You have a duty to provide the requested information in an electronic form “which is capable of re-use”.
The Explanatory Notes to the Protection of Freedoms Act 2012 say that:
“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” (note 389).
The ability to re-use and manipulate the data depends on it being machine-readable and based on open standards.
“Machine-readable” means that the data must be structured. It is not enough that the user can read the data in a document on a computer screen. The software needs to have the ability to extract specific elements of the data. This is possible if the data is in a structured form, such as a spreadsheet, but it is not normally possible if the data is contained in the text of an unstructured document in Word or PDF format.
The Explanatory Notes to the Protection of Freedoms Act 2012 show that the term “capable of re-use” means that not only does the data have to be machine-readable, but also available in a format based on open standards, rather than a proprietary format. For example, a spreadsheet that is made available in a CSV (comma separated value) format uses an open standard. However, a Microsoft Excel spreadsheet is not open standard, even though that particular product is widely used. However, the Excel spreadsheet can be saved as a CSV file. Regulation 2 of the RPSI contains the following definitions, which are helpful in interpreting the phrase ”capable of re-use":
- Machine readable format means a file format structured so that software applications can easily identify, recognise and extract specific data, including individual statements of fact, and their internal structure;
- Open format means a file format that is platform-independent and made available to the public without any restriction that impedes the re-use of documents.
- Formal open standard means a standard which has been laid down in written form, detailing specifications for the requirements on how to ensure software interoperability.
It’s possible to re-use a dataset made available in a CSV format, but you can improve the re-usability of data beyond that level. The "Open Data White Paper, Unleashing the potential" refers (at pages 24-25) to the Five Star Scheme developed by Sir Tim Berners-Lee and indicates that the Government intends to adopt it as a measure of the usability of its open data. There is no mandatory requirement that you achieve a certain level on this scheme in order to comply with the dataset provisions, but it can serve as a tool for assessing the re-usability of data. The Five Star Scheme also refers to the issue of open licences; the requirements of the dataset provisions in relation to licensing are discussed below in this guidance document.
The Code of Practice issued under section 45 of FOIA provides additional advice on how to improve the re-useability of datasets, see paragraphs 11.17 – 11.19. This includes following the Public Data Principles where possible.