A message to the DfE’s Information Standards Board

Of all the denunciations thrown across the floor of the British House of Commons, “In the name of God, go!” occupies a special place. It was first used by Oliver Cromwell when he dismissed the Long Parliament in 1653. In 1940, it was used by Leo Amery to call for the resignation of Neville Chamberlain, opening the way for Winston Churchill to come into Number 10. More recently, it has been used to call for the resignations of Gordon Brown and Silvio Berlusconi. Only Margaret Thatcher, at the hands of the more emollient Geoffrey Howe, was spared the British political equivalent of Robert Louis Stephenson’s black spot[1]. It is a call that is only appropriate at the final resort, when the last possibility of reasonable discussion has past. In the case of the DfE’s Information Standards Board, that point has now come.

The ISB holds responsibility in the DfE for the development of data standards to improve interoperability. On this blog, I have started (see Scrapping “ICT” and Aristotle’s saddle-maker) but not yet finished making the argument that will conclude (as did BESA’s Policy Commission of 2008) that these interoperability standards are critical for the intelligent application of education technology. It is in this context that the failure of the ISB should be judged.

The ISB website says that it first met in April 2006—but I do not believe that any outsiders were aware of its existence until the Spring of 2008. In July 2007 I had founded SALTIS, which resolved at its inaugural meeting to press Becta to address interoperability standards, revealed as woefully inadequate by their 2006 learning services procurement. By early 2008, I was being told by Becta that their hands were tied, as responsibility for interoperability was being assumed by the ISB, which seemed to be undergoing a long-drawn-out reconstitution under the joint sponsorship of the DfE and BIS.

As far as the industry was concerned, the ISB remained completely invisible until February 2009, when they issued their first newsletter, soliciting applications to join their Board. I responded in my role as Chairman of SALTIS, the only industry body to represent the interests of the education technology industry in respect of interoperability standards. After a delay of more than three months, my request was turned down on the grounds that the ISB believed that any industry representation would undermine its impartiality. Apart from this exchange, SALTIS had no contact with the ISB, which nevertheless cited SALTIS in its annual report as one of two industry groups with which it was in contact[2].

The ISB held its first stakeholder’s event in April 2009. DfE officials explained that the ISB’s remit was to oversee a process by which data standards should be approved for use in the “ESCS system”[3]. Officials from Becta  introduced me to someone from Atkins, a management consultancy which was in charge of the ISB’s Technical Support Service. I asked what their strategy was for ensuring that the ISB’s standards were implemented and how they could expect the industry to have confidence in a process from which it was completely excluded. He replied that they had not yet given much consideration to the question of implementation and agreed that they should do so in the coming months.

In practice, both Becta and the ISB believed that they would be able to mandate their standards through Becta’s procurement frameworks. In the meantime, their major concern lay elsewhere. Contrary to expectations, people were not flocking to the ISB’s door bearing specifications for its approval. Only one standard was approved by the ISB in its first year (XCRI, a JISC/CETIS standard for the circulation of course informaton in tertiary education); in its second year it approved Becta’s Common File Format for interactive whiteboards (a standard which never worked properly, as I pointed out to them after it had been formally approved). Both of these standards were subsequently removed from the ISB’s catalogue without any notification. The only other petitioner of any note was SIFA, whose requests for the approval of SIF were consistently refused (a matter which I shall discuss in detail a future post—on this particular point, John Callery, who worked at the ISB until Spring 2010 got it right).

Faced with a dearth of candidate specifications, the ISB started to create its own—mainly in a single burst of activity between September and November 2009. Of the 25 standards currently listed on the ISB website, 23 were created by the ISB itself; and of these, 20 were created within a single two-month window. Even though SALTIS was listed as the ISB’s main contact with the industry, I am not aware of any industry consultation whatsoever on whether these standards were appropriate or even workable. In January 2012, all 20 of these standards remain in draft and no-one has ever implemented them.

