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HomeMy WebLinkAboutData Governance StandardsData Governance Standards – August 2020 1 City of Chula Vista Data Governance Standards Updated August 2020 Data Governance Standards – August 2020 2 Contents Introduction ........................................................................................................................................................................ 3 Part 1: Data Governance Roles & Responsibilities ............................................................................................................. 4 Part 2: Data Inventory Annual Process ............................................................................................................................... 6 Step 1. Identify/verify city datasets ................................................................................................................................ 7 Step 2. Identify/verify data-sharing relationships and complete data “wish list” .......................................................... 7 Step 3: Review and prioritize datasets ........................................................................................................................... 7 Part 3: Publishing Open Data .............................................................................................................................................. 9 Step 1. Assess sensitivity .............................................................................................................................................. 10 Step 2: Mitigate risks .................................................................................................................................................... 11 Step 3: Upload .............................................................................................................................................................. 12 Step 4: Assess quality and publish ................................................................................................................................ 12 Part 4: Updating City of Chula Vista Data ......................................................................................................................... 14 Appendix A: Data Inventory Worksheet Appendix B: Data Sharing Worksheet Appendix C: Recognizing Sensitive and Protected Data Data Governance Standards – August 2020 3 Introduction The City of Chula Vista recognizes the data it generates as a strategic asset. City data is not merely a byproduct of the City operations, but a valuable tool that can be used to generate insight, align priorities, and make decisions. Through the Smart City Strategic Action Plan and the Open Data Policy, the City Council has prioritized a shift toward making City-owned data easier to access and analyze both internally — among different teams and departments — as well as externally with other government agencies, nonprofit organizations, academic researchers, and residents at large. Providing access to city data through an open data program creates value by providing the public with transparency and a better understanding of City operations. Open data helps break down silos within the City organization and between the City and other agencies, potentially increasing the accuracy and effectiveness of policies and programs. Open data can also improve and strengthen the dialogue between the City and the public, building trust, promoting accountability, and establishing a shared sense of priorities. The City also recognizes that the opportunities presented by open data come with challenges and risks. Protecting individual privacy is of paramount concern when data is released to the public. Ensuring that open data is accurate, current, and in accessible formats is essential to its value. Presenting the data in its proper context is critical to facilitating understanding and avoiding misinterpretations and improper use. The City has established a Data Governance Committee for the purpose of navigating these challenges and risks and delivering value from open data. The Data Governance Committee, comprising representatives from various City departments, is responsible for setting priorities, protecting privacy, ensuring accuracy, resolving conflicts, and directing the design and implementation of data portals and visualization tools. It is important to note that while the Data Governance Committee performs high-level leadership and oversight, the success of the open data program requires the involvement of many City employees and external stakeholders. In each City department, staff who work directly with data are key to the program’s ability to function. Described as data coordinators, these staff are the experts on specific datasets and serve as the stewards of that data in the context of the open data program. This Data Governance Standards document serves as the primary manual and policy guide for the open data program. Developed by the Data Governance Committee with insight from successful open data programs in other U.S. cities and agencies, these standards form the basis of the program. This document will be expanded and updated periodically based on new developments in the program. Data Governance Standards – August 2020 4 Part 1: Data Governance Roles & Responsibilities The Data Governance Committee includes the Program Lead and a representative selection of City staff who support the program with decisions and policies that require specialized knowledge of City operations, legal matters, or technical systems. The Data Governance Committee makes high-level decisions about data-sharing agreements, open data, data publication priority, and other related issues. The Program Lead is responsible for the implementation of the vision for the open data program. The Program Lead guides the work of the Data Governance Committee to set priorities, define related policies, and coordinate with the open data program’s technical systems and organizational processes. Data Coordinators are the subject matter experts in their respective service areas and will