Comments on the Draft ICAR Open Access Policy
The following comments were submitted to the Indian Council for Agricultural Research on May 23, 2013.
Introduction
The Centre for Internet and Society,[1] is is a not-for-profit research organization. Our substantive areas of work include openness (including openness of government data, open access to scholarly literature, open standards, free and open source software, open educational resources, and open video) access to knowledge and IPR reform, freedom of expression, privacy, accessibility for persons with disabilities, digital humanities and digital natives.[2]It is our belief that openness and collaboration are the agents of innovation and creativity, and the advent of the internet has radically redefined the meaning and practice of openness and collaboration. Pursuant to our vision, we have been actively involved in the area of Openness and the promotion of open access.[3]
Key research and highlights of our work in these areas are as under:
- Comments on the Interoperability Framework for e-Governance (Phase 1), submitted to the Department of Information and Technology.[4]
- A Status Report on Open Access to Scholarly Literature in India.[5]
- A Survey Report on the Online Video Environment in India.[6]
- A Report on Open Government Data in India.[7]
- An Open Government Data Study.[8]
- Publication of multiple blog posts and the conduction of various events including workshops and seminars around Openness and Open Access.[9]
We hope that our commitment to Open Access and Openness, substantiated with our work in these areas leads you to consider our comments to your Draft Open Access Policy favourably.
The Structure of the Report
This report will deal provide feedback on the structure of the policy, various clauses of the policy, what clauses may be omitted (if any) and other clauses that may be included. Additionally, possible challenges that might require to be addressed in the implementation of this policy have also been indicated.
Overview
It is felt that the ICAR Draft Policy on Open Access is fairly comprehensive, covering most areas associated with its implementation, detailed, embodies the principles of openness and open access, and is a step in the right direction towards achieving open access to scientific and scholarly literature, acting as an example for other communities to do the same.[10]
Structural Feedback
It is suggested that the policy be structured along the lines of the UNESCO Library Open Access Policy, with headings including Introduction, the Objectives/Mission Statement of the Policy, Applicability, Repository, Roles and Obligations of various participants, Intellectual Property Law Issues and Implementation.[11]
Feedback on Existing Clauses
The decision of the ICAR to implement an Open Access Policy is commendable, and an encouragement to other institutions to follow suit.
The adoption of OAI-MHP standard will ensure interoperability, given that it is seen as the cornerstone in open access to institutional research output, and failure to utilize this standard would reduce accessibility and therefore the impact of materials, since they are invisible to each other.
The provisions of the content to be made a part of the repository, and the implementation are comprehensive and detailed. Inter alia, measures involving encouragement to publish in journals that allow for open access through archiving, workshops for advocacy and capacity building, adoption of the CC-NC-SA license are appreciated.
Suggested Changes
It is suggested that the Policy include provisions on information to be made available in accessible formats. In pursuance of the same, it is particularly suggested that the ICAR adopt measures to publish literature that is made available through this Open Access mechanism in formats accessible for visually impaired/print disabled persons, to truly realise the underlying aims of Open Access.
It is suggested that in addition to class/lecture notes already included under the content, ‘course content’ developed for any class/seminar/lecture in any university/college/educational institution be made a separate category of material to be included for open access.
It is suggested that the following sentence in the proposed policy be further clarified: “Scientists are advised to mention the ICAR’s Open Access policy while signing the copyright agreements with the publishers”- A clarification is required regarding the application of this sentence and its applicability. Would the policy apply to both those cases where the scientists have copyright over their work, and where the institute has copyright, or to only one of these scenarios?
It is suggested that the ICAR participate in the development and promote the building of cross institutional services (cross repository services) to further the aims of Open Access,[12] and the same be reflected in the forthcoming policy.
It is suggested that the forthcoming policy include an explicit provision on long term digital preservation[13] of the collected information, including possible measures that the ICAR may adopt to this end.
It is suggested that the forthcoming policy include a specific provision that requires contributing scientists/researchers etc. to explicitly declare that they have the copyright for and have obtained the necessary permissions to post and contribute to the Open Access Project.
It is suggested that the ICAR take steps for aiding the development of Open Access Journals. In furtherance of the same, the ICAR could have links of the websites of these Journals on its own repository, such that the link to the articles on the websites of these Journals leads directly to the ICAR Repository. Such a move would incentivise authors to contribute, since their effort would be recognised, and researchers would have a persistent source to cite from an archive. This effort would also be in consonance with the broader aims of Open Access that the ICAR is keen to achieve through its proposed policy.
It is suggested that the policy also include measures to encourage persons not members of the ICAR to contribute to the Repository.
It is suggested that as regards the implementation aspects of the creation of this repository, the ICAR would also have to ensure the creation of digital document identifiers for all content to be contributed to and housed on the repository. Additionally, the policy ought to also lay down standards of training and development of the staff and authors to submit content to the repository, and to be able to efficiently utilize the same. It is also suggested that the policy encompass the development of a framework for feedback for users and feedback from users, where the former would provide current statistics and details about articles and contributions to users, and the latter would be a mechanism for users to comment on their experience in utilising the repository.
Concluding Observations
The Centre for Internet and Society deeply appreciates the effort undertaken by the ICAR to bring about Open Access in its area of work, which is definitely a welcome step in the right direction. CIS hopes that given its commitment to Open Access and strong tradition of work in this area, the ICAR would give due regard to the observations made out in this report.
[1]. Hereafter referred to as CIS.
[2]. See http://cis-india.org/about for more details.
[3]. See http://cis-india.org/openness for our work on Openness.
[4]. Available at http://cis-india.org/openness/blog/comments-ifeg-phase-1
[5]. Available at http://cis-india.org/openness/blog/open-access-to-scholarly-literature
[6]. Available at http://cis-india.org/openness/online-video-environment-in-india
[7]. Available at http://cis-india.org/openness/blog/ogd-draft-v2-call-for-comments
[8]. Available at http://cis-india.org/openness/blog/open-government-data-study
[9]. See http://cis-india.org/@@search?SearchableText=open+access for details of our posts and events on Open Access.
[10]. United Nations Educational, Scientific and Cultural Organization, Open Access Policy Concerning UNESCO Publications, available at http://www.unesco.org/new/fileadmin/MULTIMEDIA/HQ/ERI/pdf/oa_policy_en_2.pdf (last accessed 22 May, 2013).
[11]. Id.
[12]. Gerard van Westrienen and Clifford A. Lynch, Academic Institutional Repositories: Deployment Status in 13 Nations as of Mid 2005, available at http://dlib.org/dlib/september05/westrienen/09westrienen.html (last accessed 22 May, 2013).
[13]. Leslie Chan, Supporting and Enhancing Scholarship in the Digital Age: The Role of Open Access Institutional Repositories , Canadian Journal of Communication, Vol. 29 (3&4), 277, 282.