Improving Understandability and Inclusion of Government Information (FI0030)

Lasting openness means that openness penetrates all government actions and development measures. Genuine openness is impossible to achieve if the activities of the government are incomprehensible. In international comparison, Finland is a model country of openness. However, the changing world brings about new challenges. Citizens’ demands towards government openness are increasing due to technological development, among other reasons. It is important to ensure that comprehensive development of openness continues and that all those involved in government operations are duly competent in this respect. When fulfilling this commitment, special attention should be paid to the opportunities of participation for people in the most vulnerable position.

Of the OGP initiatives, this commitment address all four: transparency, citizen participation, accountability and technology & innovation.

Actions:
1) Understandability - Training and support for the use of good administrative language
An online course on good administrative language has been prepared. We will introduce guidelines and a programme to ensure that public officials and employees will take the course. The online course will become part of the orientation of new employees. A further goal is to ensure, in cooperation with the municipalities and the Association of Finnish Local and Regional Authorities, that there is a sufficient number of people who have completed the course in local government.

Expertise of language and communications, and a broader understanding of linguistic matters is required, not only for customer communications by officials, but also when it comes to management, decision-making and the preparatory tasks by experts in the various sectors.

In addition to training, there is a need for constant development and maintenance of skills and support offered by the departments and at workplaces. Support is needed when new services are produced or activities reformed, but also in daily activities. The plain language programme also seeks to support the increased use of language and usability experts at public offices and workplaces. The first priority is that the language is easy to understand for the citizens.

In addition to the online course on good administrative language, the Institute for the Languages of Finland (Kotus) is preparing a more extensive online training material of administrative language as part of its three-year (2019–2021) project.

Plain language also means non-discriminatory language. All authorities are, by law, required to prevent discrimination and to promote gender equality and non-discrimination in all their activities.

2) Understandability - Improving plain language skills in government
In addition to the plain language skills, it is also important to further increase awareness and competence of plain language in government. There are up to 700,000 people in Finland who require plain language (Finnish Centre for Easy to Read, 2019). An online course on plain language will be organised. Preparation of marketing material that will also contribute to the purposes of the course and can be used as an introduction to plain language. Plain language is in particularly needed by the authorities in the various administrative branches involved in direct customer contact with citizens or who produce different types of administrative texts, such as decisions, forms or guidelines. The goal is that increased command of plain language will also mean that it will be more commonly used and that the volume of materials produced in plain language will grow.

3) Understandability - Wire frames
In addition to plain text and speech, good visual solutions promote understandability and accessibility. A package of support materials will be produced, which will contain the practices of good visualisation and examples of successfully completed cases within the administrative branches.

4) Understandability - Boosting the accessibility competence among public officials
It will be ensured that competence on accessibility will be increased in public administration and that understandable and plain content will be highlighted in public online services. Together with Celia, a short course will be prepared on the eOppiva platform on how accessibility and plain content are connected.
Inclusion - NGO Academy - public officials to gain competence and NGO connections
A NGO Academy Day will be co-organised by the central government and NGOs. The day is intended for everyone, in particular those public servants for whom work with NGOs is not a part of their day-to-day tasks. The goal of the day is to provide people in the government more in-depth competence on the work of NGOs, and to help public officials to make new NGO contacts in their own sector. The event will contribute to the goals of the Government Programme on boosting civil society competence in the government.
Development of competence relevant to non-governmental organisations is also carried out as a part of the management development and support activities.

5) Inclusion - The day of the Elderly Citizens Council and the day of Children’s Rights will be complemented with the introduction of a day of the Council for People with Disabilities.
It is important that the representatives of the councils for people with disabilities will gain additional opportunities for sharing competence and experiences at a national level and to carry out development activities together. The Elderly Citizens Council day has been organised for a number of years now. In the future, the Councils for People with Disabilities will be offered a similar annual event, which could partly overlap the day of the Elderly Citizens Councils. The planning work for the day of the Councils for People with Disabilities will start cooperation with the Advisory Board for the Rights of Persons with Disabilities (VANE) and by hearing the wishes by members of Councils for People with Disabilities on the goals for the day.

