Our response to the consultation on the design of rail services for Wales and the borders

Black and white picture someone looks out of a train window
Watching the World go by by Jeremy Segrott used under CC BY 2.0

Transport for Wales consulted people on the design of rail services for Wales and the borders. ODI-Cardiff responded to that consultation. This is a copy of our consultation response. We work with and support the network of people working with open data across Wales. This consultation response was put together with the assistance of many people from that network.


The new rail franchise presents significant opportunities to benefit the communities of Wales and the borders. The consultation on the design of the rail franchise leaves out a vital component. If TfW addresses this, it will significantly enhance the effectiveness of rail and other transport service design. That component is data. To operate effectively, the franchise holder, TfW and other stakeholders will need to share a wide range of data across the life of the franchise. The franchise will also generate data through its operation and will consume data from third party sources. The decisions taken by TfW at the start of the franchise about the publishing, sharing and ownership of data will have profound consequences on design possibilities along the franchise life. As a hypothetical example: In the future, metro rail services may be tightly integrated with bus services. As a light rail train is ready to depart a station it would be helpful to understand the location of a bus that is delayed and the number of passengers the bus is carrying. If the bus is nearby and is full the rail service might wait for the bus. This prevents overcrowding on the platform and significant ongoing delays to following services. In order to achieve the scenario described above would require good data infrastructure, combined with dynamic timetabling and effective automated decision making. Those things do not need to be designed and built now. They may never need to be designed and built by TfW or the franchise holder at any point. As long as the data infrastructure is in place, then the technology that uses that data can be supplied when it is appropriate and, potentially, by other investors in the technology market. If TfW specifies a largely closed data infrastructure (or worse still, does not specify data infrastructure at all), then little data will be available to third parties. It will be hard (and potentially expensive) to gain access to data for those third parties and innovation is likely to be significantly hampered. If TfW specifies a largely open data infrastructure, third parties would be able to access relevant anonymised data dynamically via APIs and to use and reuse the data in their own services. This will support innovation in services and access to services across Wales and the borders. This innovation could come at no cost to TfW or the franchise holder and without requiring those bodies to become involved in the development of services. Network Rail is already providing such open data to the community on a national basis leading to websites such as Real Time Trains. The decision by Transport for London to open up their data led to over 8,200 developers signing up to the program and more than 500 apps being created in the first two years that it has been online. Open Data and associated “Hackathons” have provided innovative solutions. For example Transport for London has been able to provide better quality service to their customers whilst reducing the normal costs associated with developing such software. For these reasons we strongly encourage TfW to urgently develop a data policy and infrastructure plan. We propose a set of principles which, we believe, should underpin such a policy and plan if they are to be effective for Wales.

Our proposed data principles for the rail franchise

Principle 1: presumption to publish and open

There should be a presumption that data will be published under an open licence in a timely fashion. There should also be a presumption to share data as widely as possible throughout the franchise. The Open Data Institute has published a guide to How to embed open data into the procurement of public services.

Principle 2: rights to the data

TfW should consider at design stage the rights in the data that is used and created across the franchise. Some of these rights will lie with the people using the service. These rights are expanded in the GPDR. TfW has an opportunity to use data infrastructure to give people more control over the data about them that will be gathered within the franchise. TfW should use open APIs to create opportunities for innovation by the people and companies of Wales and the Borders. For the avoidance of doubt TfW should be clear about who has rights over what data across the franchise. Where possible data created as a result of the operation of the franchise should be vested with TfW. TfW should also have rights to all data inputs into the franchise unless it is not legal or feasible to do so. Where TfW cannot have rights to the data it should by contract ensure that data is published and shared in a timely fashion in line with Principle 1.

Principle 3: data infrastructure plan

TfW should develop, publish and maintain a data infrastructure plan. This should identify the datasets that are required and will be generated within the franchise. The plan should also show how that data will be governed in a way that benefits the communities of Wales and the borders. There is more information how governance relates to data infrastructure for transport in this report for the Transport Systems Catapult. It is important that this plan is owned and maintained by TfW itself and not by the franchise holder to avoid conflict of interests over the collection and release of data. The data infrastructure plan should make it clear how datasets will be maintained and accessed by stakeholders. We suggest that TfW should minimise the requirement to hold data itself. Instead it should require data to be made available to itself and to other stakeholders via suitable APIs. Given the length of the franchise and the speed at which digital technology advances the data infrastructure plan is likely to require significant redrawing at regular intervals through the life of the franchise.

Principle 4: appropriate open standards

However it is published, provided or shared: all data across the franchise should adhere to appropriate open standards and formats. The UK Government provides a comprehensive set of guidance and tests to establish whether a standard is open or not.

Principle 5: develop policy about withholding data for security or crime prevention reasons

TfW should develop, in partnership with relevant experts, a policy toward the suppression or masking of data for security reasons or the prevention of crime. This investment in policy would be to avoid unnecessary or unhelpfully risk averse decisions being made during the life of the franchise. Any decisions not to publish, share or open certain datapoints or datasets for the protection of the public should be made against a clear policy drawn up with a clear understanding of the risks and benefits of publishing and suppressing certain types of data. Where possible, and in the interests of transparency, the reasoning behind each decision should be placed into the public domain to ensure that all and any users of the system understand the restrictions on the datapoints/sets. The police already publish crime maps and other forms of open data and may have advice to contribute.

Principle 6: use of third party data

TfW should lay out its policy towards the use of third party datasets. In particular throughout the franchise there should be a presumption not to duplicate data held by other organisations  but instead to access the data when required via APIs (for example accessing crime data through data.police.uk). TfW should also encourage third party holders of relevant data to publish their data under open licences via APIs and adhering to appropriate open standards.

Principle 7: working with open data communities

TfW should encourage the use of open data sources wherever possible and actively contribute back to these datasets.

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