Guide and Standardization for the Provision of Services & for Procedures Per Service/Entity (GR0035)
Overview
At-a-Glance
Action Plan: Greece National Action Plan 2016-2018
Action Plan Cycle: 2016
Status:
Institutions
Lead Institution: Ministry of the Interior and Administrative Reform – division of Administrative Reconstruction & e-Government, Alternate Minister for Reform, Deputy Secretary General
Support Institution(s): All Ministries and entities of the Public Sector (legal persons of public and private law, Societes Anonymes), Local Government Agencies of first and second degree and their legal entities, through the utilisation of the Register of Services and Entities of the Greek Public Administration of the Ministry of the Interior and Administrative Reconstruction – division of Administrative Reconstruction & e- Government
Policy Areas
Capacity Building, Public Participation, RegulationIRM Review
IRM Report: Greece Mid-Term Report 2016-2018, Greece End-of-Term Report 2016-2018
Early Results: Marginal
Design i
Verifiable: Yes
Relevant to OGP Values: Yes
Ambition (see definition): High
Implementation i
Description
Context It has been observed that the main reason of trouble for the citizens and for the wasting of time and resources for the services of the State is the incomplete information and knowledge of procedures necessary for the provision of a service or for an action by the administration (e.g. municipalities ignoring the procedures for the transfer of a civil servant, citizens addressing the wrong services). Corruption also arises because of a lack of transparency and awareness of citizens concerning the administrative procedures for an action or for responding to requests. Furthermore, the procedure for the provision of services or for the completion of an action by the authorities varies in issues that are identical or similar. This leads to the provision of inadequate information to the citizens while the administration is also affected by problems and distortions. So far there is no regulatory framework providing for a Guide of Services that could present all the detailed information on the kind of services and competencies of each service/body, while a comprehensive listing of procedures regarding the provision of identical or similar services under common standards is still lacking. The lack of information of citizens as to which Services are competent for the provision of services or for an action and by what procedure they are provided and the lack of common standards, renders difficult the relation between the citizen and the state. The lack of public and reliable information favours the lack of transparency and corruption, while it represents a cost both in human resources and in financial terms. Commitment Description Each Service/Entity of the Public Sector shall publish on its website the Guide for the Provision of Services and for Procedures, in accordance with its competencies. The Guide shall describe in detail which are the services and actions it may provide as well as the necessary procedure, so that all the steps required for the provision of a service may be known in advance. In addition, a data base of standard procedures shall be created regarding the provision of identical or similar services by the Public Sector. The data base of standard procedures as well as all the Guides (apart from the website of the relevant Service/entity) shall be published in the web site of the Ministry of Interior and Administrative Reconstruction. Citizens shall have the possibility to submit comments on the improvement of operation and the provision of services. OGP Values Access to public information, Accountability, Participation, Technology and Innovation for Transparency Implementation bodies Implementation: Ministry of the Interior and Administrative Reform – division of Administrative Reconstruction & e-Government, Alternate Minister for Reform, Deputy Secretary General Stakeholders: All Ministries and entities of the Public Sector (legal persons of public and private law, Societes Anonymes), Local Government Agencies of first and second degree and their legal entities, through the utilisation of the Register of Services and Entities of the Greek Public Administration of the Ministry of the Interior and Administrative Reconstruction – division of Administrative Reconstruction & e- Government Objective This commitment shall reinforce publicity and transparency in the State, it shall allow savings of resources, more speed and improvement in the delivery of services, while at the same time reinforcing the work of civil servants. The public administration shall become more open given that every citizen shall know where exactly he/she should address himself/herself, the procedure followed and the steps taken at any given time. In addition, the public administration shall be able to use the comments made in order to improve. Means for the implementation The achievement of the commitment shall require a legislative regulation and a Ministerial Decision for the determination of the implementation details. Each Service/Entity shall upload the Guide for the Provision of Services and for Procedures on their web sites.
IRM End of Term Status Summary
Commitment 2, 3, 4 and 5: Public Service Delivery
Commitment 2. Participation in the Assessment of the Public Sector – e-goal setting tool & monitoring of the government’s work
Until now the involvement of citizens in the assessment of services received by the State does not have an institutional nature and is almost non-existent in the functioning of the services/agencies while it is not taken into account when establishing policies on the functioning of the public sector.
