of PRM tools used by the Accident Compensation Corporation, New Zealand’s government entity responsible for administration of the accidental injury compensation scheme. The academics found that the practice raised a number of fundamental questions that the government ought to be able to address when considering the implementation of PRM.90 These questions include whether: • The PRM tool is accurate – this requires both transparent evaluation processes and a thorough description of the data set on which it was assessed • The responsible agency can explain how the PRM tool works so that clients can appeal a decision made by it • The PRM tool distorts the way the agency pursues its policy objectives • The PRM tool enables the agency to ‘duck’ its responsibility to make fair and humane decisions • The PRM tool implicitly discriminates against individuals – evaluative processes should be used to identify whether this is the case • The responsible agency is effectively training employees in the use of the PRM tool and associated decision-making system 2.6 Citizen Based Analytics New Zealand is taking a leading and innovative approach to the use of scientific evidence to inform public policy, led by the Office of the Prime Minister’s Chief Science Advisor, Sir Peter Gluckman. In June 2017, the Office released a discussion paper on the benefits and limitations of how the Government can use big data to better inform social policy decisions, an approach described as “social investment” in New Zealand.91 The research was the result of a collaboration with European data statisticians via the European Commission. The use of data and citizen-based analytics has been made possible in New Zealand through the 90 http://www.otago.ac.nz/humanities/news/otago664403.html. 91 Using Evidence to Inform Social Policy: The Role of Citizen-based Analytics, A discussion Paper, Sir Peter Gluckman, 19 June 2017, http:// www.pmcsa.org.nz/wp-content/uploads/17-06-19-Citizen-based-analytics.pdf development of the Integrated Data Infrastructure (IDI), a large research database containing microdata about people and households taken from a range of government agencies, Statistics NZ and NGOs.92 Once the data is linked it is anonymised and placed under the custodianship of Statistics NZ. Researchers and analysts can then examine the data to look for trends and relationships between factors.93 The IDI has been subject to privacy impact assessments and is subject to the privacy protocols of Statistics NZ. Sir Peter Gluckman’s research notes that there are also circumstances where identifiable client level data may be used and therefore appropriate data governance, safeguards, accountability and oversight must be in place to ensure social acceptability and the social license for the use of big data.94 According to the discussion paper, in order to address the multiple uses of data, the Government Statistician, the Privacy Commissioner, the Chief Science Advisor and the Data Futures Partnership95 are working together to recommend an assurance and governance system for data access and use. Countervailing privacy risks associated with policies that enable the state access to and use of client level data were addressed by the Privacy Commissioner in a major 2017 inquiry and report on a controversial policy of the previous government to require NGOs to disclose individual client level data to the Ministry of Social Development as a condition of their funding contracts.96 The contracts were linked to MSD’s four service lines – Work and Income, Child, Youth and Family, Family and Community Services, and the Ministry of Youth Development, including services that have a children, young 92 http://archive.stats.govt.nz/browse_for_stats/snapshots-of-nz/integrated-data-infrastructure.aspx 93 Enhanced evidence-informed policy making, A report by the Prime Minister’s Chief Science Advisor, July 2017 http://www.pmcsa.org.nz/ wp-content/uploads/17-07-07-Enhancing-evidence-informed-policy-making.pdf 94 Ibid. 95 The Data Futures Partnership is an independent group funded by the New Zealand Government that identified challenges in the data-use system and facilitates conversation with New Zealanders to understand their perspectives on data use in order to develop guidelines to help organisations build and maintain trust of those whose data they wish to use, http://datafutures.co.nz/our-work-2/. 96 Office of the Privacy Commissioner, Inquiry into the Ministry of Social Development’s Collection of Individual Client-level Data from NGOs, https://www.privacy.org.nz/assets/Files/Reports/2017-04-04-Inquiry-into-MSD-collection-of-individual-client-level-data-OPC-report.pdf 21