help identify potential datasets, upload datasets to the open data portal, and periodically update data. Data Coordinators serve as a liaison between the Data Governance Committee and their respective departments or service areas. Data Coordinators may also participate directly on the Data Governance Committee. Every department, including Police and Fire, has at least one designated data coordinator. Figure 1 and Table 1 outline in more detail the specific roles and responsibilities of various City staff in the context of data governance. Note that some individuals might serve more than one function. Figure 1: Data Governance Relationships City Management Data Governance Committee Program Lead IT / GIS Data Coordinators Communications Manager City Attorney Data Governance Standards – August 2020 5 Table 1: City Staff Roles and Responsibilities Role Description Chula Vista Staff Executive Support • Executive level support and encouragement of the open data process. This is critical to gaining buy-in citywide. • Publicly announce the new open data program or policy, as well as provide encouragement and support to the City’s Data Governance Committee. City Management Strategic Alignment • Responsible for overall program leadership; ensures alignment with overall city and administration goals. • Create accountability for department heads and delegated departmental staff; help set and approve priorities for data releases; reports to the City Manager or Assistant City Manager(s) on program activities. • Assign data coordinators within each service area. Open Data Program Lead Communications Strategy • Ensure public datasets are presented with messaging consistent with city goals and programs. • Assist city leadership with potential responses to public input on published dataset. • Oversee public engagement activities and events. Communications Manager Technical Operations • Oversee the technical aspects of open data, such as maintaining the public data catalog, extracting data from internal IT systems, and ensuring public data is kept up to date. • Build and configure the tools needed to routinely copy data from city technology systems to the open data website. IT Director GIS Manager Data Coordinators • Work with the program lead and others to complete periodic data inventories and ensure the publicly released data is accurate, well documented, and up to date. • Review source data systems; recommends specific data elements for release approval; helps develop public documentation; handles manual data publishing if needed. Department staff as assigned Legal Strategy • Assist in developing policy and guidance materials for releasing datasets. • Develop terms of service and licensing for data access and usage. • Resolve legal considerations for complex datasets. City Attorney’s Office Data Governance Standards – August 2020 6 Part 2: Data Inventory Annual Process The City maintains a comprehensive inventory of the various sets of data in its possession. Maintaining this catalog of datasets helps City staff and the public understand what data might be available to them. A data inventory is a fully described record of the various sets of data maintained by the City. The inventory includes basic information about each dataset, such as its name, a description of its contents, how frequently it is updated, who owns and maintains the dataset, whether it is subject to privacy laws, the source of the data, and other relevant details. These details about a dataset are known as metadata. It is important to keep in mind that the data inventory does not consist of any raw data. The data inventory provides metadata only. The actual contents of the datasets are maintained separately from the data inventory. Each year, the City updates the data inventory using a prescribed process to identify datasets, identify data-sharing opportunities, and prioritize datasets for publication in a public open data portal. The process of updating the data inventory is led by the open data program lead and the Data Governance Committee, with support from data coordinators in each of the city’s departments and program areas. Figure 2: Data Inventory Process • Data coordinators complete inventory worksheet • Data coordinators identify which of their datasets are shared with other departments • Data coordinators identify which datasets they want or need from other departments • Data Governance Committee checks worksheets for accuracy and completeness • Data Governance Committee prioritizes datasets based on demand and difficulty of implementation For a data inventory worksheet template, see Appendix A. For a data sharing worksheet template, see Appendix B. Identify / verify datasets Identify/verify data-sharing relationships Review and prioritize datasets Data Governance Standards – August 2020 7 Step 1. Identify/verify city datasets Each fiscal year, data coordinators around the City work with their departments to complete an inventory worksheet that lists all datasets created or managed by that data coordinator’s respective service area. The existing data inventory, as well as worksheets from the previous year, may be used as a starting point for the following year’s inventory. In addition to identifying datasets and providing details for each dataset, the worksheet asks data coordinators to suggest a draft priority level for each dataset. This suggested priority level reflects the data coordinator’s opinion on how valuable or impactful the data might be to another user. For a sample worksheet, see Appendix A. Note that all datasets are included in the inventory, including datasets that may contain sensitive or restricted data, or datasets that may not seem valuable to the open data program. Step 2. Identify/verify data-sharing relationships and complete data “wish list” While completing the data inventory, data coordinators also identify which datasets are regularly being shared among departments, and identify which departments regularly receive a given dataset. The purpose of tracking these data sharing relationships is to identify opportunities to create efficiencies and assist in the