The Department for Education in collaboration with other authorities in the Education, Skills and Children’s Services sector has, since at least 2009, been developing its own set of data-related standards under the management of the Information Standards Board (ISB).

According to its own website (, “The core business of the ISB, supported by the Technical Support Service (TSS), is to successfully embed standards within the Education, Skills and Children’s Services (ESCS) system in England.”

The ISB has two “approved” statuses for its published standards – “Approved: Recommended” and “Approved: “Adopted”.  On the ISB website today, there are 269 “Recommended” standards, and zero “Adopted” standards.

So why, in five years, has the ISB failed in its core aim of issuing standards which are actually being used?

We believe the answer lies in the approach taken by the ISB in producing and publishing these standards.  Let’s take as our benchmark the work of the Internet Engineering Task Force (IETF), which is responsible for producing a large number of widely-deployed technical standards.  To quote from “The IETF Standards Process” (RFC 2026):

The goals of the Internet Standards Process are:

  • technical excellence;
  • prior implementation and testing;
  • clear, concise, and easily understood documentation;
  • openness and fairness; and
  • timeliness

Assuming we agree that these are all good goals to have when producing a standard, let’s assess the performance of the ISB against those goals.

1) Technical excellence

It could be argued that technical excellence should be relatively low on the list of priorities for ISB (its aim is simply to produce usable standards), but there is a minimum standard that the work is “fit for purpose”.  Unfortunately there have been numerous examples of documents published as “Approved” by the ISB which are simply not fit for purpose.

One of the foundations of the ISB data standards is the Business Data Architecture Data Types document.  This was first published on 20th September 2013 as version 4.0 and was so riddled with errors that that version is not even archived on the ISB website!

It contains statements such as the recursive definition of a date being “A string providing date information and hence containing following values – year, month and date”.  Those three components of a date are each defined to consist of a single digit (0 to 9).  Or defining a type called “Simple_Integer” as being “A simple unsigned string of numeric values.”, and another type called “Integer” with the simpler definition of “Signed numeric value”.

It was simply not possible to implement any of the definitions provided in this document without ignoring large parts of it and trying to guess what the document author intended.

When defining controlled lists of values for common concepts such as language, country and currency, the ISB have quite rightly decided to adopt existing ISO standards in those areas.

However, the ISB have fundamentally misunderstood the purposes of the ISO standards, which are titled “Language Codes – ISO 639”, “Country Codes – ISO 3166” and “Currency Codes – ISO 4217”.  i.e. these are standard lists of *codes* for languages, countries and currencies.

In trying to fit in with other controlled lists, the ISB have broken perfectly good existing standards by using the textual descriptions (e.g. Spanish, Spain and Euro) instead of the code defined by the standard.  The problem is when ISO codes remain the same but the textual description changes.

This was raised as an issue with ISB in May 2014 but no visible action has been taken.

Regarding the many other controlled lists and data documents, there is no way to reliably assess their fitness for purpose without attempting to implement them in the real world.  Which brings us to…

2) Prior implementation and testing

The ISB have stated that it is not their role to perform testing – the ISB propose standards and it is reliant on stakeholders to implement them.  However, given that no ISB standards have been through an implementation process and moved to “approved” status, this approach is obviously not working.

The ISB standards are also heavily dependent on each other, adding layer upon layer upon layer.  When mistakes are found in documents that many other documents depend on (such as the BDA Data Types document) or improvements are suggested to those documents, then these suggested improvements are rejected as being impossible to implement due to the many other standards that would be affected by such a change.

If no stakeholders have implemented any of these standards then in addition to not proving the standards are fit for purpose, it also raises the obvious questions around the need for those standards in the first place.

The motivation for a lot of the standards developed as part of the work of the ISB has been the DfE Data Transformation Programme, which is described as consisting of the “Data Exchange” and “School Performance Data Programme” projects, neither of which are  currently being actively pursued.

However, there is still value in the work undertaken by the ISB, especially in the production of controlled lists which can be used regardless of the over-arching data model.  Instead of investing in the production of further standards, the ISB should stop and invest in its own testing and implementation of at least the core standards and their XML representation.

To quote Albert Einstein, “In theory, theory and practice are the same. In practice, they are not.”

3) Clear, concise, and easily understood documentation

The documents published by the ISB are far from being clear, concise and easily understood.

The ISB staff developing the ISB data model need to use the ERwin software to view, develop and maintain the data model behind all the published ISB documents.

However, the “other side” of the process (organisations wishing to develop systems conforming to ISB) do not have any of that functionality, and are just provided with a set of static PDF documents, often containing 90% boilerplate text and 10% actual content.