Enforced compliance with the Act on the Openness of Government Activities The experiences by the Chancellor of Justice indicate that the compliance with the Act on the Openness of Government Activities remains insufficient. A significant number of the complaints received by the Chancellor of Justice concern the Act on the Openness of Government Activities.
As outlined in the Government Programme, compliance with the Act on the Openness of Government Activities must be enhanced by issuing stricter obligations for government officials to comply with the Act on the Openness of Government Activities in a manner that promotes openness and by determining more explicit consequences for breaches of the law.

The goal is to enhance the openness-promoting compliance with the Act on the Openness of Government Activities through ethical and purpose-oriented development in particular. This is because the interpretations of the Act on the Openness of Government Activities and the data protection regulations are, in many respects, genuinely borderline cases and there are strict sanctions for unlawful disclosure of confidential information.
6) Openness - Strengthening commitments
The support package for open government activities and its various language versions will be updated. As part of the update, materials will be added and developed in the following fields in particular: 1) enabling and supporting the participation of young people (children and young people under 18), 2) taking into account the various linguistic groups in the promotion of government openness and development of opportunities for participation and information on linguistic rights and means to promote them, 3) the equality aspect, 4) accessibility in order to support the new law concerning accessibility (Act on Providing Digital Services, 306/2019) and to ensure that people with disabilities have access to information and opportunities for inclusion. The accessibility element will be completed in cooperation with Celia and other parties that offer accessible services

The support package will also contain information on how public officials, local government officials and public sector employees can take part in social media debates and how to face and increase citizen participation on social media, for example.

Boosting the marketing of the “Openness Game” as a means of development and make a Swedish-language version of the game.

A training course on openness will be produced for the eOppiva platform in Finnish and Swedish. The contents will also feature basic information on the Act on the Openness of Government Activities and such topics as personal data protection. One of the modules in the training will cover internal inclusion.

Openness and inclusion must become part of everyday tasks.It will seek to establish the kind of opportunities and means which could be used to support public officials in their efforts to act as openly as possible in their tasks in the office.
The principle is that openness is deeply rooted in all of the government’s operational methods and attitudes instead of being a separate responsibility that causes extra work.

6) Communications - Supported by management commitment
A regional tour will take place and offer a forum of dialogue for the local government management, public officials and government officials in the region and the topics will include the activities on the promotion of openness, inclusion and trust. The goal is to strengthen cooperation and communication between authorities that promote openness.

7) Communications - Sharing best practices
Collecting and additionally highlighting Finnish and international best practices and tools for promoting open government.

One important element in sharing best practices is the availability of information and its accessibility as laid down in legislation concerning accessibility (306/2019) through websites and other means. Online services must comply with level AA as laid down in the accessibility recommendations.

1. Sustainable Openness

Main Objective

“Sustainable openness means that openness penetrates all government actions and development measures. Genuine openness is impossible to achieve if the activities of the government are incomprehensible. In international comparison, Finland is a model country of openness. However, the changing world brings about new challenges. Citizens’ demands towards government openness are increasing due to technological development, among other reasons. It is important to ensure that comprehensive development of openness continues and that all those involved in government operations are duly competent in this respect. When fulfilling this commitment, special attention should be paid to the opportunities of participation for people in the most vulnerable position.”

