Open Procedures (FI0021)

Issue to be addressed: Visibility of government projects. The aim of the Act on the Openness of Government Activities is to ensure openness of government activities and give the citizens and other actors of the society a possibility to monitor the use of public authority and public funds, to formulate their own opinions and to influence the use of power and to safeguard their own rights and needs. Digitalization has increased possibilities to enhance openness. The expectations of the citizens have however increased faster than the government practices have advanced. Since 1999 information on government projects has been available via Government Project Registry (HARE). The registry is now being renewed. The use of this new registry by the ministries needs to be assured and the knowledge of it increased among the citizens and the media. Updating the instructions for legislative drafting. Ministry of Justice has given instructions for legislative drafting. Instructions need to be updated to meet the needs of the changing operational environment. The needs of children and the youth as well as people with special needs are taken into account as well as the obligations of the new Municipal Law. The established open government networks can collect needs for additional instructions and handbooks. The open government network of state government and the open government network of municipalities are also ways to implement the instruction to the administrations. More web castings in government. Web castings of events organized by government are provided. The wider use of web castings is hindered e.g. by additional cost of organizing them. Better and more cost-effective ways of providing web castings are needed and they need to be more extensively implemented. Enhancing openness within the government: In order to be open to the citizens the government needs to be internally open. Sharing information and working together within the government is essential for the government to be able to handle horizontal wicked problems. The need for a lobbying register is assessed. According to the Corruption Index of the Transparency International, Finland is the third least corrupted country among the 175 countries evaluated. The first two places are held by Denmark and New-Zealand. Despite this good rating Finnish government needs to continuously work to remain and improve the existing level of trust. Possible creation of a lobbying register has been addressed by The Committee on Ethics of State Civil Servants in a report published in 2014 (Report in Finnish: Valtion virkamieseettisen toimikunnan raportti VM 3/2014).
Main Objective:
Opening the government procedures. Milestones and Indicators. 1. Renewed government project registry (HARE) has been opened and it is used by all the ministries. Indicator: % of all government projects published in HARE. Survey in 2016 and 2017. 2. HARE is well known by citizens and media.
Indicator: Number of users. 3. Instructions for legislative drafting have been updated. 4. Number of interactive web castings in government is increasing.
Indicator: Number of agencies providing web castings. Survey on 2015 and 2017. 5. Report on creation of a lobbying register and the possibility of providing it as open data has been published and conclusions of possible actions decided. 6. Open government is presented in the annual International anticorruption day event organized by the Ministry of Justice and the Transparency International Finland 7. Open government principles are also applied to horizontal work within the government. Indicator: Annual personnel survey of the government (VM-Baro).

Commitment 3. Open Procedures

Commitment Text:

Status quo or problem/issue to be addressed:

Visibility of government projects

The aim of the Act on the Openness of Government Activities is to ensure openness of government activities and give the citizens and other actors of the society a possibility to monitor the use of public authority and public funds, to formulate their own opinions and to influence the use of power and to safeguard their own rights and needs. Digitalization has increased possibilities to enhance openness. The expectations of the citizens have however increased faster than the government practices have advanced.

Since 1999 information on government projects has been available via Government Project Registry (HARE). The registry is now being renewed. The use of this new registry by the ministries needs to be assured and the knowledge of it increased among the citizens and the media.

Updating the instructions for legislative drafting

Ministry of Justice has given instructions for legislative drafting. Instructions need to be updated to meet the needs of the changing operational environment.

The needs of children and the youth as well as people with special needs are taken into account as well as the obligations of the new Municipal Law. The established open government networks can collect needs for additional instructions and handbooks. The open government network of state government and the open government network of municipalities are also ways to implement the instruction to the administrations.

More web castings in government

Web castings of events organized by government are provided. The wider use of web castings is hindered e.g. by additional cost of organizing them. Better and more cost-effective ways of providing web castings are needed and they need to be more extensively implemented.

Enhancing openness within the government

In order to be open to the citizens the government needs to be internally open. Sharing information and working together within the government is essential for the government to be able to handle horizontal wicked problems.

