Tuesday, 11 October 2016

RIP IDA – local government, the lender of last resort

No need to say it, it goes without saying, it should be obvious to all but,
just in case it isn't obvious to all,
IDA is dead.

IDA, now known as "GOV.UK Verify (RIP)",
is the Cabinet Office Identity Assurance programme.


The Government Digital Service (GDS) have convinced 19 local authorities to conduct trials of GOV.UK Verify (RIP).

11 local authorities are going to try to use GOV.UK Verify (RIP) to issue concessionary travel passes. And 14 local authorities are going to try to use it to issue residents' parking permits.


The plan previously was to see if GOV.UK Verify (RIP) could help with issuing taxi licences as well. It was always a peculiar plan and now it's been dropped.

GDS are demanding that local authorities commit to the trials/pilot runs. Once they've started they have to finish – GDS lays down law on council Verify adoption criteria. It's expensive, conducting trials ...

... and local authorities only want to use GOV.UK Verify (RIP) if it saves them money. That plan hasn't been dropped. GDS still haven't provided a price list but they're going to have to soon.

What should we expect to see as these trials unfold?

Let's work our way through an example.

Which local authority to choose? We've done Warwickshire County Council before. This time, let's choose Brighton & Hove City Council (B&HCC).

Which application? Residents' parking permits or concessionary travel passes? Let's go with the former. There's a form to fill in. Which kicks off with:


Standardisation v. localisation
This is quite different from the form we fill in here in the London Borough of Merton, for example. The two forms are doing one job. Why have two forms? That looks like the sort of duplication GDS normally abhor.

Getting everyone to use the same tools to do the same job is precisely the rationale for Government as a Platform. Are GDS happy to see different parking permit application systems developed in each local authority? Hundreds of different forms? Hundreds of different on-line application systems?

It seems unlikely while they are at the same time telling central government departments that they should all use the same (non-existent) payments platform, GOV.UK Pay.

Two years ago the BBC were belabouring local government. They were said to be wasting money by failing to standardise. Bull Information Systems joined in with the criticism. So did Skyscape. And the Taxpayers' Alliance. And Policy Exchange. GDS threw in their contribution by claiming that most government IT applications are about as difficult as the requirements of a medium-sized dating website.

Not a single local authority among them, of course, these critics are all confident because they've never done the job. Most attempts to share services between local authorities seem to fail. But the ignorant faith in standardisation remains.

As the pilot projects to which both GDS and the local authorities are committed unfold, expect to see an element of this tension between standardisation and localisation.

Data protection
Right at the top of the form, before any other business, there's B&HCC quite properly reassuring its parishioners about the personal information they're about to enter on the residents' parking permit application form:
Brighton & Hove City Council is the Data Controller for the purposes of the Data Protection Act 1998. This means that Brighton & Hove City Council is responsible for making decisions about how your personal data will be processed and how it may be used. The purpose(s) for which your data will be processed is Parking Permits. The information you provide may be used in detecting possible fraud. The information you provide will be treated confidentially at all times. Security safeguards apply to both manual and computerised held data, and only relevant staff/named disclosures can access your information.

If you have any queries contact the Data Protection Officer Tel: 01273 291207
That is a set of statements B&HCC can't possibly make if GOV.UK Verify (RIP) is inserted into their residents' parking permit application system. B&HCC will have no control over what information is collected, the uses to which this information is put, who can see it or where it will be stored. You can ring 01273 291207 all you like ...

... you won't get anywhere. GOV.UK Verify (RIP) is the end of privacy. In Brighton, and Hove, and anywhere else it infects. As long as that is understood, these trials may proceed smoothly. If there's any objection to local authorities abdicating their responsibilities and throwing their parishioners to the wolves, then it's going to be a bumpy ride.

Exclusion
Let's take it for granted that B&HCC need to know who is applying for a parking permit:


GOV.UK Verify (RIP) doesn't collect titles. Further, when you come to register for a GOV.UK Verify (RIP) account with one of GDS's remaining "certified companies" which often aren't certified:
The certified company will also ask your gender. Anyone, for any reason, can opt out of identifying themselves in this way and choose an ‘I prefer not say’ option. You’re not required to provide an answer and - even if you choose to do so - the certified company won’t verify it.
But that's the least of B&HCC's problems if they rely on GOV.UK Verify (RIP) to identify applicants for parking permits.

The level of assurance offered by GOV.UK UK Verify (RIP) that the applicant is who they say they are is low. The US National Institute for Standards and Technology believe that GOV.UK Verify (RIP) achieves no proof of identity whatever, it's no more than a self-certification scheme.

And that's the case for people who manage to register. Lots of people can't even self-certify.