- By virtue of law 4369/2016 the citizens shall be able, through questionnaires and the submission of proposals, to participate in the shaping of the results of the assessment, while at the same time they shall be able to monitor its detailed and visualized results through the e-goal setting tool.
- Each service/entity and in particular those with a strong interaction with citizens shall make available questionnaires and forms for the submission of proposals, while these shall be also available in electronic form on the website of each service/entity.
- Both the results and the preparation of the goal setting through the e-goal electronic platform shall be public and citizens shall be constantly aware of the functioning of services, while being able to formulate proposals.
- This project already implemented through the new NSRF 2014-2020 will be launched as a pilot for the Ministry of the Interior and Administrative Reconstruction and the Ministry of Health, and will be extended to the whole of the public sector.
- Monitoring of the work of the government. All government bodies should provide open data on their activity, and to draw up reports to be published online.
Responsible Institution(s): Ministry of the Interior and Administrative Reform – Department of Administrative Reconstruction & e-Government; Management Authority of the Operational Program “Reform of the Public Sector” Alternate Minister for Reform, Deputy Secretary General.
Start Date: July 2016 End Date: March 2017
Commitment 3. Publish organizational charts
The Greek State will make publicly accessible every organizational chart of all services and entities of the Greek State, through their publication on the website of the relevant services/entities down to the level of department. The publication shall be made based on common standards and shall include details of electronic and phone communication as well as a brief description of competencies and tasks.
(Ministry of the Interior and Administrative Reform – division of Administrative Reconstruction & e-Government, Alternate Minister for Reform, Deputy Secretary General July 2016 – December 2017)
Commitment 4. Accountability in dispute settlement between citizens and the public sector
Through procedures of institutional dialogue the social actors and the citizens are able to resolve or even anticipate problems in their transaction with the services of the public sector.
- Hearing Committee of Social Actors and Citizens, article 24 of law 4369/2016.
- Institutional Mediation – (binding or optional) before the recourse to administrative courts.
- The creation of the Hearing Committee per Service or per Entity, as provided for in article 24 of law 4369/2016 consolidates confidence in relations between the citizen and the State, contributes to the smoother operation of the public sector and prevents any disagreements and maladministration.
- The citizens may submit improvement proposals, particularly for Services with which they come in direct and daily contact. -Furthermore, if the procedure of the Hearing Committee does not allow the resolution of the existing problems and disputes, then, before the recourse to administrative courts and the creation of additional burden of judicial affairs for disputes between citizens and the State, there will be a procedure of Institutional Mediation.
- In this procedure, each citizen shall be able, following a reasoned request and possibly with the presence of an attorney, to enter in mediation with the public sector (with the participation of a representative from the Legal Council of State) for the resolution of the existing dispute.
- The establishment of the Hearing Committee and of the Institutional Mediation in each organizational chart ensures their rational operation and their institutional consolidation beyond the legislative provisions for their creation.
Milestones: 4.1 Ministerial Decisions on the procedures of the hearing committee. 4.2 Legislative regulation on institutional mediation. 4.3 Establishment and operation of institutional mediation. 4.4 Establishment and Operation of the Hearing Committees.
(Ministry of the Interior and Administrative Reform – division of Administrative Reconstruction & e-Government, Alternate Minister for Reform, Deputy Secretary General July 2016 – December 2017)
Responsible Institution(s): Ministry of the Interior and Administrative Reform – Department of Administrative Reconstruction & e-Government; Management Authority of the Operational Program “Reform of the Public Sector” Alternate Minister for Reform, Deputy Secretary General.
Start Date: July 2016 End Date: December 2017
Commitment 5. Standardize public service provision and procedures and publish a guide
- Each Service/Entity of the Public Sector shall publish on its website the Guide for the Provision of Services and for Procedures, in accordance with its competencies. The Guide shall describe in detail which are the services and actions it may provide as well as the necessary procedure, so that all the steps required for the provision of a service may be known in advance.
- In addition, a data base of standard procedures shall be created regarding the provision of identical or similar services by the Public Sector. The data base of standard procedures as well as all the Guides (apart from the website of the relevant Service/entity) shall be published in the web site of the Ministry of Interior and Administrative Reconstruction.
- Citizens shall have the possibility to submit comments on the improvement of operation and the provision of services.