The need for a lobbying register is assessed

According to the Corruption Index of the Transparency International, Finland is the third least corrupted country among the 175 countries evaluated. The first two places are held by Denmark and New-Zealand. Despite this good rating Finnish government needs to continuously work to remain and improve the existing level of trust.

Possible creation of a lobbying register has been addressed by The Committee on Ethics of State Civil Servants in a report published in 2014 (Report in Finnish: Valtion virkamieseettisen toimikunnan raportti VM 3/2014).

Milestones:

1. Renewed government project registry (HARE) has been opened and it is used by all the ministries. Indicator: % of all government projects published in HARE. Survey in 2016 and 2017.

2. HARE is well known by citizens and media. Indicator: Number of users.  ^{This milestone is an indicator and therefore is not assessed as an individual activity in the table below.}  

3. Instructions for legislative drafting have been updated.

4. Number of interactive web castings in government is increasing. Indicator: Number of agencies providing web castings. Survey on 2015 and 2017.

5 Government is active in social media.  ^{Milestone 3.5 ”government is active in social media” is listed only in the Finnish language version of Finland’s national action plan. According to the interviewed government representative, this was not listed in the English version by accident.}

6. Report on creation of a lobbying register and the possibility of providing it as open data has been published and conclusions of possible actions decided.

7. Open government is presented in the annual International anticorruption day event organized by the Ministry of Justice and the Transparency International Finland.

 8. Open government principles are also applied to horizontal work within the government. Indicator: Annual personnel survey of the government (VM-Baro)

Responsible institution(s): Ministry of Justice, Ministry of Finance.

Supporting institution(s): State agencies, ministries, municipalities, civil society organisations, and employer and employee organisations.

Start date: 1.07. 2015...........                                     End date: 30.06.2017

Context and Objectives

This commitment aims to increase the openness of government procedures—a main theme carried over from Finland’s previous action plan. The Organisation for Economic Co-operation and Development (OECD) reports that confidence in government has declined between 2007 and 2014 in Finland.  ^{Organisation for Economic Co-operation and Development (OECD), “Government at a Glance 2015,” http://www.oecd-ilibrary.org/docserver/download/4215081e.pdf?expires=1475222878&id=id&accname=guest.}   Increasing the transparency of government operations and procedures could improve the public’s trust in the government and encourage greater citizen participation in decision making. While Finland ranks in the top 10 most open governments globally,  ^{World Justice Project Open Government Index, 2015 Report, http://worldjusticeproject.org/sites/default/files/ogi_2015.pdf.}  CSOs highlighted trust in government as an important issue in an online IRM questionnaire.

The commitment itself has eight milestones,  ^{The commitment milestones are fully described in the national action plan: http://www.opengovpartnership.org/wp-content/uploads/2001/01/OGP_Action_Plan_Finland-2015_2017.pdf.}  which address different issues related to open government practice. These include opening information about publicly funded government projects, updating consultation guidelines for drafting laws, and reviewing lobbying procedures and anti-corruption reforms.

Completion

Project register:

3.1. The joint project register (HARE) for ministries and Parliament will be replaced by an updated website called “Hankeikkuna.” The goal of the register is to open public project information to citizens, media, and CSOs. The register will include regularly updated information on the following: implementation of government programs, laws being drafted, proposed reforms, and development projects. It will also provide information on appointments to government institutions and working groups, strategies, and reports to Parliament. The register will be published internally to civil servants in October 2016 and to the general public in March 2017.  ^{Finland Midterm Report Self-Assessment, http://www.opengovpartnership.org/country/finland/assessment.}  

3.2. Ministries will provide training and guidance activities to enable civil servants to use the new project register. The new register will also be publicized online through government webpages and at public events. According to the self-assessment report, this communication has already begun and is linked to OGP activities. Members of the Civil Servant Network discussed the register in a meeting on 11 May 2016, and the slides are available online.  ^{http://vm.fi/documents/10623/1194961/Valtioneuvoston+yhteinen+Hankeikkuna+-+P%C3%A4ivi+Nurminen+VNK.pdf/3bed6fad-5846-48a9-b3c5-24371d76989c.}  However, according to a representative of the Ministry of Finance,  ^{Interview with the Ministry of Finance point of contact, 10 January 2017.}  implementation has been delayed due to a change in leadership. The Prime Minister’s Office is now responsible for implementation through the remainder of the commitment period. The register is under development within the civil service, with a public launch planned in 2017. As written, this milestone represented an internal government process of unclear relevance to OGP values.

