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This chapter explores the data exchange relationships between stakeholders in a tourism domain as a means of assessing the potential application of open data initiatives. Social network analysis is utilized to analyze network relationships and explain the pattern and consequences of these relationships. Based on centrality and other network attributes, the analysis highlights the key influencers in the tourism data ecosystem examined, and suggests that initial steps towards implementing a tourism open data policy should focus on opening up tourism asset data, and relaxing current restrictive data exchange practices. The agency with responsibility for collecting and disseminating tourism asset data, is well positioned to become the data broker in an emergent tourism open data ecosystem.