The machine readable data challenge

The obligation to provide information in a reusable, and machine readable data format not only arises under the Freedom of Information Act. It is also important for GDPR – when people exercise their right to data portability, for example. What exactly this means is a bit nebulous and in fact technology hasn’t quite caught up with the concept. Unusually the standard is defined in the notes to the Protection of Freedoms Act (which amended the Freedom of Information Act): “a re-usable format is one where the information is available in machine-readable form using open standards which enables its re-use and manipulation”.
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PDF is Not Machine Readable Data

PDFs are a form of machine readable data.

From now on all stored data must comply with both FOI (when it applies) and people’s data rights. To me this raises a question over the continued use of PDF as a method of data storage. PDFs can be scanned by computer but are essentially electronic paper. If, for example, you have converted a Word document to PDF you can search for specific words. However, you cannot simply transfer data from a PDF from and to an excel spreadsheet for example – particularly if automated calculations or formulas were used to derive the results.

Also, it is common to scan documents in as an image and save them as a PDF – in which case they are not readable at all.

While there are tools that can convert PDFs into other formats they typically aren’t free, commonly used or meet the standard of machine readable data. Essentially what the GDPR envisages is the automatic transfer of data from one system to another. This should happen when the data subject requests it. The aim is for data processing activities the data are used for to continue seamlessly.

The Machine Readable Data Challenge

Like all GDPR compliance activities getting this right is a journey. However, my own experience with clients is that people are increasingly aware and assertive of their rights; and an inability to comply with them is something the ICO takes a dim view. Machine readable format data is the way to go. 

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So what does the future look like? Most computer systems allow data downloads or uploads to be in CSV format. For instance our bank, accounting systems and even this website are set up to do this. Whether you need a CRM system, or a patient record data base, the ability to access and share information in this was is important. Ensure that you include it in your requirements when procuring new systems.