Legislative procedures:

3.3. The government approved updated instructions for drafting legislation on 4 February 2016 and published guidelines for their use.  ^{Link to new instructions (in Finnish/Swedish only): http://kuulemisopas.finlex.fi/ohje/kuulemisohje/.}  In the revised consultation process, civil society stakeholders and citizens have opportunities to share their views on draft laws. The new guidelines have replaced the government’s decision-in-principle policy from 2010. According to the government self-assessment, the e-participation website, Lausuntopalvelu.fi, will be a platform for public consultation on policy making, and all consultations will take place online once government ministries have joined the document-handling system. The preparatory steps seem to be progressing on schedule but are of unclear relevance to OGP values.

3.4 and 3.5. The government intends to increase the use of webcasts and social media to provide citizens with information. In May 2016, the use of social media was a theme in “morning coffee sessions” for the highest-level leaders. The Civil Servants Network will review best practices for using online tools and will publish experience cards highlighting the key findings in the fall of 2016.

According to a member of the Ministry of Finance’s OGP team,  ^{Interview, September 2016.}  the government has not made this activity a priority. However, plans to increase webcasts are on schedule, and internal discussions are underway. In addition, the state’s Civil Servant Ethics Commission has published a statement providing recommendations and guidelines for social media use by civil servants and the government administration.  ^{Link to statement (in Finnish): http://vm.fi/documents/10623/2033991/Valtion+virkamieseettisen+valiokunnan+suositus/f6b3ae92-17ec-4d82-88f6-488ca1692abb.}  

Lobbying register and anti-corruption:

3.6. The government is considering creating a lobbying register and providing the information in an open data format. However, no assessments or active reviews have taken place at the midterm. According to an interviewed official, the government has not been able to decide on the right unit to carry out the work, which has delayed the process.
 

3.7 and 3.8. The government OGP representative gave a presentation at the International Anti-Corruption Day event on 9 December 2015. In addition, the government self-assessment and interviewed officials stated that increasing open government practices across ministries and agencies is a priority. However, these activities are of unclear value relevance to OGP.

Early results (if any)

There is little early evidence that the commitment has changed government practice as many activities in this commitment are in preparatory phases. Based on the limited level of completion and the inclusion of activities that lack specific relevance to OGP, the government has made limited progress on opening government after the first year of implementation. However, some stakeholders see the project register (3.1) as an improvement to access to information, and it could have a positive effect on opening government information once it is implemented. Milestone 3.3, related to updating instructions for legislative drafting, was completed, but it lacked a public-facing element and relevance to OGP values. One open government academic from the University of Helsinki  ^{Interview, 21 November 2016.}  said that updating the guidelines for drafting legislation is an important goal. However, the interviewee felt that the government should focus more on ensuring useful participation and achieving realistic goals using available resources for citizens to participate in legislative processes.

Next steps

The IRM researcher recommends completing the activities as planned and suggests organizing workshops with stakeholders to build on milestone activities and enforce implementation. Eight stakeholders responded to an IRM online questionnaire, and all considered both the commitment and its activities important. However, they believed that the government should apply the consultation process to all policymaking, especially in high-impact cases. The government could better include stakeholders early in the process, ensuring adequate time and ability to influence draft laws and outcomes.  ^{Interviews with Finnish Youth Cooperation–Allianssi, August 2016, and Transparency International Finland, August 2016.}  

A representative from academia thought the action plan was somewhat unclear on how to improve citizen participation and provide more accessible information on government activities.  ^{Interview with an academic from the University of Helsinki, 21 November 2016.}  He suggested that the government further develop the project registry (3.1) to improve indicators. Instead of measuring how many projects are included, the registry would be more useful if it included information on how recent the projects are, the levels of completion, and how to retrieve more information on outcomes. To be most useful in opening government, the registry should be more than an archive and should enable real-time monitoring to improve the transparency of government works. In addition, the legislative drafting milestone (3.3) should also include clear steps for incorporating the results from public consultations in the drafting process, for example, by use data-mining procedures.

