On Tuesday, the Tony Blair Institute for Global Change (TBI) and The Entrepreneurs Network (TEN) published Governing in the Age of AI: Building Britain's National Data Library, a comprehensive report outlining proposals for implementing the National Data Library (NDL).
We're pleased to see the ODI's work on data infrastructure and open data cited in this contribution to the UK's data policy landscape. The report provides a detailed roadmap for the NDL's development across three phases – immediate actions (first six months), medium-term actions (six months to three years), and long-term actions (three to five years).
This is an ambitious attempt to set out specifics on a pivotal future part of Britain’s data infrastructure. It’s something we’ve been talking about for a while and we’re pleased to see others thinking about the detail.
Bringing vision and technical implementation together
The TBI report is different from the work we’ve seen on the topic to date in that it focuses on the strategic value and purpose of the NDL (rather than on broad, thematic work and technical implementation). This is a vision-led approach that’s complementary to others’ work, including our own submission to the Wellcome Trust and ESRC’S recent Technical Whitepaper Challenge call, and our input to the AI Opportunities Action Plan.
The relatively short timescales proposed will be a challenge for the government but the next important step will be to bring together visionary thinking, technical expertise, and practical application, including strong governance and public engagement. This will require a multidisciplinary approach by the implementation team that bridges policy, technical, legal, ethical(and other) domains.
Common ground and divergence
The TBI report presents the NDL as a transformative infrastructure for unlocking the value of public sector data. While this broadly aligns with our position on the importance of data infrastructure, there are subtle differences in the approaches we’ve both set out.
The TBI takes a predominantly economic and instrumental view of public sector data as a resource to be unlocked for policy-making, productivity gains and innovation:
The NDL’s transformative potential lies in its ability to advance better decision-making, support innovation and drive AI-powered applications across multiple domains. It is not just a data-sharing platform; it is a strategic enabler of evidence-based policymaking, research and economic growth. It is essential to delivering the government’s Plan for Change, and supporting key missions including improving health care, tackling inequality, boosting economic growth and achieving clean-energy goals.
At the ODI, while we recognise these benefits, we've consistently positioned public sector data as both an economic asset and a public good that requires careful stewardship, contextual understanding, and meaningful public participation in its governance.
The ODI and TBI/TEN agree on a federated rather than centralised approach to data storage. Federation is more fundamentally about distributed stewardship than mere departmental control however, and balanced power dynamics matter – and equitable non-bottlenecked access while maintaining context-specific ethical data governance frameworks will be important in the final design.
Promising elements and constructive concerns
Several proposals in the report deserve particular attention. The phased implementation approach is pragmatic and acknowledges the complexity of the task ahead. Starting with high-impact use cases while building toward a more comprehensive vision reflects good practice in digital transformation. It’s also what the ODI has recommended in our recent commentary on the topic.
There is a welcome focus on supporting data controllers, not just demanding access to their data. This recognises an often-overlooked reality in data sharing that data holders need assistance in preparing data for wider use, not just mandates to share. Finally, the commitment to transparency through a public registry of projects and data uses could enhance accountability. However, we think this should be complemented by more proactive public engagement in decision-making.
We’d like to see more attention given to some aspects:
The proposed universal personal identifier for linking data across government raises important questions about privacy, consent, and power. While efficient data linking is important, the ODI has historically advocated for more contextual, privacy-preserving approaches to joining data about the same entities. This aligns with our broader commitment to individual data control, exemplified by our recent adoption of the Solid protocol that gives individuals greater agency over their personal data through decentralised storage and permissions. Universal identifiers may create centralised vulnerabilities and power imbalances that contradict this principle of user-centred control.
The commercial model proposed in the TBI/TEN report, with tiered access fees for industry users, differs from our proposed emphasis on maximising the public value of government data. While sustainable funding is necessary, and there's a case for industry to pay for access that would necessitate some form of paid tiered model, we must ensure that monetisation doesn't create new– unintended–inequities in who can access and benefit from public data.
Interoperability receives limited attention in this report, focusing primarily on technical standards rather than the multi-layered systemic approach (encompassing legal, organisational, semantic and technical elements) that we at the ODI have advocated. The governance of standards development processes requires broader stakeholder involvement than is suggested in the report.
Finally, the timescales suggested are really ambitious with compressed actions, particularly in the immediate phase (six months vs 12 months) and a suggested full implementation within five years at most. We caution against rushing technical considerations and solutions. To achieve the user-centric approach, the NDL needs - and the public has the right to expect - a proper participatory and consultative process that engages experts and diverse stakeholders over a more extended period.
The way forward
The NDL represents a significant opportunity to position the UK as a leader in the responsible use of high-value public sector data. The TBI/TEN report contributes to this vision. Implementation will require balancing multiple considerations.
As the government develops its plans, we encourage it to emphasise several factors, including deeper engagement with the public and civil society in shaping the NDL's governance and access frameworks, going beyond transparency to meaningful participation. The TBI/TEN report encourages this in one of its recommendations, saying that NDL’s governance structure should seek:
Continuous senior sponsorship and external input into the NDL work and strategic plans, establishing a permanent board that includes secretaries of state of DSIT and other relevant departments, the national statistician, and representatives of UKRI, the AI Security Institute, industry and civil society (such as the Open Data Institute).
As plans for the NDL develop, we’d also like to see greater emphasis on the alignment of data standards with international best practices, ensuring the UK contributes to and benefits from global developments in data governance.
At the same time, there should be careful consideration of the power dynamics in data access and use, ensuring that the NDL democratises access rather than reinforcing existing advantages and entrenching large dominant market actors. Finally, while the emphasis on rapid implementation is welcome, a careful balance must be struck between speed and effectiveness. As someone wise once said: “cheap, fast, good - choose two”!