There is also an XML Schema (xsd) file which partially specifies the XML representation of ISB data.  In order to obtain the full specification of this XML representation, an implementer is required to refer to the PDF documents.  No examples of XML files have been published.

To quote from the W3C, “XML Schemas express shared vocabularies and allow machines to carry out rules made by people. They provide a means for defining the structure, content and semantics of XML documents.”

The XML Schema provided by ISB defines the structure of an ISB XML file, but as a matter of policy declines to use the language of XML Schema to define the content and semantics of such files.

The main example of this is the lack of incorporation of controlled lists into the Schema, but also includes the lack of any documentation on the semantics of the structures being defined.  Instead, a user of the schema is referred to the many PDF documents as being the definitive source of documentation.

Given that XML will be the main method of transferring ISB data between systems, it is vital to ISB’s success that the documentation on the XML format is both accessible and unambiguous.  The XML Schema language should be fully used to aid in this task, not ignored.

It seems clear that the information published by the ISB needs to be stored in a structured way (e.g. in a database), and the content should be accessible via an interactive website.  In addition, the same database of information could be used to automatically generate PDF documents similar to those now created manually, or to create an XML Schema which as the W3C intended, would “allow machines to carry out rules made by people”.

4) Openness and fairness

In 2014, an independent review of ISB was undertaken, which included contributions from stakeholders outside the ISB and its constituent organisations.  However, the findings of this review have not been made public, not even to those who contributed time to the review. This is particularly shocking given this Administration’s emphasis on “transparency”.

5) Timeliness

It is difficult to judge the timeliness of the work of the ISB given that there is no apparent desire to implement any of the published standards.

And Now For Something Completely Different… Scholarly Articles from SDA!

SDA are delighted to announce two new peer-reviewed articles discussing their work to improve access to 1) School Performance data and 2) Free School Meals . Both papers have been spearheaded by Dr Alan Strickley, the former with contributions from SDA colleagues, and are available from

First up is:

A National Single Indicator for Schools in England: Helping Parents Make Informed Decisions

Alan Strickley, John Bertram, Dave Chapman, Michael Hart, Roy Hicks, Derek Kennedy, Mark Phillips.


With an ever-increasing measurement of pupil and school performance and presence of resultant statistical tables and indicators, parents are faced with a sometimes overwhelming plethora of data and information when monitoring the performance of their children’s present or prospective school. The authors are part of a company that has, using open data, developed a parent/carer-accessible site to attempt to address issues and needs for parents/carers. Anecdotal evidence indicates that a single portal where parent/carers can find all the relevant data about schools in England would be an invaluable tool for monitoring and choosing a school. It was decided that such a site would be built around a National Single Indicator (NSI). The indicator is formed from an amalgam of expected progress measures: the main threshold level; pupils’ average points score; and the value added measure. By changing the weight attributed to each of these measures, the website allows parents to modify their relative importance according to the value they place on them. This dynamically alters the overall result to give users their own “personal indicator”, which means they can compare schools in a list tailored to their own specification.

The website is available at

The second article is:

Online Free School Meals as a Cloud-Based Solution: Three Case Studies of Its Use in England

Alan Strickley


Online Free School Meals (OFSM) was a transformational programme supported by the Department for Education (DfE) in England. The full process is documented by Strickley[1]. Whilst the use of the system can be judged an overwhelming success, most Local Authorities (LAs) have stopped short of the full web-based system in which parents can apply directly via an online form as a result of the perception of negligible cost benefits created by a lack of technical expertise, scarce resources and server and development costs. The paper describes how these issues were overcome by developing a generic cloud-based solution. The paper looks at the general structure of the solution and examines the experiences of three types of user: an academy consortium, a single school and a large LA to illustrate adoption, implementation, usage and benefits. It concludes that a cloud-based system is cost effective by removing much administration and as a result of lowering the stigma of applying can result in an increase in applications. This has resulted in financial advantages for schools and LAs.

More information is available at


Reading Orwell’s 1984 was a formative experience for me. It helped determine my adult mistrust of the concept that we’re “all in this together”. The concept of Doublethink leaps out as the means by which this sort of fabrication might prevail.

Doublethink is the act of ordinary people simultaneously accepting two mutually contradictory beliefs as correct. Somewhat related… is cognitive dissonance, where contradictory beliefs cause conflict in one’s mind. Doublethink is notable due to a lack of cognitive dissonance — thus the person is completely unaware of any conflict or contradiction.”

Just recently SDA have been engaged in negotiations with, oh – let’s just say “”. Our old contract is being replaced by a “new model contract” through which doublethink runs as if it were a stick of Brighton rock.

