Skip to main content

Recommendation 2

Recommendation 2: Make location information policy integral to, and aligned with, wider data policy at all levels of government

Implementation guidance Related information



  • Location information is key public data and much public policy has a location context.
  • Location information has particular requirements that need to be considered in formulating wider data policy.
  • It is important to avoid contradictions between location information policy and broader data policy.
  • Authentic location data is costly to maintain and this needs to be recognised in wider data policy decision making.
  • A connected strategic approach will help align implementation actions for mutual benefit.
  • Interoperability of data policies paves the way for integrated digital public services offered cost effectively, aiming to solve overarching societal problems and create value for a broader range of users.
  • Public-private partnerships and crowdsourcing of data can support sustainability and reliability goals and ensure real needs are met.
  • Effective data policies are seen as important at a European level and enhancements are introduced from time to time to ensure policies reflect latest requirements (e.g. Open Data Directive, European Data Strategy, GDPR). It is essential that location data stakeholders and policies recognise and align with these wider data policy developments.




Policy reach

  • When developing the approach to ensure consistency and alignment between location policy and wider data policy, include key topics such as data sharing, open data, authentic data, data licensing (including reuse), intellectual property rights (IPR), privacy, data protection and the ethical and professional handling of data.
  • Ensure that location information is a prominent feature of policies and actions in areas where it can make an important contribution, e.g. open data, authentic data, data licensing and re-use, and data aspects of digital government and digital transformation strategies.

Data governance

  • There is a common data governance approach for all public sector data, determining how data are collected, managed, used and made available by public authorities.
  • A data-driven culture is created within government, which includes data literacy and recognises the importance of location data, location data infrastructures, and location-enabled data ecosystems.
  • Access to and reuse of privately held - location - data is covered under the data policy of government.

Stakeholder engagement

  • Location information stakeholders are involved in the development of broader data policy and those responsible for broader data policy engage with and take account of the interests of location information stakeholders.
  • The role of public-private partnerships and crowdsourced data is determined and applied consistently across all data policy (including location data policy).
  • Data policies and clear governance facilitate value creation for stakeholders in collaborative environments such as data ecosystems and digital platforms. 
  • There is a clear and agreed allocation of tasks and responsibilities between the different parties involved in general data policy and location information policy.

European alignment

  • Ensure that European data policies and location data policies, as well as the goals of the EU’s Digital Strategy, ‘A Europe Fit for the Digital Age’, are reflected in national policies. Take steps so that national location information makes a significant contribution to European data infrastructures and data ecosystems, including INSPIRE, Open Data, Earth Observation, European public sector location data products (e.g. EuroGeographics EuroRegional Map and EuroGlobal Map), and thematic data ecosystems, such as those in transport, weather and health.
  • The European Data Strategy adds further impetus to European collaboration on data, through the implementation of open high value datasets under the Open Data Directive and European data spaces. Location information from different Member States will play an important integration role within and across the European data spaces.
  • The table below outlines some of the main European data policies and their implications for national location information policies and data providers.
European data policy and implications for national location information policy
European data policy National location information policy implications
The Aarhus Convention and Environmental Information Directive

The Aarhus Convention, signed in 1998, guarantees public rights of access to information, public participation in decision-making, and access to justice on environmental matters.

Directive 2003/4/EC aims to ensure that environmental information is systematically available and distributed to the public. 

In 2020, the EC adopted a proposal amending Aarhus Regulation No. 1367/2006 to allow for better public scrutiny of EU acts affecting the environment

INSPIRE Directive (2007/EC)

National legislative transposition and implementation programme

National governance and organisation of data sharing

Standardised EU data infrastructure and access to a wide range of authoritative location data

Opportunity for reference data harmonisation across Europe

Harmonised location data for environmental policy

European INSPIRE Geoportal
Reuse of Public Sector Information (PSI) and Open Data

Reuse of public sector information for economic benefit, data accessibility, simplified licensing (Directive 2003/98/EC)

European open data portal

Amended by Directive 2019/1024 on open data and reuse of public sector information (“Open Data Directive”). Harmonising conditions for re-use and removing barriers to re-use. Provisions on non-discrimination, charging, exclusive arrangements, transparency and licensing, and tools to facilitate discovery and reuse. Entered into force 07/2021

Commitment to opening up access to high value government datasets for SMEs and innovation.
General Data Protection Regulation (2016/679)

Applicable from 05/2018

Increased trust, recognises location data privacy
Regulation on free flow of non-personal data (2018/1807)

Free movement of non-personal data across borders and sectors

Public authorities retain access to data for regulatory control purposes, even when it is located in another EU country or when it is stored or processed in the cloud.

