National Data Strategy Consultation - Which? response

Introduction

Which? welcomes the opportunity to submit a response to the consultation on the Government’s National Data Strategy. We welcome the intention to support the UK in building a world-leading data economy. Which? firmly believes that digitisation and the use of data can bring substantial benefits and has great potential for consumers. In looking to secure these benefits, there should be a focus on ensuring that consumers have control of their data and are able to trust the way that data they share is collected and used. A truly world-leading data economy should ensure that people have confidence in the systems that deliver it.

Which? is the UK’s consumer champion. As an organisation, we’re not for profit - a powerful force for good and here to make life simpler, fairer and safer for everyone. We fund our work mainly through member subscriptions. We are not influenced by third parties - we never take advertising and we buy all the products that we test. Which? works in pursuit of its charitable objects for the public benefit.

In Which?’s capacity as the UK’s consumer champion, we have chosen to answer those questions which allow us to draw on our experience in consumer protection in the data sphere to present evidence and recommendations that draw on our expertise. We believe that there are other stakeholders and organisations that are well-suited to consult on the other areas of this consultation. Our response therefore will concentrate on questions relevant to consumers, or work Which? has undertaken and published that could bring insights, guidance or recommendations for the National Data Strategy team, going forward.

Overall, Which? is supportive of the National Data Strategy and welcomes a focus on data as a driver for a thriving digital economy; for the wider societal good, as well as for consumers. Consumers, however, are not well considered by the strategy, which focuses on the role of government and the private sector. We believe a National Data Strategy must be people-centric, and we propose ways in which the Government can bring people into the conversation about data to help shape the strategy and its implementation.

We believe the strategy to be very ambitious and are keen to see an action plan that sets out how it will be achieved. We offer our insights about security - of data on devices and in services, as well as the security of data infrastructure providers - and we caution against over-reliance on dominant infrastructure providers. Our response also discusses our views on strengthening GDPR and details where trade deals could impact UK citizens’ data rights, now or in the future. Underpinning our support of the strategy, and any comment we make about improving and strengthening it, is our desire to support consumers across the UK to get the best possible outcomes from the data opportunity; building consumer trust in data and data-driven services will be of paramount importance in ensuring the strategy is successful.