Milestones

• Understandability – Training and support for the use of good administrative language. Introducing guidelines and a program to ensure the participation of public officials in a training course in good administrative language.
• Understandability – Improving plain language skills in government. Organization of an online course on plain language, preparation of marketing material for the course that could be used as an introduction to plain language.
• Understandability – Wire frames. Production of a package of support materials containing the practices of good visualization of information and examples of successful cases.
• Understandability – Boosting the accessibility competence among public officials. Preparation of a short course on the eOppiva platform on how accessibility and plain content are connected.
• Inclusion – NGO Academy – public officials to gain competence and NGO Co-organization of an NGO Academy Day by the central government and NGOs with the goal to provide public officials more in-depth competence on the work of NGOs, and to help public officials make new NGO contacts in their sector.
• Inclusion – The day of the Elderly Citizens Council and the day of Children’s Rights will be complemented with the introduction of a day of the Council for People with Disabilities. The Councils for People with Disabilities will be offered an annual event for sharing competence and experiences at a national level and for carrying out development activities together.
• Enforced compliance with the Act on the Openness of Government Activities. Enhancing compliance with the Act on the Openness of Government Activities by issuing stricter obligations for government officials to comply with the Act in a manner that promotes openness and by determining more explicit consequences for breaches of the law.
• Openness – Strengthening commitments. Updating the existing support package for open government activities with materials on supporting youth participation, linguistic groups and linguistic rights, equality, accessibility, public officials’ participation in social media debates and ways to increase citizen participation. The commitment also involves marketing and making a Swedish-language version of the “Openness Game”. A training course on openness will be produced for the eOppiva platform in Finnish and Swedish. The contents will also feature basic information on the Act on the Openness of Government Activities and topics such as personal data protection.
• Communications – Supported by management commitment. Organizing a regional tour to offer a forum of dialogue for the local government management, public officials and government officials in the region for promoting openness, inclusion and trust.
• Communications – Sharing best practices. Collecting and highlighting Finnish and international best practices and tools for promoting open government.

Editorial Note: For the complete text of this commitment, please see Finland’s action plan at https://avoinhallinto.fi/assets/files/2019/09/ENGLANTI_Avoin-hallinto_IV_toimintaohjelma_FINAL_240919-1.pdf.

Commitment Analysis
This commitment aims to promote sustainable government openness in order to prevent the erosion of trust in society and fight polarization. [1] It focuses on building government officials’ know-how of open government and stronger relationships between government and civil society, in particular with more vulnerable groups of society. [2] The commitment involves a number of activities which fall into four general categories: 1) civil service training, 2) networking and capacity-building events, 3) guidelines and support materials, and 4) strengthening the legal basis of government openness. It pays particular attention to improving the understandability of government information for groups who need information in simplified language. Such groups include people with developmental disabilities, people suffering from dementia, or people of migrant backgrounds, among others. [3] Another dominant theme is increasing the inclusion of different societal groups through joint events for government and civil society. The planned activities are generally relevant to the OGP values of access to information and civic participation. In addition, the planned enforced compliance with the Act on the Openness of Government Activities under milestone 7 makes it relevant to public accountability.

Several activities (e.g. improving the understandability and accessibility of government information – milestones 1-4) continue the government’s long-time priorities addressed in several previous OGP action plans. For example, the Administrative Procedure Act [4] requires the use of clear administrative language since 2003 and strengthening clear language skills among civil servants has been promoted in all OGP action plans. Previous action plans have also tried to advance the use of plain language (simplified Finnish, which is different from clear administrative language) through training, guidelines, and ontologies. However, the activities have had limited impact on improving information accessibility. [5] The Finnish Centre for Easy Language has emphasized a need for more plain-language information on decisions that directly affect citizens [6] as well as up-to-date information on current issues such as the global COVID-19 pandemic, which is unfolding in Finland at the time of writing. [7] While the accessibility of government websites is improving thanks to the requirements in the new Act on the Provision of Digital Services, the scope of the law does not include the understandability of web content for groups with special linguistic needs. [8] Sami Älli of the Finnish Association on Intellectual and Developmental Disabilities (FAIDD) also points out that efforts to improve the understandability of government information have mostly focused on online information, while many users of easy language do not use the internet and would need information to be produced in printed formats. [9] Although this action plan’s focus on civil servants’ training is an important way to improve public officials’ skills in understandability and accessibility, it does not address the full spectrum of gaps in this area. Moreover, participation in the courses will not be mandatory for officials. [10] At the same time, the fact that all courses will be offered online for free makes them easily accessible for anyone interested, including local government officials. [11]

Similarly, milestone 8 (the open government support package [12] and Openness (Trust) Game [13]) involve updating or marketing information resources that already exist. This is important to ensure their use but only constitutes an incremental improvement to the existing situation. The collection and dissemination of open government best practices [14] could strengthen the impact of this set of activities.