Not only have the standards not been implemented; they are incapable of being implemented in a consistent manner that delivers interoperability. The major part of the ISB standards comprises a data entity relationship diagram—an abstract model often used in the design of a new database. It shows how the database is to be structured and how the different tables are linked together. It is like a plan showing how the furniture in your sitting room should be laid out. It does not show how that furniture should be transported between one place and another. Such a document would need to show how the furniture should be packed (a data binding), moved (a transport mechanism) and what process is going to be followed for handing it over (a protocol). The ISB standards, which include none of these things, manage at the same time to do too much and too little.

These standards are now being imposed unilaterally on the industry, which is mandated to implement them as one of the conditions for bidding for the IMLS Framework. As part of the tendering process, potential bidders are allowed to ask clarification questions. Q&A 43 ran as follows.

Q. L1D3.11 para (c) states: Potential Providers of Information Management Services shall ensure their products and services support new and updated standards as and when they are published by the ISB.

Please advise what procedures exist within the ISB to protect suppliers against the future imposition of data standards which are technically unsound or prohibitively expensive to implement?

A. The ISB processes and procedures are designed to ensure that standards which are recommended for adoption have been through a rigorous consultation process in order to reach agreement with stakeholders prior to being signed off and published (and, therefore any potential issues will have been resolved during the consultation process).

In respect of the likely costs of any adoption, as part of the consultation process the ISB will be mindful of suppliers’ software update schedules where possible, to minimise the impact of any changes.

The answer given to this question is completely untrue:

• there was never any public consultation;
• there was never even a private consultation with the industry;
• any private consultation that might have occurred within the public sector was clearly hurried, as the interval between the first and last drafts never took more than two months;
• no documentation for such a private consultation has ever been published.

Q&A 204 ran as follows:

Q. Whilst the ISB web site has a list of standards none seem clearly to be marked as recommended, adopted or deprecated – please advise which standards are now sufficiently developed to allow commercial adoption.

A. All published standards are sufficiently developed to allow commercial adoption.

This is a curious answer considering the fact that the standards are still in draft, have never been piloted, have never been subject to formal consultation, and are inconsistent with current general practice, as revealed by Q&A 85:

Q. The CBDS [Common Basic Data Set] does not currently conform to the ISB Data Architecture model. Please provide more information.

A. The DfE is committed to aligning CBDS and its collections with the ISB standards as part of a rolling programme of work.

In respect of the ISB’s “rolling programme of work”, it is worth noting that only one standard has seen any activity since May 2010, when the contract for Atkins to provide the ISB’s Technical Support Service lapsed.

Q&A 42 also confirms that the standards have never been piloted and are not sufficiently precise to support consistent implementation in future.

Q. Mandatory requirement 25 states that: All data shall be accessible to third party products and services, (authorised by the Establishment) through both an automated system (not requiring a manual export of data), and via a manual export of the data; and [that]… The format of the information to be exchanged shall comply with those standards recommended by the Information Standards Board for education, skills and children’s services (ISB).

Given that the ISB’s BDM standards are presented in the form of an abstract entity relationship diagram, and lack either a data binding or transport mechanism, please provide details of a reference implementation which shows how these standards can be used to achieve effective interoperability, as required by the ITT.

A. The ISB standards define only the structure and semantics of data used for information exchange, and do not impose technical constraints on how this data can be transported or which encoding scheme is used for data binding.

The fact that the ISB standards are incomplete means that if two suppliers implement them, it is almost certain that they will be implemented in different ways, so that the two systems, which will have both used their best efforts to implement the ISB standards, will not interoperate.

At BETT, I spoke to all the companies that one would assume were bidding for the IMLS framework and they all agreed: these were “non-standards”. They would do their best to achieve something that could be presented as compliance (which it was clear, no-one was going to evaluate with anything approaching rigour) because, even though most of them did not expect to get much business through the framework, it was a list of suppliers that they could not afford, for reputational reasons, not to be on. Such is the Alice-through-the-looking-glass world which the ISB and the DfE runs.

