Any data that is not determined to be 'exempt' for reasons described above, must be published in adherence to the principles outlined in section 4.0 of the Open Data Directive (ODD).

TBS has developed a process (described below) for ministries to assess risks and publish their data. Provincial agencies should consider the ministry requirements as an example of best practice and use them as a guide to develop their own internal publication process. As an additional final step in publication, provincial agencies must notify their responsible ministry when they have published data.

Step 1: Identify and prioritize data

Organizations are expected to focus their efforts and prioritize high-value datasets for release sooner.

There are several factors that can help you decide what data should be a priority for release:

  • High value data:
    Data that is frequently requested by the public, or collected or produced in support of government priorities, mandated by act or statute, also released by other jurisdictions, or identified as high value by reputable international organizations, such as the Open Government Partnership or the Open Knowledge Foundation. See Appendix D of the Open Data Directive.
  • Public engagement and feedback:
    Data is considered of high interest or value if it is the subject of a high number of public website searches, related webpage usage (e.g., similar datasets or info), relevant to public engagements posted in the Open Government Office consultations directory, FOI requests or email/correspondence requests. Work with your web team, correspondence unit, call centres, program areas or FOIP coordinators to help determine what data the public would like opened.
  • Transparency & accountability:
    Data that increase transparency and accountability, specifically data used to create legislation, regulation, policy, program and service evaluation, or data related to asset management, procurement contracts and audited financial information (e.g., Public Accounts) is considered high-value.
  • Policy evaluation:
    Releasing data that is useful for internal and external stakeholders' evaluation of the delivery of policy, programs or services can be considered high-value. However, usefulness requires timely and frequent release to support effective evaluation.
  • Government Priority:
    Data that aligns with new or important initiatives are considered high-value.
  • Program efficiency:
    Data that can help improve the delivery of programs and services are considered high-value. To determine if data are of high-value to others, examine the inter-agency or inter-ministerial data requests (e.g., Early Development Instrument).
  • Cost/return on investment:
    Ministries and provincial agencies may want to prioritize data that will cost less to release, such as data that is already published or collected in a machine-readable format and will take less time and fewer resources to prepare as a result.
    Alternatively, data that has a large return-on-investment, such as data that can reduce FOI requests, create more efficient programs through research, or have positive economic or social impacts, should also be prioritized for release.

Given the prioritization criteria above, organizations must develop a plan, including timelines, for the publication of all datasets which were not deemed 'exempt' in their inventory exercise.

Step 2: Assess data

Once datasets are deemed eligible to be Open as part of the inventory process, the data must be assessed prior to publication for:

  • legal, security, confidentiality, privacy and/or commercial-sensitivity issues
  • compliance with French Language Service (FLS) requirements, and
  • issues management.

Ministries are responsible for leading the assessment of their respective datasets. For corporate-wide or financial data, the TBS OGO will work with the data custodians to assess the data.

Prior to publishing datasets that contain de-identified data, they should be assessed in the context of existing data to manage the risk of identification through linking with existing datasets in the catalogue, or other similar datasets that are publically available

A detailed checklist of who needs to be involved at ministries and how the data should be assessed can be found on the Open Government intranet site. The following is an overview:

Open Government lead

The ministry Open Government lead should:

  • identify their ministry’s assessment team,
  • convene the assessment team each time datasets need to be assessed, and determine timelines,
  • document the results.

Program/Policy lead

The ministry program or policy lead (e.g., the data custodian or coordinator) should consider and document the dataset’s content, any data quality issues, and update the release schedule.

Considerations when assessing data:

  • whether the data can be interpreted by other people
  • whether the data can be used to add value
  • the limitations of the dataset
  • similar data released in other jurisdictions
  • the demand for and importance of a dataset as it may determine a dataset’s economic or social impact potential.

Legal branch

Legal representatives participate to provide advice on the data’s legal issues.

Privacy team

FOIP coordinators assess whether the datasets contain personal and/or confidential information. They also provide background on whether the dataset was included in an FOI request.

If the data contains personal information, they are required to make recommendations on whether it should be redacted, de-identified or exempt from publication.

The Information and Privacy Commissioner for Ontario has published De-identification Guidelines for Structured Data. The guidelines introduce institutions to the basic concepts and techniques of de-identification, outline the key issues to consider when de-identifying personal information in the form of structured data and they provide a step-by-step process that institutions can follow when removing personal information from datasets.