Commitment 3. Open procedures

Commitment Text:

Visibility of government projects

The aim of the Act on the Openness of Government Activities is to ensure openness of government activities and give the citizens and other actors of the society a possibility to monitor the use of public authority and public funds, to formulate their own opinions and to influence the use of power and to safeguard their own rights and needs. Digitalization has increased possibilities to enhance openness. The expectations of the citizens have however increased faster than the government practices have advanced.

Since 1999 information on government projects has been available via Government Project Registry (HARE). The registry is now being renewed. The use of this new registry by the ministries needs to be assured and the knowledge of it increased among the citizens and the media.

Updating the instructions for legislative drafting

Ministry of Justice has given instructions for legislative drafting. Instructions need to be updated to meet the needs of the changing operational environment. The needs of children and the youth as well as people with special needs are taken into account as well as the obligations of the new Municipal Law. The established open government networks can collect needs for additional instructions and handbooks. The open government network of state government and the open government network of municipalities are also ways to implement the instruction to the administrations.

More web castings in government

Web castings of events organized by government are provided. The wider use of web castings is hindered e.g. by additional cost of organizing them. Better and more cost-effective ways of providing web castings are needed and they need to be more extensively implemented.

Enhancing openness within the government

In order to be open to the citizens the government needs to be internally open. Sharing information and working together within the government is essential for the government to be able to handle horizontal

wicked problems.

The need for a lobbying register is assessed

According to the Corruption Index of the Transparency International, Finland is the third least corrupted country among the 175 countries evaluated. The first two places are held by Denmark and New-Zealand. Despite this good rating Finnish government needs to continuously work to remain and improve the existing level of trust.

Possible creation of a lobbying register has been addressed by The Committee on Ethics of State Civil Servants in a report published in 2014.[Note75: Valtion virkamieseettisen toimikunnan raportti VM 3/2014, http://vm.fi/documents/10623/1107479/Valtion_virkamieseseettisen_toimikunnan_raportti_3_2014.pdf/ab866e15-a9af-456d-aca4-99b7b1c2e340.]

Main objective
Opening the government procedures.

Milestones:
3.1. Renewed government project registry (HARE) has been opened and it is used by all the ministries. Indicator: % of all government projects published in HARE. Survey in 2016 and 2017.

3.2. HARE is well known by citizens and media. Indicator: Number of users.

3.3. Instructions for legislative drafting have been updated.

3.4. Number of interactive web castings in government is increasing. Indicator: Number of agencies providing web castings. Survey on 2015 and 2017.

3.5 Government is active in social media.[Note76: Milestone 3.5 “government is active in social media” is listed only in the Finnish language version of Finland’s national action plan. According to the interviewed government representative, this was not listed in the English version by accident.]

3.6. Report on creation of a lobbying register and the possibility of providing it as open data has been published and conclusions of possible actions decided.

3.7. Open government is presented in the annual International anticorruption day event organized by the Ministry of Justice and the Transparency International Finland.

3.8. Open government principles are also applied to horizontal work within the government. Indicator: Annual personnel survey of the government (VM-Baro)

Responsible Institution(s): Ministry of Justice, Ministry of Finance

Supporting Institution(s): State agencies, ministries, municipalities, civil society organizations, and employer and employee organizations.

Start Date: 1 July 2015 End Date: 30 June 2017

Commitment Aim:

The commitment aims to increase government transparency and improve citizens’ trust in government by opening decision-making procedures to the public for monitoring. The commitment includes applying and distributing information on open government principles, publishing information on public projects, as well as making the government more visible on social media. Additionally, the government aimed to assess the need for a lobbying register.