Milestones: 5.1 Enactment of regulatory framework. 5.2 Publication of Guidelines in each service and entity. 5.3 Data base of standardization procedures.
Responsible Institution(s): Ministry of the Interior and Administrative Reform – Department of Administrative Reconstruction & e- Government; Management Authority of the Operational Program “Reform of the Public Sector” Alternate Minister for Reform, Deputy Secretary General.
Start Date: July 2016 End Date: June 2017
Editorial Note: Commitment text has been abridged by the IRM. To see the full action plan, please refer to https://www.opengovpartnership.org/documents/greece-national-action-plan-2016-2018/.
Commitment Aim:
Commitments 2, 3 and 4 aimed to improve public service delivery to regain citizens’ trust. At the time of drafting these commitments the Greek government had to reorganize its administrative structures and rationalize public administration processes in the context of the third Memorandum.[Note 34: Greece: The third memorandum’s plans for public administration,
https://www.eurofound.europa.eu/el/publications/article/2016/greece-the-third-memorandums-plans-for-public-administration] This cluster of commitments reflects government efforts to insert elements of transparency, participation and accountability into ongoing policy initiatives concerning public sector evaluation, public services delivery, disputes settlement and organizational charts. More specifically:
- Commitment 2 would create systems for performance feedback through questionnaires and public input into performance in each agency.
- Commitment 3 would publish organizational charts of each agency so that the public can access standardized information.
- Commitment 4 creates a framework for bringing, settling, and reporting disputes on public services in each agency (pursuant to Law 4369). This commitment introduces two new institutional mechanisms for mediation.
- Commitment 5 creates a uniform catalog of services that allows interoperability across services. This commitment expands access to information and participation by standardizing the information and providing an opportunity for citizens to provide feedback.
Status
Commitment 2. Participation in the assessment of the public sector – e-goal setting tool and monitoring of the government’s work
Midterm: Limited
The e-goal setting system that would enable monitoring and evaluation of government and administrative proceedings was still pending during midterm evaluation. At that time, the Ministry of Administrative Reconstruction (MAR) had not indicated a course of action regarding the necessary regulatory amendments that would define the tools and processes with which citizens could have their say in public sector evaluation. The lack of specific public-facing elements and the fact that the government designed the evaluation questionnaires without citizens’ input raised concerns among CSOs.[Note 35: OGP, “Independent Reporting Mechanism (IRM) Progress Report 2016–2018: Greece”, https://www.opengovpartnership.org/documents/greece-mid-term-report-2016-2018-public-comment]
End of term: Limited
There is no publicly available evidence to suggest any further progress in the implementation of this commitment. MAR has not announced any plans on how to include public participation elements into the evaluation of the public sector. According to the OGP point of contact, the existing evaluation process[Note 36: Nancy Routzouni, national point of contact, response to IRM researcher questionnaire, September 2018.] is mandated by the current regulatory framework without any provision for allowing public feedback.[Note 37: Frequently Asked Questions on public sector goal setting practices (in Greek), http://www.minadmin.gov.gr/?p=30531]
An initial version of the e-goal setting system was put into operation on 10 May 2018 and was completed on 20 July 2018.[Note 38: Nancy Routzouni point of contact, written response to IRM questionnaire, September 2018.] The e-goal system aimed to enable the evaluators from the Administrative/Personnel Directorates to complete the evaluation forms electronically. All the evaluation data is stored in the e-goal setting system. The next stage concerns validating and finalizing the evaluation reports.[Note 39: Ibid. ] The above actions do not introduce the public feedback mechanisms that were originally included in the action plan and therefore implementation remained limited.