IT cluster

Ministry IT clusters or ministry analytics branches can assess the data quality and accessibility, and also suggest how to extract the dataset in a machine-readable format.

Communications branch

Communications can help identify potential issues and opportunities associated with the release of the datasets. They can draft House Book Notes, Issues Notes and Qs&As to support the release of the dataset.

French Language Services Coordinator

Raw data is exempt from translation but FLS coordinators will ensure that language requirements under the French Language Services Act are met and will provide advice for identified datasets on French translation needs.

Step 3: Prepare data

The following steps should be taken to prepare data for publication:

  1. Write briefing note with background information about the datasets, relevance, assessment, frequency of updates, issues, mitigation and recommendation.
  2. Convert data into data file formats with help from IT cluster as applicable. Ensure that specific technical requirements are met and that the data is in a machine-readable format.
  3. Complete the data description form. Review mandatory requirements using the checklist.
  4. Check in with the OGO for advice and approvals on draft data description form. It is good practice to share a draft version of the data if possible as well, if seeking guidance on Open Formats.
  5. Translate the description form, the data dictionary, and other material for the Data Catalogue. For greater clarity:
    • Data files are published in the catalogue in the language in which they were collected. They are exempt from translation requirements.
    • The dataset description, metadata, and accompanying data dictionaries or technical documentation must be translated. These will be separate documents that accompany the datasets. Any separate documents to accompany a dataset must also comply with AODA requirements.
    • The ministry or affected program area is responsible for obtaining and covering the costs of translation.
  6. Un-formatted data files that are structured for database consumption already meet accessibility requirements. Formatted tables must pass Excel accessibility checks (e.g., no merged cells, alternative text, properly named columns and sheets, etc.)
  7. Update your House Book Note.
  8. Prepare your internal approvals documentation.

Step 4: Approve to publish data

New datasets must be approved before they are published. Approvals must be documented, including the name of official and date of review and/or sign off. TBS OGO will require proof of approvals, in the format used by the ministry when you submit your data.

It is important that the dataset is reviewed and approved by the following officials, using existing ministry processes for approvals:

Who needs to review?

  • Legal
  • Privacy
  • French Language Services

Who needs to approve?

  • Communications Branch
  • Manager
  • Director
  • Assistant Deputy Minister

Who needs to approve / be informed (according to Ministry process)?

  • Deputy Minister’s Office
  • Minister’s Office (including Legislative Assistant)
    • Although Minister’s approval is not mandatory, some Minister’s Offices (Legislative Assistant) will add this approval to the process. Check with your MO contacts to confirm early in your approvals process.

Tip: Identify a key contact in your ADM, DM and Minister’s Offices that will help facilitate approvals of Open Data on an ongoing basis.

What to submit for approvals:

The recommended package for ministry approvals includes the documents listed below. The mandatory approvals package for submission to the OGO is outlined in step 5.

  • Briefing Note
  • Reviewed dataset(s)
  • Draft dataset(s) name/title, description and supporting documents
  • Updated House Book Note
  • Documentation of approvals (sign-off sheets and/or email confirmations)

Step 5: Submit data

Once the dataset is approved, it is ready to be submitted to the TBS OGO. The submission package to TBS OGO must include:

  • Data file, link to data files location, or documentation required to access a database directly
  • Data description form, send to OGO who will coordinate CO approval.
  • Proof of approvals in the format used by the ministry

Before the approved dataset is published online, the TBS OGO will:

  1. Assess the data and confirm its compliance with the directive and the guidebook.
  2. Check with ministry Communications Branch to ensure their Minister’s Office has received an updated House Book Note.

Step 6: Publish data

The TBS OGO will work with Cabinet Office Digital to publish the data in the Data Catalogue on

Once published, the TBS OGO will send the relevant links to the ministry and TBS Communications will update the TBS House Book Note with the total number of datasets in the catalogue.

After publication, ministries should work with their Communications Branches and Cabinet Office to:

  • promote through social media and traditional media in both English and French (e.g., links in News Releases).
  • let their ministry and Ontario Public Service (OPS) colleagues know that they have published a new Open Dataset
  • engage with partners

Tip: Check out the Open Knowledge Foundation’s guide for more ideas on what you can do next.