prioritization of data publication. In addition to noting which datasets are regularly being shared among departments, the worksheet asks data coordinators to make a “wish list” specifying datasets that their department or team wishes to procure from another department. For a sample worksheet, see Appendix B. Step 3: Review and prioritize datasets Following the submission of data inventory worksheets, the program lead coordinates with the Data Governance Committee to consolidate the various worksheets into a master inventory. The program lead, Data Governance Committee, and IT team then perform a review and gap analysis to identify any datasets missed by data coordinators. Chula Vista employs a series of relational databases to house complex datasets, and data within these important databases could be missed by some coordinators. The program lead works with the IT team to conduct a gap analysis between the results of the data inventory and the contents of the City’s various relational databases. Data coordinators then assist with filling in any missing details. The data coordinators will have suggested draft priority levels for datasets in their respective worksheets. The program lead, in consultation with the Data Governance Committee, will review these draft priority levels and make adjustments as necessary. The priority level will be based on two dimensions, the demand for or value of the dataset, and the ease of publication. Priority levels will be assigned as high, medium, or low in each area. Data highest in demand and lowest in difficulty of implementation will be considered Priority 1 (P1). Data lowest in demand and highest in difficulty of implementation will be considered Priority 4 (P4). Table 2 shows the priority levels resulting from the relationship between demand and difficulty of implementation. Departments will review the draft inventories and priority levels and have an opportunity to submit corrections. Data Governance Standards – August 2020 8 Table 2: Dataset Prioritization Matrix Demand/Value: • High – The dataset is tied to a performance management goal, a City Council or City Manager’s initiative, or would provide immediate benefit to multiple departments, the organization, or the community for making data-informed decisions. • Medium – At least one of the following is true concerning the dataset. The dataset has been previously requested or has the potential to be requested by the public or business community. The dataset has been included on a department data wish list as defined in the previous section. • Low – The dataset historically has had little or no public demand. Little organizational, departmental, business, or public benefit has been identified. Difficulty of implementation: • Low – Most of the following are true concerning the dataset. Very minor (if any) sensitivity concerns are found in the dataset and can be quickly and easily mitigated by the data coordinator and program lead. Metadata is already accessible, or easy to produce. The data is already in a format that can be uploaded to the portal or is easily configured and converted. An existing automation process used to maintain data on the portal can be implemented for the dataset. • Medium – The dataset configuration will require a concerted effort but can be generated in a format that the portal accepts without deviating from the established business process. Sensitivity concerns are minor and successfully addressed by the data coordinator and program lead. Metadata can be generated for the dataset within the current business process for creating open datasets. • High – One or more of the following is true concerning the dataset. The dataset contains significant sensitivity concerns that will require an extended sensitivity review process, a legal department review, or a significant revision of the dataset to resolve. The dataset requires significant configuration to generate the file in a format the portal accepts. Setting up the automation process will require a change in business process and will require significant effort. HighP2 P3 P4 MediumP2 P2 P3 LowP1 P2 P2 High Medium LowDifficulty of implementationDemand / Value Data Governance Standards – August 2020 9 Part 3: Publishing Open Data After the data inventory and prioritization process is complete, datasets are uploaded to the open data portal using the following process to effectively ensure strict adherence to data privacy protections and legal requirements. Figure 3: Data Publishing Process Data Governance Standards – August 2020 10 Step 1. Assess sensitivity Transparency is a core goal of Chula Vista’s open data program, but transparency must be balanced with the imperative of protecting sensitive and private information. The City’s Open Data Policy (Policy Number 112-03) excludes the following protected data from publication: • Any data which if published would violate state or federal laws governing privacy or privileged information • Any data which if published would violate contractual or proprietary rights • Any data which if published would jeopardize the security of individuals or property Refer to Appendix C for further discussion and examples of potentially protected data. For each new dataset that has been identified for publication, the data coordinator and program lead will perform a sensitivity assessment to address concerns about protected data. The data coordinator begins by documenting any sensitivity concerns and sharing these concerns with the program lead. The program lead reviews these concerns and classifies the dataset as having “no concerns,” “minor concerns,” “significant concerns,” or “overwhelming concerns.” If there are no concerns or only minor concerns, the data coordinator is responsible for applying appropriate mitigation (see Step 2). Once the data coordinator has applied mitigation measures, the program lead will verify that all concerns have been addressed and will present the concerns and mitigations to the Data Governance Committee for approval. If the data coordinator does not complete the mitigation within 30 days, the dataset will automatically be forwarded