The failings of the ISB’s standards do not just indicate a technical misunderstanding: they reflect the whole prescriptive, bureaucratic mind-set which permeates everything that they do.

Consider two possible approaches to standardisation:

• you can standardise things, in the interests of imposing conformity;
• or you can standardise interfaces, in the interests of enabling diversity.

At ISB’s stakeholders event in April 2009, the DfE’s PUS, David Bell, made a keynote speech all about the need for more conformity. I indicated my concern at this approach to Dorian Bradley, next to whom I happened to be sitting. Mr Bradley is Chairman of the ISB, even though, as an ex-Director of Ofsted, he has no technical expertise or any prior experience of standards processes. According to the first of the two approaches suggested above, you might specify a standard toaster and forbid anyone to buy anything which had an unauthorised number of slots, controls, or colour. According to the second approach, you would create a standard three-pin-plug and socket, precisely so that anyone can buy whatever sort of toaster they like, from whoever they like, and still plug it into the mains. I suggested to Mr Bradley that we should be creating the standard three-pin-plug and not the standard toaster. He said that he was very pleased with the analogy, which was new to him, and which he told me he would remember carefully.

When I met Mr Bradley again two years later in the DfE, he introduced himself by saying that he saw the ISB’s role as being to create the equivalent of the three-pin-plug. I felt little pleasure at the fact that he had remembered my speech, the point of which it was clear that he had never understood. By focusing on database designs, the ISB standards were specifying how different systems should be internally implemented, without specifying how they should talk to one another. This is the opposite of the three-pin-plug, which specifies how appliances should talk to one another, without specifying their internal implementations. Standardizing things reveals the mind-set of the bureaucratic regulator; standardizing interfaces is what builds free markets.

My second meeting with Mr Bradley followed from an Interoperability Summit, hosted by the DfE’s Chief Information Officer’s Department in January 2011. This was mainly attended by representatives from the ISB and SIFA-UK and when I suggested that the bi-polar nature of the summit reflected a rather narrow perspective on the problem, I was invited to the second meeting, just with Dorian Bradley and Ken Anderson, Deputy Directgor of the DfE’s Chief Information Officer group, and member of the ISB Board. At this second meeting, I suggested that if the DfE wanted to make progress in improving interoperability standards, it should pay more attention to engaging industry in its processes, respecting the role of the industry in leading innovation, and not rely on the blunt and illusory instrument of mandating on the industry standards written in Whitehall. I was promised a quick response within two weeks but, inspite of a number of chasers, received no further follow-up from the meeting.

As before, my advice seemed to have been heard but not understood. On 22 July 2011, the ISB held the inaugural meeting of a new Special Interest Group for suppliers. Even as the ISB acknowledged the need to involve the industry, it continued to show it’s mistrust by  the way that it attempted to control the process:

• the only organisations to be invited were those with which members of the ISB had themselves had direct contact—this reflected the centralized, administrative focus of the ISB and excluded nearly all publishers of education software;
• membership of the group was not restricted to commercial suppliers, but included public sector organisations which happened to have developed their own software, —these organisations were classed as suppliers even though they were not dependent on commercial funding, but rather represented the bureaucratic interest;
• the ISB proposed that a steering group for the new suppliers group should be formed of volunteers selected from the unrepresentative first meeting;
• the ISB proposed that the eventual SIG should be constituted in a way that reflected the bureaucratic structure of the “ESCS system”, with a certain number of representatives for the school sector, FE, and HE.

