Data are also checked for compliance with restricted data policy.

4. Data Steward is engaged to preview the Data and make any recommendations regarding the fitness of the Data for publication. The Data Steward also acts as an SME (Subject Matter Expert) regarding the Data and any dashboards or reuse associated with the Data.

5. Data is released to the public on in accordance with the implementation schedule.

6. Data refresh cycle is established and data is refreshed according to the latest Datasets available. The Open Data Team does this task by using an automated process when possible.

E. Data Restrictions

1. Data restrictions apply to all data that the City and County are restricted from disclosing under state or federal law; and all data that the City and County are permitted to withhold from disclosure under state or federal law and has elected to withhold from disclosure.

2. Departments disseminating data through an Open Data Portal must ensure that access to restricted data is blocked.

3. Examples of restricted data include:

   a. Trade secrets (which may include vendor software, technical specifications or other intellectual property);

   b. Proprietary information such as license agreements or fees, copyrights, patents, etc.

   c. Personal identifying information as defined by NCGS 132-1.10;

   d. Information contained in City or County personnel files as provided by NCGS 160A-168 and 153A-98, except for certain personnel information that is not exempted from being a public record;

   e. Information relating to criminal investigations conducted by the City or County and records of criminal intelligence information compiled by the City or County;

   f. Billing information of customers compiled and maintained in connection with City- or County-provided utility services;

   g. Sensitive security information, as defined by “Protection of Sensitive Security Information” in Title 49, Code of Federal Regulations (CFR) Part 1520, regarding Homeland Security, including but not limited to:

   I. Building plans of City and County owned buildings or infrastructure;

   II. Local tax records of the City that contain information about a taxpayer’s income or receipts;

   III. The security features of the City’s and County’s electronic Data processing systems, information technology systems, telecommunications networks, or electronic security systems as provided by NCGS 132-6.1; and any Data collected from a person applying for financial or other types of assistance, including but not limited to their income and bank accounts, etc.

   h. Open Data Team must also ensure that disseminated Data, and all tools used to disseminate it, adhere to all standing City and County policies and standards, as well as applicable laws.

F. Legal Restrictions On Data Dissemination

Departments that publish data into the public purview should be aware that the following laws restrict the dissemination of Data:

1. Departments disseminating Data must ensure that access to restricted Data is blocked.

2. Information in Title 49 Code of Federal Regulations (CFR) Part 1520 regarding Homeland Security: building plans; infrastructure; data on EDS.

3. NCGS 132-6. X: Any Data collected from a person applying for financial or other types of assistance including, but not limited to, their income.