What the Paper Said

In the Article Ethical governance model for the data economy ecosystems in Digital Policy Regulation and Governance · February 2023 DOI: 10.1108/DPRG-01-2022-0005

The authors synthesise prior work into a conceptual paper which discusses the ethical and governance challenges inherent in Emerging Data Ecosystems. Offering a conceptual solution based on Discourse and rules-based governance, they discuss the ethics and effectiveness of governance Ecosystems subject to commercially exploitative behaviour by dominant platforms. The paper presents a well-researched and reasoned hypothetical governance structure, and then presents evidence to support the efficacy using the IHAN project.

This is a top-quality paper, from a group of respected researchers. There is only one graphic, but it is relevant and presents the model well. While well structured and logical, this is a particularly concept dense paper, many concepts are assumed to be known, or must read the references. More tables might help – Possibly, particularly to quantify some of the abuse of data and provide cardinality on the scale of the issues. Semiotics are helpful in this kind of conceptual work and could have made this more accessible. It fails to present any statistical analysis and states ethical positions as facts. The assumption that these ethical positions and rational discursive approach would be universally shared outside of the liberal democracies of Europe is not considered.

Developing from prior work by the authors, this important conceptual paper synthesises many aspects and applies them to the development of a governance model for Data Ecosystems.  The research question is stated clearly – but differently in two places.

RQ1: How to govern complex data economy ecosystem in a way that all stakeholders are included ethically. (P2)

RQ2:  How to govern complex data economy ecosystem in such a way that it can include all relevant stakeholders in an ethically acceptable way?

The claimed is that:

“By offering a new ethically justified governance model, we may create a trust structure where rules are visible and all stakeholders are treated fairly.”

Given the examples of gross abuse of data by multiple technology platforms, and the regular data breaches experienced this is an extremely important issue for many stakeholders. The subject of data sovereignty and the ethics of business are topical to Regulators and Lawmakers, all digitally transformed companies and individuals as data subjects. This is evidenced by the wide range of related topics and number of reputable, peer reviewed, published papers referenced in the paper. Industry participation levels attest to this, SITRA lists 36 European proposals, the GAIA-X Association has 340 members developing pan European federated cloud services, IDS is developing a “Trustworthy Architecture for the Global Economy” .

Researching and developing a relatively new area requires a great deal of research and synthesis of adjacent and contributing topics. There are 86 direct references, including some prior publications by the authors, and four recommended publications. The background research is meticulous, and the authors are cited in peer reviewed papers on the topic. This paper successfully clarifies and condenses a wide and complex topic, while providing a cornucopia of information in the references. These are necessary, for example, the authors refer to new business models, providing three references, but no example. This makes the paper less useful to the average IT professional, who is not fluent in Business Model theory. On the Governance of Data the paper covers three theoretical constructs and combines them. 

The core tenet of the paper is that Critical Discourse Ethics (Habermas,2018) provides a path to building consensus on the ethics and consequent governance models for Data Ecosystems. By recognising the right of subjects of legislation to participate in rational discourse. This, of course, optimistically assumes that the average person is willing and able to engage in such discourse productively. Fortunately, in practice it is the professionals who act on their behalf, and the paper recognises the concept of representative actors, and the need to pragmatise the discourse.

Several statements about unethical and criminal abuse of data in ecosystems are made without direct reference to the facts. Later readers may not know what the Cambridge Analytica or DeCode Genetics cases involved.
Additionally, the critical discourse advocated, should surely reflect on the assumptions and framing perspective of the authors. Much as one may wish it to be so, it can’t be assumed that liberal western ethics apply globally.

The proposed model incorporates the IHAN project’s governance model.

Figure 1 IHAN – Ethical governance model for data economy ecosystem

The paper concludes tritely that it has shown that the current data economy is not aligned to the values of individuals, that discourse and formal governance are a permanent requirement, and that the presented governance model offers a practical solution.  One risk is that powerful platform actors may be motivated to participate, but with the intent of stalling the initiative in endless detail and discussion to retain dominant positions and cynical extraction of value from the Data Ecosystems. Much has been written about the Governance of Ethics but this paper addresses the Ethics of Governance, involving multiple stakeholders. Similar to the approach developed by the King Commission in South Africa. 

As a Conceptual paper, using a theory based discourse ethical reflection. With extensive literature reference, coupled with reference to a Case Study as subject matter. Appropriate method to identify gaps in the existing concepts, elicit opportunities for synthesis and development of a conceptual model of Data Ecosystem governance. It combines theory and considers real world application.  The methods, and their advantages, limitations and applications are well described and extensively referenced. Conversely, Ecosystems by definition require system thinking, which is implicit in the proposed solution. Reflective discourse is not easily evaluated in terms of correctness. The arguments are presented logically and developed systematically with attention to detail and extensive reference to theory. The paper does not present data but conclusions are supported by a case study.

While the subject of the paper is Data and information management, the themes of System Thinking, IS Ethics and digital innovation and transformation are incorporated into the critical discourse.


from unit of Information System Sciences, University of Turku, Turku, Finland.


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