Status

Midterm: Limited

At the midterm, plans had been made to replace the joint project register (HARE) for ministries and Parliament with an updated website for public project information called “Valtioneuvoston hankeikkuna” by March 2017. The updated instructions for drafting legislation were approved by the government on 4 February 2016, and guidelines for their use were published online.[Note77: Säädösvalmistelun kuulemisopas, http://kuulemisopas.finlex.fi/] All public consultation on policy making was to eventually take place online at the consultation portal Lausuntopalvelu.fi. The needs assessment for an open-data lobbying register was delayed by the lack of a leading unit within the government. In the self-assessment report, the government reported planning wider involvement with anti-corruption work but did not include any specifications. Several of the milestones (3.1, 3.7 and 3.8) were of unclear relevance to OGP values. For more information, see the midterm Progress Report.

End-of-term: Substantial

3.1. Project register opened and used and 3.2. HARE is well known:

The new online register for public projects, “Valtioneuvoston hankeikkuna,” was available to civil servants in January 2017,[Note78: Interview with Päivi Nurminen, the Prime Minister’s Office, 11 January 2018.] and opened to the public in June 2017. The end-of-term self-assessment report states that training for civil servants in using the “hankeikkuna” was organized, and the register was publicized extensively internally and externally.[Note79: Finland’s End-of-term self-assessment report, 2015–2017 (in Finnish), p. 9,
http://avoinhallinto.fi/assets/files/2017/10/Avoin-hallinto_-khoitsearviointiraportti-2017.pdf ] The Prime Minister’s Office reported having conducted a tour focused on digitalization and system reforms in 2016–2017, as well as presented the register to the ministries.[Note80: Interview with Päivi Nurminen, the Prime Minister’s Office, 11 January 2018.] Although occurring after the commitment implementation period, as of December 2017 242 new projects have been published on “Valtioneuvoston hankeikkuna”, and 11,340 log-ins have been made by ministry civil servants.[Note81: Statistics beginning on 9 January 2017. Interview with Päivi Nurminen, the Prime Minister’s Office, 11 January 2018.] This was an inward-facing reform, and of unclear relevance to OGP.

3.3. Updating instructions for legislative drafting

The instructions for legislative drafting were updated on 30 June 2016.[Note82: Instructions for legislative drafting, http://kuulemisopas.finlex.fi/ ] According to a representative of the Ministry of Justice, most ministries are actively using the consultation portal Lausuntopalvelu.fi.[Note83: Interview with Niklas Wilhelmsson, Ministry of Justice, 20 December 2017.] This was an inward-facing reform that lacked a public element and was of unclear relevance to OGP values.

3.4 and 3.5. Increasing webcasts and social media use
The government reported the need to find more economical tools for producing webcasts. The Ministry of Finance’s OGP team has evaluated that the commitment to increase webcasts was not prioritized by the government.[Note84: Midterm report, p. 35,

https://www.opengovpartnership.org/wp-content/uploads/2017/06/Finland_Progress-Report_2015-2017.pdf ] The Civil Servants Network intended to review best practices for using online tools and publish experience cards highlighting the key findings in the autumn of 2016,[Note85: Ibid. ] but the IRM researcher found no evidence this step had been carried out.

Out of six ministry Twitter accounts investigated by the researcher in November 2017,[Note86: Ministries of Justice, Education and Culture, Foreign Affairs, Defence, Economic Affairs and Employment, and Social Affairs and Health. Follower statistics compared by using the Wayback Machine, https://archive.org/web/] four had between 12,000 and 21,000 followers. The most popular account was that of the Ministry of Foreign Affairs, with more than 78,000 followers. Comparatively, one of the commitment’s responsible institutions, the Ministry of Justice, had just over 5,000 followers.[Note87: Ministry of Foreign Affairs on Twitter, https://twitter.com/Ulkoministerio; Ministry of Justice on Twitter https://twitter.com/oikeusmin. Twitter followers checked using the WayBack Machine, https://archive.org/web/] According to a representative of the Ministry of Finance, monitoring of the ministries’ social media usage is not centralized, but performed in each ministry separately.[Note88: Interview with Katju Holkeri, Ministry of Finance, 16 January 2018.]

