Citizen Development Standards
Citizen development standards define the rules, constraints, and obligations that apply to staff who build technology solutions using low-code platforms without formal software development training. These standards establish what citizen developers are permitted to build, how they must build it, and what ongoing responsibilities accompany solution ownership. IT staff use this reference to evaluate citizen-built solutions and enforce compliance; citizen developers use it to understand their boundaries and obligations before beginning work.
For the rationale behind these standards and the governance structures that support them, see Low-Code Platform Governance.
Citizen Developer Definition
A citizen developer is any staff member who creates automated workflows, applications, integrations, or data solutions using low-code or no-code platforms while holding a primary role outside IT or software development. Programme officers building KoboToolbox automations, finance staff creating Power Automate workflows, and fundraising coordinators maintaining Airtable bases all qualify as citizen developers regardless of their technical proficiency.
The classification depends on role, not skill. A staff member with computer science training who works as a programme manager and builds Power Apps solutions remains a citizen developer under these standards. The distinction matters because citizen developers operate under different governance requirements than IT development staff, with additional constraints on solution complexity, data handling, and integration scope.
Registration Requirements
All citizen developers must register with IT before creating solutions. Registration establishes accountability, enables IT oversight, and ensures solutions receive appropriate support classification.
| Requirement | Specification |
|---|---|
| Registration form | Submit via IT service desk, category “Citizen Development Registration” |
| Approval authority | IT manager or designated low-code platform administrator |
| Processing time | 5 working days maximum |
| Prerequisites | Completion of platform-specific training module (2-4 hours per platform) |
| Re-registration | Required when changing primary platform or department |
| Validity | 24 months, then renewal with refresher training |
Registration does not grant automatic approval for specific solutions. Each solution of moderate or higher complexity requires separate approval through the solution approval process detailed in the Solution Lifecycle section.
Permitted Platforms
Citizen development is restricted to platforms that IT has evaluated for security, data governance, and supportability. Using unapproved platforms for organisational data constitutes a policy violation regardless of the solution’s utility.
| Platform | Permitted Use | Data Classification Limit | Licensing |
|---|---|---|---|
| Microsoft Power Platform | Workflows, apps, dashboards | Internal, Confidential with approval | Included in Microsoft 365 E3/E5 |
| Airtable | Databases, workflows, interfaces | Internal only | Team tier or higher |
| Google AppSheet | Mobile apps, workflows | Internal only | Via Google Workspace |
| Notion | Databases, documentation | Internal only | Team tier or higher |
| KoboToolbox | Data collection forms | Up to Confidential | Free tier or licensed |
| Zapier | Workflow automation | Internal only | Team tier or higher |
| Make (Integromat) | Workflow automation | Internal only | Core tier or higher |
Platforms not listed above require formal evaluation through IT before use. Evaluation takes 15-30 working days depending on complexity. Staff may not use trial accounts on unevaluated platforms with organisational data.
Platform-Specific Constraints
Each permitted platform carries specific constraints beyond the general requirements in this document.
Microsoft Power Platform operates within the organisation’s tenant and inherits its security configuration. Citizen developers may not create custom connectors, use premium connectors without IT approval, or deploy solutions outside the default environment. Power Automate flows connecting to external services require security review when processing any personal data.
Airtable bases containing more than 10,000 records or connecting to external services via automations require IT registration as moderate-complexity solutions. Sync integrations with other platforms require explicit approval. Bases must use Airtable’s organisation workspace rather than personal workspaces.
KoboToolbox deployments for beneficiary data collection require data protection impact assessment completion before field deployment. Encryption at rest must remain enabled. Data exports must follow the data handling requirements specified in this document.
Zapier and Make automations that transfer data between cloud services require documentation of data flows and approval when any personal data is involved. Multi-step workflows exceeding 10 steps require IT review before activation.
Use Case Classification
Solutions fall into three complexity categories that determine approval requirements, documentation obligations, and review frequency. The classification depends on data sensitivity, integration scope, user count, and operational criticality.