Opposed to this model, I argued for a “standards incubator”, which would allow innovative groups of companies to bring forwards candidate specifications, again arguing that the ISB was approaching the requirement for standardisation from a narrow, bureaucratic perspective. Mr Bradley decided that the two approaches should be represented by two different SIGs: one to work on what he termed “known” and one to work on “unknown” standards (later renamed to the “Understood” and “Emergent” SIGs). My immediate perception (in which other commercial education technology providers present also concurred) was that this represented an attempt to control the “Understood” SIG and to side-line the “Emergent” SIG. Mr Bradley denied my suggestion that he was attempting to kick the Emergent SIG into the long grass. I advised members of SALTIS to express interest in joining the Emergent SIG, which was the only one which I believed could give real freedom to the industry to develop standards that were effective and appropriate to their needs, and to challenge the prescriptive model of the ISB.

Although forty companies expressed interest in joining the SIG, no action was taken by the ISB to set this up on the totally spurious grounds that the extent of interest was still unclear[4]. It was not until a meeting at the DfE on 15 December, arranged by Lord (Ralph) Lucas, that I was able to complain about this lack of action. Following this meeting, the ISB announced on 4 January that the steering committee for the Emergent SIG was to have a meeting on 1 February, inviting anyone who had previously expressed interest in the SIG to volunteer for membership of the Steering Committee. I responded to this invitation, at the same time expressing my concern that it was being proposed that the Steering Group should be self-selected, rather than properly elected by members of the SIG. I also expressed concerns about the very limited remit which the new SIG was to be given:

The output of the SIG (as and when) is expected to be proposals for ISB projects or actions to be put forward for ISB consideration…Where the SIG wishes the ISB to consider one of its proposals, then a paper will need to be put forward to the next ISB meeting…a member of the TSS will present papers produced by the SIG to the ISB.

In other words, papers produced by the SIG would be sent up for the consideration of the ISB, and the industry SIG would be bound by the decision of the ISB, made at a meeting at which no member of the industry SIG would be present. What was being offered to the industry was no kind of partnership, but a totally subordinate role.

I received no reply to my email expressing concerns except that, as I was the only person to express interest in serving on the steering group, the ISB announced on 20 January that the meeting scheduled for 1 February would now involve the entire SIG. I objected to this announcement on the grounds that it was improper for the ISB to call a new meeting with only 11 days notice: many interested members of the SIG would not be able to attend and any decisions taken would in these circumstances not be legitimate. Most constitutions and club rules, even for the local village hall committee, have minimum notice periods of meetings for precisely this reason. I withdrew from the meeting and advised members of SALTIS to do likewise.

The ISB again did not reply to my email, proceeding to circulate an agenda and attendance list on 27 January. Apart from four members of the ISB Technical Support Service, the attendance list includes only four attendees, one of which is a standards consultant; one of which had already copied me into an email to the ISB secretariat, informing them that they were unable to attend at such short notice; and the remaining two of which both represented Capita.

Any credible standards organisation needs to pay particular attention to the propriety of its procedures and the transparency of its activities. The DfE’s answer to Q&A 43 claims that the ISB’s “processes and procedures are designed to ensure that standards which are recommended for adoption have been through a rigorous consultation process”. And yet they are willing to proceed with an important inaugural meeting which any reputable organisation would regard as having been called with inadequate notice and inquorate. Until I recently raised the issue, the ISB had published no agendas, attendance lists or minutes. It subjects its standards to no public consultation, nor does it observe any formal process for the deprecation of standards previously approved. It observes no separation of powers between the creation and the approval of standards. It has no regard for due process in the way that it appoints people to steering groups. It gives a pretended legitimacy to damaging bureaucratic interventions in the market and, worst of all, it has over nearly six years proved completely ineffective in helping to improve interoperability standards for education technology.

I shall be pursuing the issues raised in this post through FOI requests and (with respect to the IMLS Framework) through formal complaints to the Government Procurement Service, the Public Administration Select Committee and the European Commission, as turn out to be required. In the meantime, I hope this post has done enough to show why we have reached a point where Cromwell’s words now fit the case:

You have been sat too long here for any good you have been doing. Depart, I say, and let us have done with you. In the name of God, go!