There's a lengthy section on measuring website usage, with detailed proposals around the new requirement for website auditing, kicking in imminently with the aim of ensuring that 'the rules for measuring the number of Unique User/Browsers, Page Impressions, Visits and Visit Duration have been implemented correctly'. Government websites' data will be audited twice a year, at a minimum cost of £1,740 per audit.

So what's the alternative in the post-free world? How about a centrally managed, mandatory, open-source web analytics package - like Piwik?

• It would place the absolute minimum demand on individual departments: all they'd have to do is include a few lines of javascript at the bottom of their page templates - just like Google Analytics.
• It wouldn't stop departments running their own analytics packages, if they so desired. Not that many would want or need to.
• Implementation of appropriate standards - statistical, technical, privacy, transparency, etc - could be guaranteed by experts at the centre.
• Lower overall cost: in terms of purchase, ongoing licensing & support, and of course, auditing.
• Freedom to tailor it to particular government requirements, if any.

I must say at this point, I've got no direct experience of Piwik myself: but the demo looks great, and it's used by people I respect - such as Sourceforge and MySociety (eg TheyWorkForYou). Plus, as TWFY demonstrates, you can use Piwik alongside other tracking methods: they seem to have two others on the page too. It's still at version 0.something, but they're pledging to hit v1.0 'in 2009'. (Actually, can any of the MySociety gang share their experiences?)

Instead, where will the COI guidance leave us? Website owners will face a financial penalty (admittedly a relatively modest one) if they aren't using a 2-star rated ABCe Associate Subscriber. And how many of these 'recommended' analytics tools are open source, do you think?

Perhaps COI might want to take another look at the Open Source Strategy, (re)published just a month ago: for example, the part where Tom Watson says in his foreword:

We need to increase the pace. We want to ensure that we continue to use the best possible solutions for public services at the best value for money; and that we pay a fair price for what we have to buy. We want to share and re-use what the taxpayer has already purchased across the public sector – not just to avoid paying twice, but to reduce risks and to drive common, joined up solutions to the common needs of government. We want to encourage innovation and innovators - inside Government by encouraging open source thinking, and outside Government by helping to develop a vibrant market. We want to give leadership to the IT industry and to the wider economy to benefit from the information we generate and the software we develop in Government.

I'd be grateful if COI would consider this as Puffbox Ltd's contribution to the consultation exercise. Thank you.