Easier switching between cloud service providers and consistency on cybersecurity.
European Data Strategy (02/2020)

Use of location data in European data spaces – Integrating role within and across all data spaces, thematic role in many data spaces (e.g. Green Deal, Mobility)

Contribution to high value datasets (programme of implementation)

Support to SMEs in developing products and services

Integration of data from businesses and citizens

Participation in federated cloud infrastructure
Data Governance Act (11/2020) Fosters data reuse by increasing trust in data intermediaries and strengthening data-sharing mechanisms to ensure data interoperability across sectors (through technical and legal means and with organisational support). Applies to data made available voluntarily by public administrations, businesses, individuals and researchers.
Digital Markets Act (12/2020) Identifies data access and portability remedies for business and individual data held by online platforms (aimed at controlling the market power of major providers) 
Implementing Act on High Value Datasets under the Open Data Directive (Q3/2021) Specific rules on free access, machine readable formats, APIs and, where relevant, bulk downloads. There are six thematic categories: geospatial, earth observation and environment, meteorological, statistics, companies and mobility
Data Act (Q4/2021) Better access to and control over data for a fair data economy. Encouraging B2B and B2G data sharing. Addresses issues in terms of economic incentives to share data, trust, imbalances in negotiating power, fear of misappropriation of data, and lack of legal clarity, e.g. establishing fairness in use of co-generated, IoT data.
  • As well as contributing to European initiatives on data sharing, public administrations in Member States should also aim to draw on the benefits of such initiatives in their own national policies and actions.
  • European policy makers should also ensure their policies are aligned in terms of the data obligations for national administrations. The ‘European package’ of data related policies is growing significantly and clear communications, responsive consultations and effective plans are needed to ensure that national administrations are able to contribute positively.            



  • Lack of understanding of the specifics of location information by general data policy makers.
  • Data policy fails to take into account the cost of collecting and making available location data of sufficient quality.
  • Location policy continues to be seen as “special” and fails to align with wider data policy where it is feasible to do so.
  • The European policy agenda and particular actions impacting Member States may not align well with national priorities for action. European policies may be in contradiction with existing national legislation, e.g. on open high value datasets. Alternatively, national solutions may already be in place but in a different format. Or the timing of European initiatives may be too early and not such a priority in the national agenda.
  • European data policy is stepping more extensively into ‘implementation’ with requirements on open data and data spaces on top of the obligations under GDPR. This will be a challenge for national administrations who have already seen the efforts needed with INSPIRE. Where there are established national data programmes, their business cases may be diluted by the changes needed to support new European policies.
  • Finally, the European policy agenda may not appear to be well aligned or priorities may be unclear. The European Commission needs to address any potential contradictions or uncertainties as it progresses implementation of policies on multiple overlapping fronts.


Best Practices


Bar chart dark blue 32
LIFO Monitoring

The Location Information Framework Observatory (LIFO) monitors the implementation of EULF Blueprint recommendations in European countries. Read about the implementation of Recommendation 2 in the LIFO Country Factsheets or the LIFO European State of Play Report. Explore the results for selected countries at LIFO Interactive Dashboards - Recommendations.


Related Frameworks: European Interoperability Framework (EIF)

EIF Pillars Recommendations
Underlying Principle 2: Openness Recommendation 2: Publish the data you own as open data unless certain restrictions apply.
Underlying Principle 3: Transparency Recommendation 5: Ensure internal visibility and provide external interfaces for European public services.
Interoperability Layer 1: Interoperability Governance Recommendation 20: Ensure holistic governance of interoperability activities across administrative levels and sectors.
Basic Component 4: Open data Recommendation 43: Communicate clearly the right to access and reuse open data. The legal regimes for facilitating access and reuse, such as licences, should be standardised as much as possible.


Related Frameworks: UN-GGIM Integrated Geospatial Information Framework (IGIF)

Strategic Pathway 2: Policy and Legal

Documentation Elements

Implementation Guide



Norms, Policies and Guides

Data Protection, Licensing and Sharing

Governance and Accountability

Actions Tools
1. Providing Leadership  
Review Group APP2.1: Common Legal Terms
2. Assessing Needs  
Review and Assessment

APP2.2: Review and Assessment – Considerations

APP2.3: Review and Assessment – Questions
Gaps and Opportunities

APP2.4: Legal and Policy Framework Use Case

APP2.6: Gap Analysis Matrix
3. Addressing Opportunities  
Design and Develop

APP2.7: Policy and Legal Instruments - Advantages and Disadvantages

APP2.8: Assessing Fitness for Purpose for a Policy

Guidance and recommended actions aligned with Strategic Pathway 2: Policy and Legal

Data Sharing and Dissemination  
Licensing Geospatial Information Compendium on Licensing of Geospatial Information
4. Future Proofing  
Future Proofing  
5. Addressing Coherence  
Intellectual Property Rights APP2.9: Managing Intellectual Property Rights
Privacy and Data Protection  
Liability Concerns  
Sensitive Information App2.10: Addressing Sensitive Information
6. Delivering Compliance  
Impact Assessment  
Compliance Strategy  


Marker Small 2
ELISE Resources

Type Resource Date
Study Study of the terms of use applied in the INSPIRE resources and their usability barriers 2018
Webinar Location enabled public services 2020
Presentation INSPIRE Conference: Good practices for licences - overcoming usage barriers for INSPIRE data Presentation Video 2018
Presentation INSPIRE Conference: Adding Location Interoperability to Better Regulation’s Assessment of ICT Implications of New Legislation Presentation Video 2018
Training INSPIRE training platform: INSPIRE data and service sharing 2018


Further Reading


Version: EULF Blueprint v5.1