Supporting Everyone’s Possibility to Participate. (FI0023)

Enhancing citizens’ possibilities to participate in the preparatory work of public administration’s decision making and development projects. Taking care of the accessibility of engagement and the availability of participation possibilities. The different forms of participation function only if citizens can find them. The engagement possibilities of especially those who are in a vulnerable position, like children and special groups, will be strengthened. Supporting the use of different forms of participation side by side. Different ways of participation can be for instance digital channels and services, different kinds of events and workshops, experiments and events. Securing the comprehensive use of the consultation portal (lausuntopalvelu.fi) in the state administration and enhancing its use in the regions and municipalities.

1. Supporting everyone’s possibility to participate.

Language of the commitment as it appears in the action plan:

“Enhancing citizens’ possibilities to participate in the preparatory work of public administration’s decision-making and development projects.

Taking care of the accessibility of engagement and the availability of participation possibilities. The different forms of participation function only if citizens can find them. The engagement possibilities of especially those who are in a vulnerable position, like children and special groups, will be strengthened.

Supporting the use of different forms of participation side by side. Different ways of participation can be for instance digital channels and services, different kinds of events and workshops, experiments and events.

Securing the comprehensive use of the consultation portal (lausuntopalvelu.fi) in the state administration and enhancing its use in the regions and municipalities.”^{[Note : Finland National Action Plan 2017-2019 (in English), https://www.opengovpartnership.org/documents/finland-national-action-plan-2017-2019-all-languages/.]}

Start Date: Not identified              

End Date: Not identified

Context and Objectives

This commitment addresses the need for citizens to be more involved in the early stages of public administration planning in Finland by providing citizens with a one-stop-shop consultation portal (lausuntopalvelu.fi) for government consultation in planning and decision-making and by making forms of participation easily discoverable, accessible^{[Note : The implementation of accessibility requirements stipulated under the Accessibility Directive (EU 2016/2102) will begin gradually on 23.9.2019. The directive concerns all state and municipal authorities, independent public bodies, universities, and many others. For more information, please see https://vm.fi/saavutettavuusdirektiivi.]} and understandable. The commitment calls for special attention to be paid to vulnerable groups, although such groups are not identified in the commitment beyond children and “special groups”.^{[Note : Special (interest) group is a term used in Finnish public administration and it simply means a group of people with a common denominator or special needs. ]} According to an estimate by the Finnish Centre for Easy to Read (2014), 8%–12% of Finns, including immigrants studying Finnish language, elderly citizens with memory loss, the disabled, and the socially marginalised, need clear language in order to deal with authorities.^{[Note : Planner Eliisa Uotila, the Finnish Centre for Easy to Read, consultation on the national action plan 3.3.2017, p. 13, https://avoinhallinto.fi/assets/files/2017/06/Lausuntoyhteenveto-III-toimintaohjelma.pdf.]} These groups are also disadvantaged in terms of keeping up with technological advancement.^{[Note : Sari Vapaavuori, Head of Development, Valli - The Finnish Union for Senior Services. Email interview 22.02.2019.]} This commitment aims to make use of diverse methods of participation to reach a wider variety of citizens.

The commitment falls short in describing the specific measures or activities the government aims to employ to improve citizen participation. The commitment does not identify the responsible institution, participating institutions, measurable activity, or a clear timeline.^{[Note : Anitta Raitanen, former Executive Director of Kansalaisareena – Citizen Forum, consultation 24.2.2017, p. 18-19, https://avoinhallinto.fi/assets/files/2017/06/Lausuntoyhteenveto-III-toimintaohjelma.pdf.]} The consultation portal provides access to information on the government’s decision-making processes (already established in the previous action plan)^{[Note : Finland End-of-Term Report 2015-2017, p. 13-17, https://www.opengovpartnership.org/wp-content/uploads/2001/01/Finland_EOT_Report_2015-2017_EN_for-public-comment.pdf.]}, but the objective of securing the comprehensive use of the consultation portal, as written, does not include any concrete measures to raise awareness of the portal or encourage and facilitate its use. Thus, although the commitment is relevant to the OGP value of civic participation, the lack of specificity in its wording makes its potential impact difficult to assess beyond “minor”. CSOs involved in the preparation and comment round of the action plan endorsed the general aim of commitment yet criticized its lack of specificity and the lack of responsible institutions for the implementation of planned activities.^{[Note : Summary of comments on Finland’s third national action plan submitted during the consultation period 2 February          –3 March 2017, https://avoinhallinto.fi/assets/files/2017/06/Lausuntoyhteenveto-III-toimintaohjelma.pdf. Sari Vapaavuori, Head of Development, Valli - The Finnish Union for Senior Services. Email interview 22.02.2019.]}