Simple Solutions
Simple solutions automate personal or small-team tasks without processing personal data or connecting to systems of record.
| Criterion | Threshold |
|---|---|
| Users | Fewer than 10 |
| Data classification | Internal only, no personal data |
| External integrations | None |
| Systems of record | No read or write access |
| Business criticality | Failure causes inconvenience only |
| Approval | Self-service with registration |
| Review frequency | Annual self-attestation |
Examples include personal task automation, team scheduling tools, simple calculators, and document generation from templates that contain no personal data.
Moderate Solutions
Moderate solutions serve broader user groups, process limited personal data, or integrate with approved external services.
| Criterion | Threshold |
|---|---|
| Users | 10-100 |
| Data classification | Internal, limited personal data (staff only) |
| External integrations | Up to 3 pre-approved services |
| Systems of record | Read-only access permitted |
| Business criticality | Failure disrupts team operations |
| Approval | IT review required (10 working days) |
| Review frequency | 6-monthly |
Examples include departmental request tracking, team dashboards pulling from approved data sources, expense pre-approval workflows, and leave request automation.
Complex Solutions
Complex solutions approach the threshold where professional development becomes appropriate. These solutions require substantial IT involvement and may warrant transition to IT-managed development.
| Criterion | Threshold |
|---|---|
| Users | Over 100 |
| Data classification | Confidential, beneficiary data, sensitive personal data |
| External integrations | More than 3, or any non-pre-approved service |
| Systems of record | Write access |
| Business criticality | Failure disrupts organisational operations |
| Approval | IT architecture review required (20 working days) |
| Review frequency | Quarterly |
Complex solutions require a named IT contact who shares accountability for security and data handling. If a proposed solution exceeds complex thresholds, IT will recommend professional development rather than citizen development.
Prohibited Patterns
Certain solution types and integration patterns fall outside citizen development scope regardless of the developer’s capability.
Prohibited Solution Types
The following solution categories require professional IT development:
- Solutions processing payment card data or bank account details
- Authentication or identity management systems
- Solutions storing credentials, API keys, or secrets outside platform-provided secure storage
- Public-facing applications or portals accessible without organisational authentication
- Solutions processing special category data under GDPR (health, biometric, political, religious, trade union, sexual orientation, criminal records) without explicit IT approval
- Mobile applications distributed outside enterprise app stores
- Solutions intended to replace or significantly extend systems of record
Prohibited Integration Patterns
Citizen developers may not implement the following integration patterns:
- Direct database connections to production systems
- Screen scraping or robotic process automation against systems without API access
- Integrations using service accounts with administrative privileges
- Webhook endpoints receiving data from external systems without validation
- Bidirectional sync between systems of record
- Integrations that bypass audit logging
For integration patterns that are permitted, see API Integration Patterns.
Prohibited Data Handling
Data handling restrictions apply regardless of solution complexity:
- Downloading beneficiary data to personal devices
- Storing personal data in platform features lacking appropriate access controls
- Transferring data to platforms not approved for that data classification
- Disabling or circumventing platform audit logging
- Sharing access credentials rather than using platform permission features
- Exporting data to file formats that cannot be encrypted (plain CSV for confidential data)
Naming Conventions
Consistent naming enables IT oversight, simplifies support, and clarifies ownership. All citizen-built solutions must follow the naming convention for their platform.