Examples of the new doublethink:

“The singular includes the plural and vice versa” (ouch; I thought these were discreet concepts)

“The reference to a gender includes the other gender and the neuter” (ditto)

“The words ‘in particular’ and similar words shall not limit the generality of the preceding words and shall be construed as if they were immediately followed by the words ‘without limitation’” (erm… so “in particular” = “without limitation”?)

This would be laughable if it wasn’t so sinister. Hang on – let me practice my doublethink – yes… actually it’s laughable and sinister. And it gets worse as you plough on, into the details where white begins to merge into black. Here we go:

“The Authority shall not acquire any right, title or interest in or to the Intellectual Property rights of the supplier or its licensors…”

…except that the supplier must…

“Hereby grant to the Authority perpetual, royalty-free and non-exclusive licenses to use the supplier software (and background IPRs) for any purpose relating to the services (or substantially equivalent services) or for any purpose relating to the exercise of the Authority’s (or any other Central Government Body’s) business or function.” (My italics.)

So just to be clear: they don’t want anything except complete and perpetual carte blanche to use suppliers’ IPR throughout Government! And STILL it goes on:

The Authority… may assign, novate or otherwise transfer its rights and obligations under the licences granted… to any body (including a private sector body) which performs any of the functions that previously had been performed by the Authority. (Yes, my italics again)

For the avoidance of doubt (a phrase which makes frequent appearances in this New Model Doublethink, sorry, contract) when you sign this thing you’re letting the Government use your stuff – or just give away your stuff for others to use – for ever. So next time you go head to head with, say REDACTED to provide the service you invented, don’t be surprised when they give you the finger. What they’re saying is “We sort of said we didn’t want your stuff (and then we sort of insisted we did) and, hey, now we’ve got it for free, forever… well, these guys are our mates/cost less (given we’ve got your IPR)/have another couple of years to run on their contract (and we’ve got your IPR).”

Oh – a final poke in the eye: the document you’ll be signing is doublethought thus:

No warranty is given by the REDACTED as to the completeness of this document or its suitability for any purpose. (Their bold and underline, so it must be important.) I take this as saying “This document nails you to the floor but we don’t even acknowledge that it’s fit for purpose.”

I guess that one man’s* doublethink is another man’s cognitive dissonance

(*where reference to a gender includes the other gender and the neuter).

Digital Services: The Machinations of Government

Where are we with Government Digital Services?

  • We’ve got: the philosophy, rationale and economics.
  • We’ve got: the direction, process and standards. (OK, not standards – but it’s the thought that counts.)
  • We’ve got: the frameworks, guidance and manuals.

And lots of other stuff from strategy to operations. The Government Digital Service (GDS) has done a heroic job of walking through how Government as a Platform might work. Could work. Hats off to them. Really. No, I mean really. But there’s a fly in the ointment. Maybe two.

A quick review

This is where we are. We have the Digital Marketplace – “A simpler way to buy and sell digital services in the public sector” – which has now replaced the Cloudstore, and is the shop-front for the G-Cloud framework; and the Digital Services Store – “The place to find digital service design and development” – which does the same for agile digital services through the Digital Services Framework.

NB: Actually there’s a third fly in the ointment: clarity, as in lack of. Unless you’re at the heart of things this all begins to look rather blurred.

The Ointment and the Flies

This is not going to be a long blog because the points are really straightforward.

Here’s the ointment. It is the ambition of the GDS to transform what used to be called the IT function. This means, amongst other things, ensuring that services are built around the citizen and that they are digital by default. The “other things” include dismantling the monolithic service provision of yesteryear and, the other side of the coin, opening up the market to Small and Medium Enterprises.

And here are the flies.The first relates to the Digital Marketplace – the home of public sector commodity computing. Fantastic. Neat slices of retail computing via infrastructure as a service; platform as a service and software as a service.

Now what was the fourth? Oh yes, specialist cloud services. Home of REDACTED et al, all providing bespoke “cloud” consulting services. Now, did I say “monolithic” somewhere back there?

(Oh, and just to avoid accusations of hypocrisy – yes we’re on it. How else to compete?)

The second fly relates to the… erm (consults notes)… Digital Services Store. I could write my own critique but Dominic Campbell nailed it in his recent FuturGov Blog when he said:

“The rigid structure of the framework, combined with mandatory on-site working, make it commercially challenging for SMEs to deliver work through it. Additionally, it lays out a model for multi-million pound, long-running programmes of work but overlooks this model’s unsuitability for small and medium-sized projects.”

Dominic also quoted Harry Metcalf of dxw who got right to the heart of my beef:

“It’s a way to buy people, not projects. The framework is essentially a mechanism for body-shopping, which is just not workable for most suppliers.”