"A prospectus for the Electronic Delivery of Government Services" - A response from the Centre for Computing and Social Responsibility Prof. Simon Rogerson Director srog@dmu.ac.uk ( The British Cabinet Office s Central IT Unit (CITU!" # $#!" %'&(%()*"%'&,+-/.0/ 1+ 23 254 06 3 + 2 3 2/4 7 3 + 2 3 2547 3 + 2 3254 7 + 23 */8 + 23 */8+ -.9%;: ) 2 5<=> 2 3? 32 5*@%A<CBD B? %;D D> B#D9%(=:-=-EC%F-E5G&H))I 5!@ Paper government.direct )) Green Introduction The Green Paper, government.direct addresses, in outline, how an integrated electronic information service might evolve to facilitate the UK s participation in the Information Society. In general, this is an initiative worthy of support. This response considers a number of issues that require addressing and suggests some modifications to various aspects of the proposal. 1
Paragraph 4.5 - How valuable would it be to have unified service delivery from different levels and types of Government body? The effective interaction between Government, and citizens and businesses is important. A unified approach which alleviates duplication, contradiction and ambiguity whilst protecting individual rights is a laudable concept. Government would become more aware of local opinion whilst individuals would become more aware of their rights and the activities and requirements of Government. This Green Paper appears to support these ideals and is therefore welcomed. Ongoing refinement of the implemented service will be necessary and must involve all those who are directly and indirectly affected by it. Paragraph 5.8 - Are the principles set out in paragraphs 5.2 to 5.8 the right principles on which to found the strategy? In general the set of principles lay the foundation for an effective and sensitive information service. A number of points are worthy of note regarding specific principles. The Choice principle should be upheld in practice explicitly. The stated electronic preference might, in practice, place pressure, through feelings of alienation and being treated in a second class manner, on those who prefer other means of access. In this situation choice is effectively removed. The Confidence principle is a key principle. The recognition of Data Protection legislation and enforcement as playing a central role is welcomed. The Accessibility principle is another key principle which must be translated into positive action that supports all citizens. The Rationalisation principle is drawn up in terms of minimum legal compliance. The Government, by taking a proactive stance, has an opportunity in this principle to encourage a move away from this minimalist position to one of social responsibility. It is suggested that this principle is amended to "... where this is legally permissible, morally permissible and socially acceptable." The Fraud principle addresses the issue of public funds protection. It demands compulsory identification of service users as a means of instigating protection. This 2
needs to be balanced with a citizen s right of anonymity in many situations. It is suggested that this principle is modified to acknowledge this. Overall the set of principles implicitly assumes a certain level of literacy, technology awareness and technology acceptance. This is not the case in practice. It is suggested that an extra principle of Education and Awareness is added that recognises this and demands that service providers include education and awareness programmes in service implementation. Paragraph 6.7 - What are the implications of delivering government services electronically direct to the public? Whilst it is recognised that there are many benefits to be gained from this initiative it is important to be aware of some potential problems. The vast investment in this new method of provision will starve more traditional forms and cause them to fall into disrepair. There is a technology aversion issue with certain sectors of the population which could have a damaging effect of the overall success of this initiative. The service will reduce social interaction and the impact of this, particularly on the more vulnerable groups, needs to be carefully analysed. Electronic provision will require individuals to use the information in a technology-dependent location. The opportunity to digest and reflect upon information, often requiring time, might be restricted. More traditional forms, such as booklets, support digestion and reflection more easily and more flexibly. There is a need to address this issue. Paragraph 6.7 - Where might public access terminals be most conveniently located? These should not simply be in centres of population primarily justified on economies of scale. A range of public buildings could be used such as theatres and cinemas, sports stadia, community centres, village schools and motorway services. In sparsely populated areas, use of, for example, mobile libraries, and community transport could offer access. 3
Paragraph 6.7 - How important are electronic "one stop shops", twenty four hour access and near instantaneous response? Service convenience will be vital in achieving critical mass in the user population. Any degradation of service in terms of access or response, particularly in its infancy, will have a detrimental effect on the long term viability and usefulness of the service. Paragraph 6.12 - What are the implications of service rationalisation? The rationalisation approach of shared data and databases might be contradictory with the sentiment of not merging personal or sensitive information expressed in paragraph 6.6. Rationalisation could result in the impact of a malfunction being very widespread and occurring quickly. This compares with only localised impact in an independent services situation. Paragraph 6.12 - What kinds of information would it be convenient to be able to tell government only once? Only generic information such as date of birth and address should be reported only once. 4