Standard Naming Format
[Dept]-[Type]-[Function]-[Version]| Component | Values | Example |
|---|---|---|
| Dept | 3-letter department code | FIN, PRG, FND, OPS, HRS |
| Type | APP (application), WFL (workflow), DSH (dashboard), INT (integration), FRM (form) | WFL |
| Function | Descriptive name, 2-4 words, no spaces | ExpensePreApproval |
| Version | v1, v2, etc. (increment for major changes) | v1 |
Complete examples:
FIN-WFL-ExpensePreApproval-v1(Finance workflow for expense pre-approval)PRG-FRM-BeneficiaryIntake-v2(Programme form for beneficiary intake, second version)FND-DSH-DonorPipeline-v1(Fundraising dashboard for donor pipeline)HRS-APP-LeaveRequest-v3(HR application for leave requests)
Platform-Specific Naming
Some platforms impose character limits or format restrictions:
| Platform | Limit | Adaptation |
|---|---|---|
| Power Automate | 256 characters | Full format applies |
| Power Apps | 50 characters | Abbreviate function name |
| Airtable | 50 characters | Abbreviate function name |
| Zapier | 64 characters | Full format applies |
| KoboToolbox | 30 characters | Use [Dept]-[Function]-v[n] only |
Deviations from naming conventions require IT approval and documentation explaining the constraint.
Data Handling Requirements
Citizen developers assume data controller responsibilities within their solutions. These requirements ensure solutions meet organisational data protection obligations.
Data Classification Compliance
Every solution must document its data classification and handle data according to classification requirements. The classification derives from the most sensitive data element the solution processes, not the average sensitivity.
| Classification | Citizen Development Permitted | Additional Requirements |
|---|---|---|
| Public | Yes | None |
| Internal | Yes | Platform access controls required |
| Confidential | With IT approval | Encryption, access logging, quarterly review |
| Restricted | No | Professional development required |
Data classification definitions and handling requirements appear in Data Classification.
Personal Data Processing
Solutions processing personal data must document:
- Legal basis for processing (consent, contract, legitimate interest, legal obligation)
- Data subjects affected (staff, beneficiaries, donors, partners)
- Personal data elements collected or processed
- Retention period and deletion mechanism
- Access control implementation
Solutions processing beneficiary personal data require a Data Protection Impact Assessment (DPIA) before deployment. The DPIA process is documented in Privacy by Design.
Data Retention
Citizen-built solutions must not retain data beyond defined retention periods. Platform features for automatic deletion must be configured where available. Where automatic deletion is unavailable, the solution owner must perform manual deletion according to the retention schedule.
| Data Type | Maximum Retention | Deletion Mechanism |
|---|---|---|
| Transactional workflow data | 90 days after completion | Automatic where supported |
| Staff personal data | Duration of employment plus 7 years | Manual review required |
| Beneficiary data | Per programme data retention schedule | Coordinated with programme closure |
| Aggregated operational data | 3 years | Annual archive or deletion |
Data Export and Backup
Solutions classified as moderate or complex must support data export in a format that enables migration to alternative platforms. This requirement ensures organisational data remains accessible if the platform becomes unavailable or the citizen developer leaves.
Export capability must be tested during initial deployment and verified during each review cycle. Exports must use formats appropriate to data classification (encrypted archives for confidential data).
Security Requirements
Security requirements scale with solution complexity and data sensitivity. All citizen-built solutions must meet baseline security requirements; additional requirements apply to moderate and complex solutions.
Baseline Security (All Solutions)
Every citizen-built solution must implement:
- Platform-native authentication only (no custom authentication)
- Access restricted to users who require it
- Default-deny permission model (users have no access until explicitly granted)
- Audit logging enabled (where platform supports)
- Solution accessible only via organisational accounts (no personal account access)
Additional Security for Moderate Solutions
Solutions classified as moderate must also implement:
- Role-based access control with documented role definitions
- Activity logging sufficient to investigate misuse
- Automated session timeout (maximum 8 hours)
- No storage of credentials in workflow steps (use platform credential stores)
Additional Security for Complex Solutions
Solutions classified as complex must also implement:
- Annual access review with documented recertification
- Data encryption at rest (platform-provided)
- Incident response contact identified and documented
- Penetration testing or security review before deployment (IT-coordinated)
Secrets and Credentials
Citizen developers must never embed credentials, API keys, tokens, or passwords directly in solution configurations. All platforms provide secure credential storage; these features must be used exclusively.
| Platform | Credential Storage Feature |
|---|---|
| Power Platform | Connection references, Azure Key Vault (complex solutions) |
| Airtable | Personal access tokens via account settings |
| Zapier | Connected accounts |
| Make | Connections |
| KoboToolbox | REST service configuration |
When integrating with services not supported by platform connectors, request IT assistance rather than using embedded credentials.