to the Data Governance Committee for review. In cases of significant or overwhelming concerns, the program lead will present the dataset to the Data Governance Committee, which will determine appropriate mitigation measures to be applied by the program lead. The committee will confer with the City Attorney’s office if necessary to ensure any proposed mitigation adequately resolves concerns. Table 3 provides more detail about this process. Data Governance Standards – August 2020 11 Table 3: Sensitivity assessments Level of concern What it means How it is handled No concerns The dataset does not contain any information that a reasonable person would consider protected. Skip to Step 3, Upload. Minor concerns The dataset contains some protected data, but these data can be easily mitigated (for example, a column that can be easily removed from the dataset). These concerns are communicated to the data coordinator or program lead for mitigation (see Step 3). The dataset is then re-reviewed by the program lead and the Data Governance Committee. Significant concerns The dataset contains protected data that cannot be easily resolved, but the issue does not immediately disqualify the dataset for publication (for example, data is anonymized but could be easily re- identified when combined with another published dataset). The dataset and documented concerns are forwarded to the Data Governance Committee and, if appropriate, the City Attorney’s office, for review and, if possible, mitigation. Overwhelming concerns The dataset contains significant protected data that obviously cannot be mitigated (for example, the dataset is clearly protected by state law). The dataset is presumptively disqualified from publication but forwarded to the Data Governance Committee and City Attorney to determine if any portion of the dataset can be published without compromising protected data or violating the Open Data Policy. Step 2: Mitigate risks If there are any concerns about protected data identified during Step 1, then the data coordinator, program lead and/or Data Governance Committee will identify and apply appropriate risk mitigation techniques, which may include: • Redaction (e.g., deleting a column of names). • Anonymization (e.g., reducing the precision of addresses). • Aggregation (e.g., averaging a dataset by age group). • Constraining access (e.g., limiting access to city staff). • Forgoing publication and discarding the dataset. Redaction is the process of removing sensitive information from a dataset. In the context of open data, redaction generally means deleting entire columns or rows from the dataset. It may also mean deleting specific cells if those cells contain sensitive data. Anonymization is the process of removing sensitive information and replacing it with a value that cannot be tied to an individual person’s identity. For example, a spreadsheet of all registrants for City recreation programs could be anonymized by removing any identifying details and replacing the name with a random number. Anonymization could also mean reducing the specificity of identifying information. For example, a spreadsheet of all police calls for service could be anonymized by removing all street address numbers and replacing them with block numbers only. Data Governance Standards – August 2020 12 Aggregation is the process of combining multiple entries within a dataset into one common category. For example, a dataset of all citations issued for residential code violations could be aggregated so that the totals are only presented for each Council District, or each ZIP Code, rather than each individual home address. Constraining access is a less common mitigation measure that may be appropriate for data sets that have high value but that also present significant or overwhelming sensitivity concerns. Constraining access is the process of making a dataset available only to selected users. For example, access to the Human Resources department’s timesheet data is limited to the Finance Department and select others within the City, but this data is never made available to the public or any external users. Forgoing publication is the last resort if other mitigations are not available. Some datasets simply contain too much protected data that cannot be mitigated using one of the methods described above. In these cases, the Data Governance Committee may decide that the dataset is not a candidate for publication. While the above-listed mitigation methods are the most common ways of mitigating, there may be other mitigation measures that are appropriate in specific circumstances. Step 3: Upload After completing sensitivity review and mitigation, datasets will be uploaded to Chula Vista’s open data portal. Upload can proceed in one of two ways: • Option 1: Data coordinators upload data directly to the portal. This method is ideal for large departments that have many datasets to contribute to Chula Vista’s open data portal. The open data program lead is responsible for training these data coordinators on using the City’s open data portal. o Data coordinators will coordinate the dataset upload with the open data program lead. o In addition to uploading datasets, data coordinators will input metadata (e.g., readme text, column descriptions) to contextualize datasets and dataset attributes. Metadata must include information on update frequency. o After the data coordinator has uploaded a new dataset and entered metadata, he or she will share the private dataset with the program lead for review. • Option 2: Data coordinators send data to the open data program lead, or the program lead’s designee, for upload to the portal. This method is intended for smaller departments and groups that may have only a small number of datasets to contribute to Chula Vista’s open data portal. o Along with new datasets, owners will send metadata (e.g., a readme text file, column descriptions) to contextualize datasets and dataset attributes. Metadata must include information on update frequency. o The program lead or their designee will upload new datasets, input metadata, and then share the private dataset with