Next steps

The government’s aim to support accessibility and variety of participation for all is laudable, yet the lack of specific indicators of completion as written makes it difficult to assess. In order to raise the specificity and potential impact of the commitment, the IRM researcher recommends:

• All participating public administration bodies commit to publication of basic information on all projects on the online register “Valtioneuvoston hankeikkuna”;^{[Note : The open project register is managed by The Ministry of Finance, https://valtioneuvosto.fi/hankkeet.],[Note : Anitta Raitanen, former Executive Director of Kansalaisareena – Citizen Forum, consultation 24.2.2017, p. 18-19, https://avoinhallinto.fi/assets/files/2017/06/Lausuntoyhteenveto-III-toimintaohjelma.pdf.]}
• Opening up a consultation period on the online consultation portal Otakantaa.fi during preparatory phases of decision-making and development projects;^{[Note : Ibid.]}
• Identifying concrete methods of increasing collaboration with citizens in public administration preparatory work, such as organising participatory workshops during preparatory phases;   
• Identifying criteria for such collaboration methods, which ensures that the needs of vulnerable groups (visually and hearing impaired, speakers of minority languages, the elderly, and others) have been considered.^{[Note : Ibid.]}
• Defining implementation measurement criteria for each milestone of the commitment.

For the next action plan, the IRM researcher recommends using the OGP commitment template even though the government has not found the OGP format useful for communicating, monitoring, and implementing commitments.^{[Note : Joonas Pekkanen, Founder and Coordinator of Open Ministry, Finland, consultation 16.2.2017, p. 20, https://avoinhallinto.fi/assets/files/2017/06/Lausuntoyhteenveto-III-toimintaohjelma.pdf.]} The government has attempted to keep the commitment text short yet broad in scope while narrowing the scope of activities. However, most of the planned activities remain too broad for specific actions to be identified from them and could be broken down into even smaller milestones. To ensure a high potential impact of the commitments, the activities could be extended to cover several action plans, as suggested by IRM during the evaluation of the previous action plan.^{[Note : Finland Mid-term Progress Report 2015-2017, p. 47, https://www.opengovpartnership.org/documents/finland-mid-term-progress-report-2015-2017.]}

1. Supporting everyone’s possibility to participate.

Language of the commitment as it appears in the action plan:

“Enhancing citizens’ possibilities to participate in the preparatory work of public administration’s decision-making and development projects.

Taking care of the accessibility of engagement and the availability of participation possibilities. The different forms of participation function only if citizens can find them. The engagement possibilities of especially those who are in a vulnerable position, like children and special groups, will be strengthened.

Supporting the use of different forms of participation side by side. Different ways of participation can be for instance digital channels and services, different kinds of events and workshops, experiments and events.

Securing the comprehensive use of the consultation portal (lausuntopalvelu.fi) in the state administration and enhancing its use in the regions and municipalities.” [1]

Start Date: Not identified

End Date: Not identified

This commitment sought to improve citizen participation in public administration planning, with special attention paid to persons in vulnerable positions, such as children and other special needs groups. [2] To do so, this commitment aimed to make participation opportunities more diverse, easily discoverable, accessible, and understandable. The concrete mechanisms to reach this aim included the promotion of an existing online consultation platform (lausuntopalvelu.fi, launched in 2014), as well as other digital channels and services, events, and workshops. [3] The online consultation platform offers individuals and organizations the possibility to comment on legislation and public sector preparatory work.

As part of this commitment, the Finnish government organized events (e.g. Universal Children's Day, an immigrant workshop, and an elder council day) and promoted the use of the consultation platform within the government and municipalities. [4] Because the commitment does not include other specific measures to reach its stated objectives, its implementation is considered complete.

During the implementation period, the Finnish government provided selected stakeholder groups opportunities to engage with public sector decision making and preparatory work. One of the stated objectives of the government during the implementation period was to develop the Universal Children’s Day. [5] To mark the 30^th anniversary of the UN Convention on the Rights of the Child in November 2019, the government arranged an event during which 100 children from different parts of Finland took over the Government Palace for three hours and drafted a children’s declaration with the help of civil servants. [6]

The emphasis on individual events for professional and special-interest groups meant that the commitment had a limited outreach. [7] The government’s willingness to increase co-operation between youth and elder councils is a positive [8] and concrete development, but its application remains limited in scope. This co-operation model is based on a three-day event held in the municipality of Hollola in May 2018. [9] The use of the online consultation platform has increased openness, but the government could ensure that all citizens and CSOs have engagement possibilities in the early stages of public sector decision making, instead of simply having an opportunity to comment on decisions that have already been made. [10]

Overall, the implementation of this commitment resulted in marginal changes to government practice.