3.6. Assessing need for lobbying register
This step was incomplete at the conclusion of the implementation period in July 2017. On 2 October 2017, the Prime Minister's Office opened a call for analysis, assessment and research activities supporting the government's decision making. The call was based on the Analysis, Assessment and Research Plan of 2018, which includes international comparative research on lobbying registers and their implementation as one of its themes.[Note89: Valtioneuvoston päätöksentekoa tukeva selvitys- ja tutkimussuunnitelma 2018, p. 4, http://tietokayttoon.fi/documents/1927382/5351063/Valtioneuvoston+p%C3%A4%C3%A4t%C3%B6ksentekoa+tukeva+selvitys-+ja+tutkimussuunnitelma+2018+p%C3%A4%C3%A4t%C3%B6sesitys.pdf/da762be7-abc8-4305-8493-733787e0be71 ] The call ended after the implementation period, on 9 November 2017,[Note90: The call for funding for analysis, assessment and research activities,
http://tietokayttoon.fi/haku/ilmoitus/-/asset_publisher/valtioneuvoston-paatoksentekoa-tukevan-selvitys-ja-tutkimustoiminnan-haku-2018 ] by which date six comparative lobbying register study proposals had been sent in.[Note91: Valtioneuvoston selvitys- ja tutkimustoiminnan hakemusmäärät teemoittain haku 2018, p. 3, http://tietokayttoon.fi/documents/1927382/5387078/Hakemusm%C3%A4%C3%A4r%C3%A4t+painopistealueittain+VN+TEAS+-haku+2018.pdf/2bcb341e-09dc-47e4-a87a-c2db8be57d69 ] The “International Models of Lobbying Registers” comparative research project led by the University of Eastern Finland launched on 8 February 2018.[Note92: Twitter post by Katju Holkeri, Ministry of Finance, 8 February 2018, https://twitter.com/HoKatju/status/961546549112295424 ] The government reported no additional anti-corruption measures in the end-of-term self-assessment report.

Open government principles, values, legal basis and a checklist for civil servants were published in the form of concise information cards called the Open Government Support Package.[Note93: Avoimen hallinnon tukipaketti,

http://vm.fi/documents/10623/1193298/Avoimen+hallinnon+tukipaketti_RGB_web_17052017.pdf/f0bc4b85-0894-460d-8f2b-c407f243c6dc ] According to the government’s self-assessment report, a survey on the realization of open government objectives was conducted in September 2017. The survey results suggest that open government principles have been diversely and broadly presented within agencies.[Note94: Finland’s End-of-term self-assessment report, 2015–2017 (in Finnish), p. 2,
http://avoinhallinto.fi/assets/files/2017/10/Avoin-hallinto_-khoitsearviointiraportti-2017.pdf ] However, results and findings from these activities are limited and occur beyond the period assessed.

Did It Open Government?

Access to Information: Marginal

Civic Participation: Did Not Change

Although Finland ranks third on Transparency International’s Corruption Perceptions Index 2016,[Note95: Transparency International’s Corruption Perceptions Index 2016, https://www.transparency.org/news/feature/corruption_perceptions_index_2016 ] corruption scandals have shaken citizens’ perception of government integrity, and there is room for improvement among the corporate social responsibility measures of the government’s administration.[Note96: Midterm report (in Finnish), p. 45,

https://www.opengovpartnership.org/wp-content/uploads/2017/06/Finland_Progress-Report_2015-2017.pdf] Finland is also currently one of five OECD countries without an institution responsible for design of integrity system policies.[Note97: OECD: Government at a Glance 2017, http://dx.doi.org/10.1787/gov_glance-2017-en] The commitment could do more in terms of monitoring campaign financing and anti-corruption ethics,[Note98: Midterm report (in Finnish), p. 45,