data coordinators for review. Step 4: Assess quality and publish After a dataset and associated metadata have been uploaded to the portal, but before they are published, a final quality assessment (QA) review takes place to find and correct any errors in the data itself or in the metadata. The QA is conducted by either the program lead or the data coordinator (whoever did not upload the data, as the intent is to subject the dataset to a fresh set of eyes). Datasets that pass both the sensitivity review and QA are made public on the portal. Each dataset is unique and requires a different process to review and assess quality. However, certain commonalities apply across all datasets. Chula Vista’s open data program employs the following quality standards during the dataset QA process: Data Governance Standards – August 2020 13 • The dataset is the most complete, accurate, and current version appropriate for public release. • The data have been spot-checked for common errors such as missing and misplaced values. • Any missing data points are left as null, but the meaning of null is defined in the dataset’s metadata. • Columns are formatted appropriately. • Metadata is complete, concise, and free of jargon. • Metadata explain the process used to create the data and summarize any changes. • Metadata clearly explain any limitations or omissions for each dataset. • Metadata clearly identify an update frequency and plan. Before publishing a new dataset (or updating an existing dataset), the reviewer (program lead or data coordinator) must verify whether any existing dashboard or other tool is dependent on that dataset. The reviewer must coordinate with whomever is responsible for the associated dashboard or other tool to ensure that updating or replacing the dataset will not interfere with the intended operation of the dashboard or tool. It is important to note that the open data program is not a data editing program. No dataset is perfect. Data coordinators will not be asked to substantially change or improve datasets pulled from city systems before uploading them to the portal. Data coordinators are not asked to impute missing values, though they may do so if they wish. The primary goal of the program is not to improve city data, but rather to share existing data with the public and among city staff. The program also provides an opportunity to gain feedback about the quality of data from other departments and the public. Any improvement to internal processes for data creation and curation that results from the open data program or associated feedback will be considered welcome but auxiliary. Data Governance Standards – August 2020 14 Part 4: Updating City of Chula Vista Data A successful open data program requires current, up-to-date data. When submitting a dataset to be published to the portal, data coordinators must ensure that update frequency is included in the metadata. Coordinators are responsible (with assistance, if needed, from the program lead) for all manual updates to datasets. Whenever possible, coordinators will update an existing dataset instead of creating a new dataset. Nevertheless, data coordinators may have limited time to monitor the freshness of datasets posted on the portal. The program lead will employ two tactics to help ensure the data portal remains up to date: • Active monitoring of dataset freshness. The program lead will periodically review each dataset on the portal and will alert data coordinators when a dataset is identified as out of date and needs to be refreshed. • Automation. For datasets that need to be updated at least once per month or more, the program lead will work with data coordinators and the IT database administrator to implement automatic updates, where appropriate. Appendix A Appendix A: Data Inventory Worksheet Dataset Title Department Division / Team Data Owner Description Format System / Source Sensitivity Sensitivity Comments Update Frequency Data Quality Data Value Accessibility Draft priority Human-readable name of the asset. Should be in plain English and include sufficient detail to facilitate search and discovery. Avoid acronyms. Department where the data is maintained. If more than one department, list the primary responsibility. The name of the division or team within the department where the data is maintained. Name of the staff member who is primarily responsible for maintaining the dataset. What the dataset describes. Provide a longer description of the data that can be readily understood by non-technical users. What file format is the data in? Examples: CSV, ArcGIS Feature Class What is the original system/application/file that houses it? Please provide additional comments as necessary. Does the dataset contain sensitive data, such as personal phone numbers, Social Security Numbers, etc.? What could be done to make the data shareable? How often is the dataset updated? Examples: Hourly, Daily, Weekly, Quarterly How accurate and consistent is the data? How valuable is the data to the city internally? How difficult is it to access and publish this data? Page 1 of 1 Appendix B Appendix B: Data Sharing Worksheet Dataset Title Owner Department Owner Division/Team Requesting Department Requesting Division/Team Description of Use Update frequency requested Current contact Notes Human-readable name of the asset. Should be in plain English and include sufficient detail to facilitate search and discovery. Avoid acronyms. Department where the data is maintained. If more than one department, list the primary responsibility. The name of the division or team within the department where the data is maintained. Department where the data is used or will be used. The name of the division or team within the department where the data is used or will be used. Describe the purpose for sharing the data / how it is used by the requesting department How often does the dataset need to be updated to be useful to the requesting department? Page 1 of 1 Data Governance Standards – Appendix C – August 2020 1 Appendix C: Recognizing Sensitive and Protected Data The City’s Open Data Policy (Policy Number 112-03) excludes the