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Data Sharing AI (DSAI) - Proof of Value

Data governance in Ireland is overseen by the Data Governance Board under the Data Sharing and Governance Act 2019, enabling transparent data sharing across Public Sector Bodies. The OGCIO Data Governance Unit provides a Playbook to ensure secure, transparent sharing under the Act. This PoV shows how governed AI agents can support drafting DSAs at Stage 3 of the Playbook, with no autonomous decisions, full Human in the Loop oversight, and strong adherence to governance principles.

Initiative overview

The Data Sharing Artificial Intelligence (DSAI) Proof of Value explores how governed AI agents can responsibly support the drafting of Data Sharing Agreements (DSAs) under Ireland’s Data Sharing and Governance Act 2019 (DSGA). The Act sets out a transparent, legally defined process for sharing personal data between Public Service Bodies, requiring public consultation and publication of DSAs, with oversight by the Data Governance Board (DGB). While this framework strengthens trust and accountability, it also introduces significant administrative and coordination demands.

In 2022, the DSGA process was formalized through a nine‑stage DSA Playbook. Stage 3 of this playbook—drafting the DSA itself using a standardized legal template—is particularly challenging. Public bodies must ensure compliance with GDPR and DSGA requirements while coordinating multiple stakeholders and managing legal, technical and policy considerations. In practice, this stage often involves manual drafting, inconsistent ethical and compliance checks, version‑control issues, limited traceability between drafting bodies and OGCIO reviewers, and little structured guidance during document preparation.

The DSAI Proof of Value focuses specifically on simplifying Stage 3 by applying AI to support—and not replace—the drafting process. Governed AI agents assist with generating traceable draft sections, applying ethical prompts, and orchestrating workflows that guide users through complex requirements. Full human oversight is maintained throughout: Public Service Data Officers remain human‑in‑the‑loop, and the OGCIO remains human‑in‑command. The AI does not make autonomous decisions but instead produces legally grounded, auditable outputs that reviewers can validate and refine. This approach demonstrates how AI can safely replace a manual process while preserving transparency, accountability and institutional control.

Early results indicate reduced administrative burden and improved quality of draft DSAs, measured through staff time and resource‑use surveys. The AI‑assisted process supports the faster creation of plain‑English, legally accurate DSAs with consistent definitions, resulting in agreements suitable for public consultation and typically requiring fewer DGB recommendations. Beyond individual agreements, the initiative establishes a reusable AI governance pattern that can improve service delivery, enhance customer experience, strengthen compliance and risk management, ensure consistent application of OGCIO principles, and improve traceability for both drafting bodies and reviewers.

Other relevant details

Compliance and governance were central considerations from the outset. The Proof of Value was assessed using Ireland’s Responsible Use of AI Guidelines, which align with the EU AI Act, and the European Commission’s 2024 guidance confirmed that the initiative falls within the minimal‑to‑no‑risk category. Governance‑by‑design measures ensure that all AI interactions are transparent, explainable and auditable, with clear risk mitigations addressing data quality, ethical interpretation, scope control, over‑reliance on automation, security and transparency. Stakeholder responsibilities were mapped using a RACI model, providing clarity over roles and accountability. Key lessons highlight the importance of clear guidance, strong project management, defined governance structures, agreed success criteria, and effective training and knowledge transfer. Further insights are expected as users engage with the tool during user acceptance testing, informing refinement and potential wider rollout across government. The Proof of Value aligns with Ireland’s DSGA principles and broader EU direction on data sharing, which is a core priority of OGCIO’s mandate. It also adheres to the Responsible Use of AI Guidelines developed by DPER, applying the AI Canvas and embedding the seven principles of trustworthy AI. Designed as a scalable model, the approach could extend beyond Stage 3 to support other DSGA steps and, if successful, be adapted to related agreements such as accession agreements and Data Processing Agreements. Overall, the DSAI Proof of Value demonstrates how governed AI can be applied to a highly regulated public‑sector process, translating complex legal and ethical requirements into a practical, traceable and scalable workflow—while maintaining full human oversight and public trust.