Why the IIA is not the best forum for Government Feedback

Minister of State Sean Sherlock has recently published “A Copyright and Innovation White Paper” its a big read at 182 pages and I have only skimmed it. At the same time he then tweeted:

 The IIA in turn posted a statement on their website which outlined my key concerns with using an  “Industry body” to collate feedback for an issue that will have widespread societal impact. Specifically:

This will allow the IIA to collate the views of its members and enable us to comprehensively represent their concerns and ideas to Government and input into this important legislation. 

So its first priority is to collate the views of its members, which is right and proper. The IIA is a society of its members that as far as I know does not purport to represent the views of those segments of the industry who are not members.

The IIA then goes on to say:

Non-members are welcome to submit their comments using this survey tool. However, comments by non-members will be passed un-collated and un-filtered to the department as it would not be in the best interests of our members to use IIA resources in working for non-members.  I believe this methodology strikes the right balance of being inclusive and facilitative whilst prioritising our member’s needs as we are charged to do. Allowing the widest stakeholder feedback is quite simply in the spirit of the community.  Stakeholders are not limited to using this tool but it is open to everyone.

They are upfront about this, the IIA is about its members.

So where is the forum for feedback for non-members of the IIA? I don’t want my feedback refracted through a third party organisation. Nor do I want to be treated as a second class citizen because I have no business being a member of the IIA. Stakeholders are not limited to this tool, but where are the other tools?

What priority is the minister likely to place on IIA feedback vs feedback from other sources? No one can tell at this point. But we can infer from his behaviour on the SOPA Ireland issue that feedback and decisions how to proceed are likely to be made behind closed doors.

Can I suggest that a more open forum for Feedback would be for the minister to set up a Facebook page to which anyone can post public commentary, an email address to which private commentary can be posted and his own survey (again trivial to setup on a site like PollDaddy).

All this feedback should be published “in the raw” including back-channel input from various industry bodies who use “other channels” to reach the minister. Lets shed a little sunlight on the process.

I would be happy to do this work for no charge in order to facilitate an open feedback process.

15 thoughts on “Why the IIA is not the best forum for Government Feedback

  1. Fair point Joe … the IIA has about 300 members. If say 10% of them fill out the survey (and that might be a generous response rate as it sounds like it will be a whooper of a questionnaire) then that’s a lot of emphasis being given to the opinions of 30 people.

    I’m trying to keep an open mind about it but I’m skeptical about how much the government actually cares about what people think, and how much this ‘consultation’ is sugarcoating and optics.

    Given that they dismissed the opinions of 80,000+ people as ‘keyboard warriors’ who should ‘call off the dogs’ it seems like a pretty devious tactic to ask for the opinions of IIA members and then say ‘well, we did ask the industry’

    The IIA, like you said, doesn’t represent the web industry, just that small part of it that pays to be a member. (Same way the golden spiders represent the best of the industry that pays to win an award. err I mean pays to enter.)


  2. Yes, yes, yes. It seems that Mr. Sherlock is more bothered with posturing than real engagement. I hope the IIA told him that it was silly of them to moderate a public discussion.


  3. Agree with what you’re saying Joe; I think the IIA is inappropriate here but fear that the horse is bolted, and the government is doing a bit of window dressing. Like Stu mentioned, they’ve just ignored the voice of people on this already.


  4. Good post Joe! +1 from me.

    This issue greatly impacts the “non-industry”, end-user, citizens of this country, and they need a voice. The IIA, being an industry body, is not appropriate.


  5. If you read the consultation document all the details on making a submission are there, along with details of the public meetings. I for one would be delighted to see multiple submissions from as many separate sources as possible.

    From the IIA’s statements its clear that they intend to represt their members, but are happy to forward any submissions that non members want to make; I wouldnt expect any more of them that that. I honestly believe that the IIA have no desire to be the “piggy in the middle here”. Yes they are obliged to represent the interests of their members and make a submission on their behalf but I think Mr Sherlock is using the IIA as an easy target here to minimise the amount of crap he has to deal with personally by suggesting people go through them. Its easy for him to single them out since recently they did organise industry representation on the #sopaireland issue and I guess since they organised meetings and interactions that didnt involve rabid individuals foaming at the mouth he’s trying to fob it all off on them again.

    In the end when you read the consultative document its clear that the IIA have been given no official role in this, all submissions still have to be directed to the consultative body itself so Sean Sherlock pointing people their way is clearly a deflection. If the IIA had had any secret backroom dealing or struck any sort of arrangement regarding being an official “moderator” then the consultative document would outline that. I’ve read and engaged with many such documents over the years and in any cases where IBEC or any industry body have an “official” role, its clearly outlined.

    In the end, Minister Sherlock is hoping that by using the IIA as a body shield, he wont have to be front and centre with the debate and discussion. Our anger and frustration should be directed at him.


    1. Hmm, that’s like saying the MySQL database the results are stored in is not Vendor Neutral. Facebook is not going to interfere in the posted content in anyway.


  6. i know it was seansherlock who caused confusion by announcing something the IIA was going doing to but are people still confused by ‘a’ consultation vs ‘the’ consultation? there is consulation process in place and unlike sopaireland they published the submission to the first round of consultations.

    it was terrible idea for iia to alllow sherlock to announce its own consultation, undermined it from the start


  7. So basically Sean Sherlock wants the IIA to do his job for him ? Also introducing this tiered responses, i.e. IIA member versus non-IIA member doesn’t seem like classifying comments equally.


  8. Joe

    I deal with internet policy matters on a regular basis.

    The IIA are in a better position to hand over feedback than any other organisation out there – be that for member or non-members.

    If you aren’t a member and work in the digital industry in Ireland you should join. (It’s not exactly expensive!)

    As for Facebook etc – that’s a really bad idea. A lot of people have taken to verbally abusing Sean Sherlock on Twitter, Facebook and other media. Verbal abuse does not help anyone and is not the kind of response that will lead to a meaningful and full review of the legislation




    1. Hi Michele,

      The IIA may be in a better position to collate material related to Internet business and businesses, but I disagree that they should be the preferred route for matters of general public interest. In this matter the IIA represents only one body of opinion and a minority opinion at that.

      I am very happy for an Facebook page administrator to immediately delete personal abuse. That of itself does not preclude the use of a neutral channel like Facebook to collect Feedback.



    1. Does that form break Data Protection Legislation by transferring my personal data (name and address) outside of EU jurisdiction and by giving no clear indication on what the data is to be used for. Oh for the love of, we can’t even collate data about one aspect of legislation without falling foul of another.


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