following protected data from publication: • Any data which if published would violate state or federal laws governing privacy or privileged information • Any data which if published would violate contractual or proprietary rights • Any data which if published would jeopardize the security of individuals or property To assist staff in recognizing data that may be sensitive or protected from publication, this appendix provides examples and discussion from several sources. The Chula Vista City Clerk’s Office, in evaluating whether data is exempt from disclosure under the California Public Records Act, considers the following parameters as part of its decision on what to release publicly: “Protected Data” is any Data or Dataset: • that is otherwise exempt from disclosure pursuant to California laws including but not limited to the California Public Records Act. • that contains a significant amount of Data that, if disclosed, would impose an undue financial or administrative burden on the City. • that reflects the internal deliberative or administrative process(es) of the City, including, but not limited to, Data relating to negotiating positions, future procurements or pending or reasonably anticipated legal or administrative proceedings. • that is subject to privacy laws or subject to copyright, patent, trademark or trade secret protection, or to a confidentiality agreement, or that are otherwise protected by law or contract. • that includes or constitutes proprietary applications, computer code, software, operating systems or similar materials. • that includes or constitutes employment records, internal employee-related directories or lists, protected health information. • which, if disclosed by the City, might in the City’s discretion, raise privacy, confidentiality or security concerns or jeopardize or have the potential to jeopardize public health, safety or welfare. When making data available, staff should consider the possibility that multiple data sets could be combined, resulting in the inadvertent availability of protected data and take steps to ensure the protection of such data. The following table shows exemptions to consider when producing data/datasets for common data and many of the most frequently raised exemptions from disclosure that may, or in some cases, must be asserted by local agencies: Data Governance Standards – Appendix C – August 2020 2 Type of Data Example Data Legal Citation Incomplete Datasets Incomplete Data; Preliminary Information; Drafts; Notes Government Code §6254(a) Personal Contact Information Address; Phone Number; Email Address Government Code 6255 Licensee Financial Information Personal financial data required by applicants Government Code §6254(n) Law Enforcement Arrest records or complaint reports; investigatory or security files; intelligence information Government Code §6254(f) Library Circulation Data kept for the purpose of identifying the borrower of items available in libraries. Government Code §6254(j) Pending Litigation/Claims Pertaining to pending litigation or unsettled claims Government Code §6254(b) Personnel, Medical or similar files Employment records; Questions scoring keys and other examination data Government Code §6254(c)(g) Real Estate Appraisals; Engineering Evaluations Government Code §6254(h) Taxpayer Information Data required from taxpayer in connection with the collection of local taxes Government Code §6254(i) Trade Secrets/Proprietary Information Records and information related to the award of a public contract. Government Code §6254.15 It is important to realize that while entire datasets may clearly be of a sensitive nature, it is also possible for smaller subsets of data within a larger dataset to present problems. For example, a single row or column within an otherwise benign dataset could contain sensitive data. A single cell, or handful of cells, within a dataset, may contain unexpected sensitive data, which may have been placed there either intentionally or by mistake. It may be helpful to think of sensitive data as falling into one of several categories. Direct or unique identifiers: Sometimes known as Personally Identifiable Information (PII), these attributes or features can clearly identify individuals. Examples: • Name • Social security number • Employee ID numbers • Email address • Home address • Phone number • Driver’s license number Indirect or quasi-identifiers: Attributes or features within a dataset that do not clearly identify individuals on their own; however, in combination with other data, these attributes can lead to the identification of an individual in what is known as the “mosaic effect.” Examples: Data Governance Standards – Appendix C – August 2020 3 • Birth date • Zip code • Gender • Race / ethnicity • Income level • Age or age bracket • Medical conditions Addresses: Street addresses are an often-overlooked source of sensitive data. While home addresses can obviously be unique identifiers, other addresses or place names can act as quasi-identifiers that reveal sensitive details about individuals when combined with other quasi-identifiers. Additionally, geographic coordinates can function in the same way as street addresses. Unstructured fields: Unstructured fields contain open-ended written comments or descriptions (as opposed to structured fields, which only offer a limited range of pre-determined values). Examples include: • 9-1-1 call descriptions • Online survey responses • ACT Chula Vista service requests • Any other freeform text fields that could be filled in unpredictable ways If you are unsure if data should be considered sensitive or protected, discuss it with the Open Data Program Lead, who may also share the question with the Open Data Governance Team. This guide was developed with significant reference to the following sources: • DataSF Open Data Release Toolkit: Privacy Edition: https://docs.google.com/document/d/1_K59q9ik5eEw9_-iiPCbQ8WSlGk0FovNz1uLajVHoi0/edit • “Open Data Privacy” by Ben Green, et al., Berkman Klein Center for Internet & Society at Harvard University: https://dash.harvard.edu/bitstream/handle/1/30340010/OpenDataPrivacy.pdf