Commitment 3. Publish organizational charts
Midterm: Limited
The publication of organizational charts for public sector entities was envisaged as a means to increase transparency, monitor performance, redesign public agencies and reallocate human resources within the public sector. Implementation of this commitment remained limited during midterm evaluation. A common standard that would allow the publication of charts in a unified manner was missing.[Note 40: Ministry of Finance organizational chart (in Greek), http://www.minfin.gr/web/guest/organogramma-olou-tou-ypoik] In order to fulfill this commitment the government was expecting delivery of a web-based system by an external private vendor by late August 2018.[Note 41: OGP, “Independent Reporting Mechanism (IRM) Progress Report 2016–2018: Greece”, https://www.opengovpartnership.org/documents/greece-mid-term-report-2016-2018-public-comment] The Open Technologies Alliance proposed an amendment to articles 6 and 8 of the Law 4369/2016 that prescribes a more detailed and timely process to create and publish the organograms.[Note 42: The proposed amendment (in Greek), https://goo.gl/k4V5wk] Also Dr. Dionysis Rigopoulos, an Inspector of Public Administration, argued that the creation of the digital organograms could be linked with the Transparency Program Diavgeia so that decisions that require public expenses cannot be implemented unless the agency has not fully produced its organizational chart.[Note 43: Dr. Dionysis Rigopoulos. Inspector of Public Administration, “The gap in the foundations of administrative reform” (in Greek), http://www.capital.gr/me-apopsi/3245219/to-keno-sta-themelia-tis-dioikitikis-metarruthmisis] For more information, please see the 2016-2018 midterm IRM report on the Greek action planP.[Note 44: OGP, “Independent Reporting Mechanism (IRM) Progress Report 2016–2018: Greece”, https://www.opengovpartnership.org/documents/greece-mid-term-report-2016-2018-public-comment]
End of term: Limited
The implementation of this commitment remained limited at the end-of-term report. According to the former Minister of Administrative Reconstruction, Mrs. Olga Gerovasili, despite the fact that the process to publish organizational charts had been ongoing for months, only 9 out of 1730 state agencies had published their charts by January 2018.[Note 45: Aftodioikisi, “Public Sector: Only 9 out of 1730 agencies submitted organizational chart”, https://www.aftodioikisi.gr/ipourgeia/dimosio-molis-9-stous-1-730-foris-katethesan-psifiako-organogramma-lista/] Mrs. Gerovasili expressed that the cause for the delay was the need to reinserti employees new positions’ into the new organizational charts.[Note 46: Ibid] The Minister also claimed that agencies were expected to speed up the publishing of their charts during 2018.
On 17 May 2018, MAR issued guidelines for all public agencies to upload their digital organizational charts and job profiles into the application.[Note 47: The guidelines (in Greek), http://apografi.gov.gr/images/esk/law/EGKYKLIOS_17_05_2018.pdf] Evidence accessed by the IRM researchers on the public sector census website[Note 48: Greek public sector employee census website (in Greek), http://apografi.gov.gr] indicated that the rate at which agencies published their organizational charts had indeed increased. However, at the time of writing this report, only 390 out of 1730 agencies had uploaded their charts.[Note 49: The latest version of published organizational charts (in Greek), https://hr.apografi.gov.gr/organizations/browse?0 ] According to an expert on information architecture, the web-based platform for organizational charts is a positive development compared with the unstructured data that was available prior to this commitment.[Note 50: Panagiotis Kranidiotis, Information Architect, e-government professional, telephone interview with IRM researcher, September 2018.] However, Dr. Dionysis Rigopoulos, inspector of public administration, considers that the published data is incomplete and far from providing a clear real-time picture of the structure and staff of all public sector agencies.[Note 51: Dr. Dionysis Rigopoulos. Inspector of Public Administration, interview with IRM researchers, Athens, 21 October 2018.] For the above reasons, IRM researchers consider that since the organizational charts of the majority of the public sector agencies have not been published and data is still incomplete, the level of completion of this commitment remains limited.
Commitment 4. Accountability in dispute settlement between citizens and the public sector
Midterm: Limited
The commitment aimed to create an efficient mechanism to support disputes between citizens and public sector entities. The implementation of this commitment had stalled at midterm. Although the government hosted an event to solicit feedback on how to enact regulations regarding dispute settlement[Note 52: Impact Hub Athens, Advocating with the Citizen - Discussion Event,” (in Greek), https://goo.gl/NuzwuW], no further implementation actions were carried forward. For example, the issuance of the ministerial decision that will specify the process that the hearing committee, mandated by Law 4369/2016, shall operate was still pending.