Documentation Requirements
Documentation ensures solutions remain maintainable when developers change roles or leave the organisation. Requirements scale with solution complexity.
Simple Solution Documentation
Simple solutions require a solution registration record only:
| Field | Content |
|---|---|
| Solution name | Following naming convention |
| Owner | Name and role of citizen developer |
| Platform | Platform used |
| Purpose | One paragraph describing what the solution does |
| Users | Who has access |
| Data elements | List of data fields processed |
| Created date | Date of initial deployment |
Moderate Solution Documentation
Moderate solutions require a solution specification document (2-4 pages) containing:
| Section | Content |
|---|---|
| Overview | Purpose, users, business value |
| Data flow | Diagram showing data inputs, processing, outputs |
| Integration points | Connected systems and data exchanged |
| Access control | Roles, permissions, approval process for access |
| Support | Who to contact for issues, escalation path |
| Backup and recovery | How to export data, how to restore if corrupted |
| Change log | Record of modifications with dates |
Complex Solution Documentation
Complex solutions require moderate documentation plus:
| Section | Content |
|---|---|
| Architecture diagram | Visual representation of components and connections |
| Risk assessment | Identified risks and mitigations |
| IT contact | Named IT staff member sharing accountability |
| Incident response | Steps for handling security or data incidents |
| Disaster recovery | Recovery procedure if solution becomes unavailable |
| Exit plan | How to migrate away from this solution |
Documentation must be stored in a location accessible to IT and the solution owner’s manager. Recommended locations include SharePoint document libraries or internal wikis with appropriate access controls.
Solution Lifecycle
Citizen-built solutions progress through defined lifecycle stages with specific activities required at each stage.
Development and Approval
+---------------+ +---------------+ +---------------+| | | | | || Register +---->+ Develop +---->+ Submit for || as Citizen | | Solution | | Approval || Developer | | (sandbox) | | |+---------------+ +---------------+ +-------+-------+ | +-------------------------------------------+ | v+-------+-------+ +---------------+ +---------------+| | | | | || IT Review +---->+ Implement +---->+ Production || (if req'd) | | Feedback | | Deployment || | | | | |+---------------+ +---------------+ +---------------+Figure 1: Solution development and approval flow
Sandbox development is mandatory. All platforms provide sandbox or development environments where solutions must be built and tested before production deployment. Deploying untested solutions directly to production violates these standards.
Approval routing depends on classification:
- Simple: Self-service deployment after registration verification
- Moderate: IT review via service desk ticket (10 working days)
- Complex: IT architecture review via formal request (20 working days)
Ongoing Maintenance
Production solutions require ongoing maintenance regardless of stability:
| Activity | Simple | Moderate | Complex |
|---|---|---|---|
| Access review | Annual | 6-monthly | Quarterly |
| Security check | Annual attestation | 6-monthly IT review | Quarterly IT review |
| Functionality test | On platform updates | Monthly | Weekly |
| Documentation update | On change | On change, minimum annual | On change, minimum quarterly |
| Backup verification | Annual | Quarterly | Monthly |
Review and Audit
IT conducts periodic reviews of citizen-built solutions to verify compliance with these standards.
| Review Type | Frequency | Scope | Output |
|---|---|---|---|
| Compliance spot-check | Quarterly | Random sample of 10% of solutions | Pass/fail with remediation requirements |
| Classification review | Annual | All solutions | Updated classification, retired solutions removed |
| Security audit | Annual | All moderate and complex solutions | Security findings requiring remediation |
| Platform audit | On platform change | All solutions on affected platform | Impact assessment, migration plan if needed |
Solutions failing compliance review receive a remediation deadline based on severity:
| Severity | Remediation Deadline | Consequence of Non-Compliance |
|---|---|---|
| Critical (security risk) | 7 days | Immediate suspension of solution |
| High (policy violation) | 14 days | Solution suspended until remediation |
| Medium (documentation gap) | 30 days | Flagged in next review |
| Low (naming convention) | 60 days | Flagged in next review |
Handover Requirements
When a citizen developer leaves the organisation, changes role, or can no longer maintain a solution, handover must occur within 20 working days of the triggering event.