https://www.opengovpartnership.org/wp-content/uploads/2017/06/Finland_Progress-Report_2015-2017.pdf] but it has included a specific and measurable milestone for tackling the opaqueness of political influencing in Finland. A representative of Open Ministry has stated that the lobbying register would increase trust in the political system as well as support participation in decision making.[Note99: Open Knowledge Finland press release, 14 October 2017,

https://fi.okfn.org/2017/10/14/kiista-eduskunnan-vierailijatiedoista-kirvoitti-lobbaus-lapinakyvaksi-kansalaisaloitteen/ ] However, in spite of the large-scale media discussion on the topic, as well as wide-spread support for the commitment among lobbyists and communications specialists,[Note100: ProCom – The Finnish Association of Communication Professionals’ voluntary lobbying register,

http://procom.fi/procom/lobbarirekisteri/selaa-rekisterin-tietoja/ ] the “Make lobbying transparent” citizens’ initiative, launched by Open Knowledge Finland, Open Ministry, and Transparency Finland, has collected less than 6,000 signatures at the time of writing.[Note101: An initiative is delivered to Parliament for consideration if it gains 50,000 or more signatures. Lobbaus läpinäkyväksi –kansalaisaloite. 12 October 2017, https://www.kansalaisaloite.fi/fi/aloite/2653 ] Additionally, a CSO has publicly voiced a concern that the lobbying register could potentially create a market for increasingly specialized lobbyists, which would in turn concentrate influencing power to large organizations and media agencies, and raise administrative barriers for the influencing possibilities of small CSOs as well as citizens.[Note102: Comment by SOSTE Finnish Federation for Social Affairs and Health on the first consultation round for the II. action plan, p. 17,

http://vm.fi/documents/10623/1332423/Lausuntojen+huomiointi+avoimen+hallinnon+toimintasuunnitelma.pdf/ef7a5b7a-6f27-4f91-82e9-962af8f24793 ]

Transparency issues are also addressed in the commitment’s aim to publish government undertakings on “Valtioneuvoston hankeikkuna.” The transparency of the register as well as the scale of access of information it provides to the public are significantly decreased by the possibility that projects will only be published internally[Note103: “Hankeikkuna” steering group meeting minutes, 20 June 2017,

https://api.hankeikkuna.fi/asiakirjat/69921653-d558-48a4-8365-abfbcdf7aaa0/77c2f5b8-0f1b-4cc1-bf07-ee98bbb72701/POYTAKIRJA_20170904063623.pdf ]—an issue also highlighted by a representative of Allianssi.[Note104: Interview with Eero Rämö, Allianssi, 4 September 2017.] A representative of the Prime Minister’s Office remarked that internal publication is monitored by quality controllers as well as implemented in the project planning phase in accordance with the Openness of Government Activities Act, which provides a loophole in which unfinished documents need not be published.[Note105: With the exception of certain information on law reforms and generally important issues. Laki viranomaisten toiminnan julkisuudesta, 21.5.1999/621, https://www.finlex.fi/fi/laki/ajantasa/1999/19990621#L5 ] The commitment could go further in terms of providing the public with a platform to not simply follow the decision-making process, but to directly comment, consult and participate in it.

Increasing the government’s visibility on social media has succeeded to varying degrees in different ministries, but the commitment merely aims to use it without a clear strategy on best practices for providing the public with information, engaging citizens, and/or increasing accountability.

Carried Forward?

With the exception of the assessment of the lobbying register, the Open Procedures commitments have not been carried forward to the next action plan. The IRM researcher recommends adding information on project impact and results evaluation to the project register, in order to improve on the commitment to transparency.[Note106: Interview with Päivi Nurminen, the Prime Minister’s Office, 11 January 2018.] As recommended in the midterm report, clear procedures of incorporating public consultation results should also be established within the legislative drafting process.[Note107: Midterm report, p. 36,

https://www.opengovpartnership.org/wp-content/uploads/2017/06/Finland_Progress-Report_2015-2017.pdf] The researcher also advises the government to continue developing suitable methods for efficiently producing webcasts as well as to create a strategy for utilizing social media as a public transparency and accountability tool.