For more information, please see the 2016-2018 midterm IRM report on the Greek action plan.[Note 53: OGP, “Independent Reporting Mechanism (IRM) Progress Report 2016–2018: Greece”, https://www.opengovpartnership.org/documents/greece-mid-term-report-2016-2018-public-comment]
End of Term: Limited
In January 2018 the government brought into effect two legal amendments mandating the process for dispute settlement between private individuals.[Note 54: Lawspot, “New framework for dispute settlement law” (in Greek), https://www.lawspot.gr/nomika-nea/neo-plaisio-gia-ti-diamesolavisi-nomos-4512-2018 ] However, the law explicitly mentions that it does not affect dispute settlements where the public sector, local administration or state-owned agencies are the litigants. The national point of contact mentioned that there are no programmed actions to implement this commitment.[Note 55: Nancy Routzouni, national point of contact, response to IRM researcher questionnaire, September 2018.] It remains unclear to IRM researchers if the government will amend Law 4512/2018 to include dispute settlement among citizens and state agencies as was the case in the original commitment, or if this commitment has been withdrawn. According to Dr. Lilian Mitrou, associate professor at the University of the Aegean, the dispute settlement mechanism of this commitment could be included under the competencies of the Greek Ombudsman,[Note 56: Dr. Lilian Mitrou, Associate Professor at the University of the Aegean-Greece (Department of Information and Communication Systems Engineering), interview with IRM researcher, Athens, 4 November 2018.] which mediates between public administration and citizens in order to help citizens exercise their rights effectively.[Note 57: The Greek Ombudsman, https://www.synigoros.gr/?i=stp.en.rolemission ] Dr. Mitrou, an expert on e-Gov and the Diavgeia legal framework, also expressed that the implementation of this commitment as it is currently worded with the hearing committees will undermine the role of the Ombudsman.[Note 58: Lilian Mitrou, Associate Professor at the University of the Aegean-Greece (Department of Information and Communication Systems Engineering), interview with IRM researcher, Athens, 4 November 2018.] Overall, since the implementation of this commitment has not seen any substantial progress since midterm evaluation, completion has remained limited.
Commitment 5. Standardize public service provision and procedures and publish a guide
Midterm: Not Started
The implementation of this commitment had not started at midterm evaluation. Τhis commitment aimed to provide the backbone that would enable informational and technical interoperability of public services across the Greek public administration. There were no government actions to suggest the publication of the regulatory framework that will standardize the catalog of public services. The government OGP management team indicated that the already existing government service portal[Note 59: Greek government main e-service portal, http://ermis.gov.gr] lists all the services currently offered by the Citizen Service Centers. However, as CSOs argue, the services listed on this portal had been available since 2013.[Note 60: OGP, “Independent Reporting Mechanism (IRM) Progress Report 2016–2018: Greece”, https://www.opengovpartnership.org/documents/greece-mid-term-report-2016-2018-public-comment] To fulfill this commitment, MAR could develop a standardized catalog with public services and include a mechanism for citizens to submit their input. For more information, please see the 2016-2018 midterm IRM report on the Greek action plan.[Note 61: OGP, “Independent Reporting Mechanism (IRM) Progress Report 2016–2018: Greece”, https://www.opengovpartnership.org/documents/greece-mid-term-report-2016-2018-public-comment]
End of Term: Substantial
The cataloging of the processes of public services in the “diadikasies.gr” website shows substantial implementation of this commitment. According to the government point of contact, by July 2018 more than 1,500 services provided by the public sector (e.g. birth and marriage certificates, drivers’ licenses, residency permits etc.) had been cataloged via an application that has more than 300 registered users.[Note 62: Nancy Routzouni, national point of contact response to IRM researcher questionnaire, September 2018.] In September 2018, this number rose to 2,186.[Note 63: The website for diadikasies.gr public service description portal (Greek version), https://goo.gl/TD7T1P] Each record contains the official title of the service, a brief description of the service, all relevant legislation governing the service, a table with the required paper and/or electronic forms, a table with step-by-step procedures followed in providing the service, any co-responsible administrative units and the registries updated upon provision of the service.[Note 64: The website for diadikasies.gr public service description portal (English version), https://en.diadikasies.gr/Main_Page ]
This cataloging of MAR follows the work carried out by the CSO Open Technologies Alliance, which had a similar commitment[Note 65: See Commitment 33.] in this action plan for the wikification of public services and was responsible for the development and maintenance of the platform and the training of public servants. The software used (MediaWiki) for supporting this initiative allowed comments and discussion on page content by default for registered members. Although this feature is intended to facilitate user discussion, comments are not yet monitored or taken into account by the government.[Note 66: The website for diadikasies.gr public service description portal (Greek version), https://goo.gl/TD7T1P
and Despina Mitropoulou, General Director of Open Technologies Alliance (GFOSS), telephone interview with IRM researcher, November 2018. ] It is unclear if the government will promote the use of this feature to allow citizens to comment on specific services.