At the same time, milestones 5, 6, and 9 (NGO Academy Day, regional open government tour, and the Day of the Council for People with Disabilities) constitute new activities, originally proposed by CSOs. [15] The annual NGO Academy Day aims to expand ministries’ knowledge of the diversity of CSOs in Finland through joint seminars and networking. According to the Ministry of Finance, the annual event is expected to complement more regular forms of interaction between the central and local administrations and CSOs. [16] The ministry is preparing the first NGO Academy Day jointly with NGOs. According to Kristiina Kumpula (KANE), initial planning meetings have discussed ways of ensuring the activity’s sustainability and creating a training system around the annual event. [17] The Day for People with Disabilities and the regional openness tours are also new activities. The Local Government Act [18] requires all municipalities to establish councils for people with disabilities. However, the councils have lacked opportunities to exchange best practices and develop their model of operation. [19] This commitment comprises a survey of councils to learn about councils’ needs and piloting the first event in 2021. The regional open government tour’s main goal is to enhance dialogue between the central government and municipalities and develop common goals around open government. The tour will visit a number of regions across Finland and involve two events in each: one for civil servants and another for CSOs. Meetings with CSOs will be used to solicit civil society input for the open government strategy (Commitment 2 of this action plan). Overall, these activities may lead to more continuous forms of government-civil society collaboration. However, their format as annual or one-off events does not allow them to make a major impact on their own.

A different activity under this commitment concerns the enforcement of the Act on the Openness of Government Activities. The law stipulates that information on all public sector activities is public and open by default (unless legal restrictions apply) [20] but frequent complaints to the Chancellor of Justice point to enforcement gaps in practice. [21] The commitment aims to issue stricter obligations for compliance with the Act and determine consequences for breaches of the law. However, the action plan does not specify how this will be done. According to the Ministry of Justice, work on this commitment has been postponed due to the COVID-19 pandemic and further details are still to be specified. [22] It is thus difficult to assess how this activity might improve the enforcement of the Act in practice.

Civil society stakeholders see the goals of this commitment as more pragmatic than ambitious. [23] However, since the commitment involves a variety of activities that may reach a large number of public officials and CSOs, their cumulative impact will likely lead to moderate changes in openness. Interviewed stakeholders had several suggestions for increasing this commitment’s ambition. The position of plain and easy language in public administration and society could be strengthened by appointing a ministry that would be responsible for promoting easy language. [24] The national Institute for the Languages of Finland (Kotus) could also do more to promote the use of easy language in addition to clear administrative language. So far, the development of easy language and production of materials in easy language has often been the voluntary work of NGOs. According to Johanna Rutenberg from the LL-Center, information in easy Swedish has been largely missing during the COVID-19 pandemic and the government seems to expect NGOs to take care of the translations without providing them with additional resources for the task. [25]

The government could also contribute to building better expertise in easy language by supporting university-level research and expert training. Finland’s current pool of experts in easy language is limited to five freelancers working with the Finnish Centre for Easy Language. The lack of experts is a limitation that may adversely affect civil servants’ training. [26] Stronger scientific research on the topic would also help develop evidence-based guidelines for producing understandable visual information for groups who rely on visual communication. [27] The impact of trainings could be enhanced by adopting common rules on easy language at the central government level, clarifying who should provide what information in easy language, and ensuring that information is available both in easy Finnish and Swedish. The government could increase the impact of trainings by making participation obligatory at least for central government officials. Lastly, the goals related to strengthening government-civil society relations could be further supported by sharing best practices of continuous collaboration between government and CSOs. A good example is the working model of the Digi Arkeen advisory board, where CSOs and government organizations discuss the development of digital services and digital inclusion. [28]