Paragraph 6.12 - What are the implications of sharing data between government departments? All transactions will use the same common data which will result in a common response. However, information of a qualitative nature collected for a specific purpose and subsequently shared might be misinterpreted resulting in an invalid and possibly detrimental response. Paragraph 6.12 - What benefits would follow from the wider use of e-mail for communication between government and the public? Without doubt the use of e-mail offers the opportunity for faster and better informed responses to enquiries. However, it is important to recognise the nature of e-mail as a communication media. E-mail is not secure although to the casual user it will appear so. E-mail is an electronic conversation rather than a formal or official communication. This informality of response can often be disregarded, misrepresented or simply misunderstood. Paragraph 6.16 - Are any difficulties caused by the present Crown Copyright arrangements and if so how might they be reduced or removed? The promotion of widespread dissemination of information that might further UK competitiveness as well as promoting a caring community should be supported through copyright arrangements that make, for example, regional demographic, economic and geographic information freely available. The move from current Crown Copyright 5
arrangements to, for example, copyright of information held by private third parties might result in excessive fees being required to access information and lead to some worthy potential recipients of such information unable to afford access. Paragraph 6.17 - What government information should be made available to the public electronically and in what form? The aim should be to make all publicly accessible information electronically available. The format is a vital issue. Current information tends to be textual and menu structured. More innovative presentation that is less reliant on text and structure would improve comprehension and widen access. Formats must cater for special citizens such as the visually impaired and those with motor disorders. The creation and maintenance of easily accessible frequently asked questions (FAQs) lists would be useful in responding dynamically to citizens enquiries. Paragraph 6.18 - How can the electronic provision of information best support the principles of the Citizen s Charter? Standards - Electronic provision extends the methods of publication of standards and actual performance. Information and Openness - Electronic provision offers the opportunity to hold and to make accessible more detailed information. Technological advances offer innovative ways of structuring this information. Choice and Consultation - There is an opportunity to establish interactive facilities which will enable more feedback from a greater number and range of citizens. Courtesy and Helpfulness - This principle relies heavily upon social interaction and electronic provision might compromise this principle. Putting Things Right - The impact is similar to that on Choice and Consultation. 6
Value for Money - The Green Paper predicts cost savings and efficiency gains which, if realised, are to be welcomed. Paragraph 6.27 - What are the implications of implementing the strategy in the way described? The use of private sector contractors whilst having many benefits, as mentioned in the Green Paper, might present tensions between commercial viability and the service provision to all citizens. The pilot schemes must involve a representative sample in terms of ethnicity, age, technology aversion, location and so on. This will then provide a clear picture of the size and nature of the application. Paragraph 8.11 - What are the implications of using electronic signatures in transactions with government? Paragraph 8.11 - What are the implications of electronic signature cards having additional functions (e.g. to carry electronic signatures recognised by private sector organisations, to carry medical or other personal data)? In many respects electronic signatures are identity cards in another guise. The Green Paper on identity cards provoked much criticism and demands for much more debate and 7
many more assurances regarding citizens rights. Due regard must be taken of this previous consultation process, (a response by CCSR). Paragraph 8.14 - How can the Government ensure suitable protection for individuals when using the new methods of service delivery? Current data protection legislation together with its forthcoming amendment in line with the European Directive provides the mechanism for protection for individuals particularly given the proactive stance adopted by the Information Commissioner. Public and specialist consultation would be most effective if co-ordinated through the Office of the Information Commissioner. Paragraph 8.19 - What technical measures are needed to ensure public confidence in the electronic handling of information? The major concern is security. Current public networks are insecure. Effective security measures need to be implemented to ensure the confidentiality of, for example, electronic income tax returns and benefit claims. Paragraph 8.21 - What are the implications of the concept of the "data donor"? There needs to be very strict control of data donors and dissemination of information by data donors. The rights of data subjects and the responsibilities of data users under the Data Protection Act might be compromised. Release of information by data donors 8
should be request-specific rather than some general authorisation on a need-to-know basis. 9