Handover package contents:
| Component | Description |
|---|---|
| Documentation | Current version of all required documentation |
| Access credentials | Transfer of ownership in platform (not sharing passwords) |
| Pending changes | List of planned modifications or known issues |
| Dependencies | External services, scheduled processes, monitoring |
| Knowledge transfer | Walkthrough session with receiving party (recorded if possible) |
| Stakeholder notification | Inform solution users of ownership change |
The departing developer’s manager is responsible for ensuring handover completion. If no suitable recipient exists within the team, IT assumes temporary ownership and evaluates whether the solution should continue.
Retirement
Solutions no longer needed must be formally retired rather than abandoned. Retirement ensures data is handled appropriately and platform resources are released.
Retirement process:
- Solution owner submits retirement request via IT service desk
- IT verifies no active dependencies
- Data exported and archived per retention requirements
- User access removed
- Solution disabled (not deleted) for 90-day recovery window
- Solution permanently deleted after recovery window
- Documentation archived
Solutions that have had no activity for 12 months trigger automatic retirement review. Owners must confirm continued need or initiate retirement.
Escalation to Professional Development
Some solutions exceed the appropriate scope for citizen development even when technically feasible on low-code platforms. Escalation to professional development protects the organisation and the citizen developer from unsupportable solutions.
Escalation Triggers
Any of the following triggers escalation to IT for professional development assessment:
- Solution exceeds complex classification thresholds
- Solution requires prohibited patterns or integrations
- Solution replaces or significantly modifies a system of record
- Three or more significant incidents within 6 months
- Maintenance burden exceeds 8 hours per month
- Solution owner unable to explain how the solution works
- External audit or compliance requirement mandates professional oversight
- Integration with systems not supporting low-code connectors
Escalation Process
+---------------+ +---------------+ +---------------+| | | | | || Trigger +---->+ IT +---->+ Assessment || Identified | | Notified | | Meeting || | | | | |+---------------+ +---------------+ +-------+-------+ | +-----------------------------+ | +-------------+-------------+ | | v v+-------+-------+ +-------+-------+| | | || Remediate | | Transition || as Citizen | | to IT || Solution | | Development || | | |+---------------+ +---------------+Figure 2: Escalation decision flow
Assessment meeting includes the citizen developer, their manager, and IT representative. The meeting evaluates whether remediation within citizen development scope is feasible or whether transition to professional development is required.
Transition to IT development follows the organisation’s standard project intake process. The citizen developer typically remains involved as subject matter expert but no longer holds development responsibility. Existing solution continues operating under IT oversight during transition.
Compliance Verification Checklist
Citizen developers should verify compliance before requesting solution approval. IT uses this checklist during reviews.
| Category | Requirement | Verification |
|---|---|---|
| Registration | Developer registered and current | Registration date within 24 months |
| Training | Platform training completed | Certificate or completion record on file |
| Platform | Using approved platform | Platform on permitted list |
| Naming | Follows naming convention | Name matches [Dept]-[Type]-[Function]-[Version] |
| Classification | Correctly classified | Thresholds reviewed against solution characteristics |
| Data handling | Classification documented | Data classification stated in documentation |
| Data handling | Retention configured | Automatic deletion enabled or manual process documented |
| Data handling | Export capability | Export tested and documented |
| Security | Authentication native | No custom authentication implemented |
| Security | Access controlled | Permission model documented and implemented |
| Security | Credentials secured | No embedded credentials in configuration |
| Documentation | Level-appropriate docs | Required documentation complete for classification |
| Support | Owner identified | Named owner with current contact information |
| Support | Handover plan | Successor identified or escalation path documented |