Did It Open Government?
Commitment 2. Participation in the assessment of the public sector – e-goal setting tool and monitoring of the government’s work
Access to Information: Did Not Change
Civic Participation: Did Not Change
The e-goal setting system was meant to enable public monitoring and evaluation of government and administrative proceedings. However, the commitment has been implemented only as an internal public administration procedure and there are no signs that any participatory mechanism or public-facing elements have been added to the e-goal setting system. Therefore, there has been no change in government practice either for access to information or civic participation.
Commitment 3. Publish organizational charts
Access to Information: Marginal
The publication of organizational charts for public sector entities was meant to increase transparency of staffing and allow standardization of information on the structures of public agencies. Currently, the majority of public agencies still need to publish their organizational charts, civil servant jobs and position descriptions. At the time of writing this report, the website that hosts this information presented organizational charts for 399 public agencies.[Note 67: Greek Public Sector Bodies Organizational Charts Repository (in Greek), https://hr.apografi.gov.gr/organizations/browse?0] According to an expert in information architecture, the availability of this information is important for citizens, especially compared to what was available in the period before the implementation of this commitment.[Note 68: Panagiotis Kranidiotis, Information Architect, e-government professional, telephone interview with IRM researcher, September 2018.] Provided that a tool to export data in machine-readable formats will become available, Mr Kranidiotis suggests that citizens and human resource departments within and outside the public sector could use the data to extract meaningful information about the operation of agencies to suggest improvements.[Note 69: Ibid.] For these reasons, the change in government practice could be considered marginal.
Commitment 4. Accountability in dispute settlement between citizens and the public sector
Public Accountability: Did Not Change
The implementation of this commitment was limited and there has been no change in government practice.
Commitment 5. Standardize public service provision and procedures and publish a guide
Access to Information: Marginal
Civic Participation: Did Not Change
In order to improve the implementation of this commitment the Ministry of Administrative Reform utilized funds from the EU Structural Reform Support Service technical assistance program[Note 70: EU Structural Reform Support Service (Plans and Reports section), https://ec.europa.eu/info/departments/structural-reform-support-service_en#department_plans] run by Expertise France and partnered with Open Technologies Alliance (GFOSS). On this platform, public sector employees self-document in a structured way the services they provide in the course of their normal duties, as well as the procedures followed to complete the delivery of each service.[Note 71: The English version of the diadikasies.gr public service description portal, https://en.diadikasies.gr/Main_Page ] Up to September 2018, 2,186 public services were cataloged on the website.[Note 72: The Greek version of the diadikasies.gr public service description portal, https://goo.gl/TD7T1P]
According to Dr. Ioanna Kostarella, an Assistant Professor in Journalism, Research and New Media, the information in diadikasies.gr helps citizens become acquainted with the step-by-step process of service delivery and thus increases trust in public institutions.[Note 73: Dr. Ioanna Kostarella, Assistant Professor of Journalism, Research and New Media at the Aristotle University of Thessaloniki, interview with IRM researchers, 20 October 2018.] The IRM researchers consider that the volume of information available in diadikasies.gr represents a marginal step forward in government practice. Moreover, as far as civic participation is concerned, the introduction of an actual feedback mechanism for citizens that is monitored by government still remains pending without changing government practice for civic participation.
Carried Forward?
According to the government point of contact for OGP, the publication of organizational charts will continue.[Note 74: Nancy Routzouni, national point of contact, response to IRM researcher questionnaire, September 2018.] Similarly, Open Technologies Alliance[Note 75: Despina Mitropoulou, General Director of Open Technologies Alliance (GFOSS), telephone interview with IRM researcher, September 2018.] indicated to the IRM researchers that there is some willingness on behalf of MAR to continue implementing the recording of public sector procedures and practices, as well as making them available on diadikasies.gr. However, the continuation of this commitment in the framework of OGP remains uncertain, since a new action plan has not been submitted by the Greek government. A renewed commitment on publishing organizational charts could include information stating how the charts are updated and exported, as well as including analytics tools to facilitate the use of the data by other applications allowing comparisons across agencies.[Note 76: Panagiotis Kranidiotis, Information Architect, e-government professional, telephone interview with IRM researcher, September 2018.]