Dear Federal Councillor
Ladies and Gentlemen,
You have invited us to comment within the framework of the consultation on the Swiss Federal law on digitalisation for the fulfilment of administrative functions (EMBaG). We are pleased to be able to take the opportunity to do so.
Since 2011, Opendata.ch has been working to ensure that more people have access to more data, and can use it to generate more knowledge, progress and added value. Organised as a non-profit association, Opendata.ch has been networking and organising around data policy and technology concerns for years and, among other things, carries out interdisciplinary innovation formats with hackathons.
The promotion of an open data culture at all administrative levels is a particular concern of the association, also in its long-standing cooperation with the federal government.
Opendata.ch welcomes the general direction of the new law. However, we are of the opinion that, especially in the rapidly changing field of digitisation, a number of developments that are already underway must be taken into account even more strongly and quickly. This is in order to maintain the authorities’ ability to act adequately in the future, and to take into account the evolving needs of citizens, the economy and civil society.
In the present version, the articles on open data and open source lack the necessary broad impact, the necessary commitment and the indispensable instruments to effectively initiate and continuously measure decisive steps towards successful digitisation. We sorely miss an article on the topic of interfaces, the importance of which is constantly increasing. We also sorely miss in the preliminary draft the possibility of cooperation between the authorities not only with companies, but also with organisations of digital civil society, not least the associations in the area of open source and open data.
Please find enclosed our detailed proposals for concrete improvement of the preliminary draft. We are confident that you will be able to take these into account in the further process. We can only support the current preliminary draft in this way, i.e. with more targeted, binding formulations on the topics mentioned and greater consideration of civil society. We thank you for the attention you have paid to our comments and ask you to take our concerns into account.
Andreas Kellerhals, President Opendata.ch
Hannes Gassert, Vice President Opendata.ch
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