The verification success rate with GOV.UK Verify (RIP) hovered around the 70% mark for a while until GDS stopped publishing the figures. They had previously made 90% success a condition of going live. 70% is less than 90%. GOV.UK Verify (RIP) shouldn't have gone live in May 2016. It hadn't satisfied GDS's own conditions.

If B&HCC can only use GOV.UK Verify (RIP) to get about 70% of applicants to self-certify – and it may be less than that – how is it going to save them money? They're going to need to operate other systems in addition. That looks like costing more, not less.

B&HCC may have a greater commitment to data science than GDS. Oh to be a fly on the wall when the Council discusses the merits of spending more money to automate the worthless self-certification of parking permit-holders.

Re-engineering
The B&HCC form moves on to:


It's quite a mouthful. There's a lot there. Let's take a step back.

GDS's "dream" was outlined by their ex-deputy director, Tom Loosemore.

"Just sort it all out for me"
The idea is that when government is fully digitised there will be no need to apply for anything, including parking permits. The government will know what you need and will provide it. (Pre-parking. C.f. pre-crime.)

There should be no need for the applicant to specify the controlled parking zone they want a permit for (A, C, E, F, G, H, M, N, O, Q, R, T, U, W, Y or Z), that should be deducible from the address GOV.UK Verify (RIP) has already provided. B&HCC know the zones, they're B&HCC's zones for goodness sake, the applicant doesn't have to tell them.

Ditto, B&HCC can find out whether the application is for a low-emission vehicle as soon as they have the registration number. Certainly if it's a UK-registered car – DVLA, DVSA and the car insurance companies are already sharing this data. And even for foreign-registered cars – at least in our dreams. There's no need for the applicant to tell B&HCC.

Is the applicant a Blue Badge-holder? B&HCC probably already know the answer, they probably processed the Blue Badge application themselves, there's no need for the applicant to tell them.

GDS believe that transactions with government should be "friction-free". Asking the applicant to confirm information B&HCC already has is just friction. Out with it.

In GDS's dream CCTV camera records and other records will have alerted B&HCC to the existence of a car which is about to be transferred to one of their parishioners and if the council just interrogate enough databases/registers they can easily work out who is involved and offer them a parking permit before the applicant has even thought about it.

Taking into account their income from all sources, their savings and their financial commitments, an algorithm could calculate better than the applicant whether to opt for the 3, 6 or 12 month permit and even – to save inconvenience/friction – take the payment from the applicant's bank account.

There's no need to issue a material parking permit, of course. An entry on a database is quite enough by way of proof of the entitlement to park for B&HCC's digitised enforcement officers. At most, the applicant might be issued with a digital certificate to be stored on his or her mobile phone as a receipt for the payment made.

Too much to expect from B&HCC?

You may be right. Perhaps this work should be centralised in Whitehall. There's no need to duplicate these functions in each local authority.

That is the at once childish and sinister vision of GDS's Government as a Platform. A panopticon in which algorithms exercise your will for you based on what the pious Mr Loosemore calls a "single source of truth", i.e. hundreds of registers full of personal information about you.

It's quite beyond them to bring it about, of course. GDS couldn't even computerise farm payments. It's all just "internet jibba jabba", as Mr Loosemore was told, on his way out of GDS.

When B&HCC and GDS sit down to re-engineer or re-imagine or "imagineer" the new residents' parking permit application scheme, let's hope that someone remembers the benefits of friction.

-----  o  O  o  -----

GOV.UK Verify (RIP) is having trouble establishing itself with central government and with the public.

GDS approach local government now as supplicants. Local government is GOV.UK Verify (RIP)'s last hope.

No doubt local government is generally kindhearted but they are in no position to take on what everyone else has rejected. Why should they? What does GOV.UK Verify (RIP) have to offer them? What do GDS have to offer them?

GDS will tend to fight the "local" in "local government". GOV.UK Verify (RIP) will take the "protection" out of "data protection". It will exclude large chunks of B&HCC's population. And all for the sake of what? Some pie in the sky imagineering about Government as a Platform.

April 2016, Stephen Foreshew-Cain, writing in Where we’re at, and where we’re going:
Imagine being able to create a new service in hours, not months. Imagine being able to create two slightly different versions of a service, and see which one works best. And then, having done the research and iterated and improved the better one, simply killing off the one that didn’t make the cut ... Imagine being able to do that at negligible cost ...
Mr Foreshew-Cain took over as executive director of GDS when Mike Bracken left, at the same time as Tom Loosemore, in September 2015. Now he, too, is gone. As is Janet Hughes, GOV.UK Verify (RIP)'s sometime funeral programme director.

"Wildly unrealistic expectations". That's the verdict on GOV.UK Verify (RIP) ...

... the verdict of its supporters.

Too much imagining. That's where GDS are at. It's hard to believe that that's where local government is going.

----------

Updated 4.3.17

It's been a few months since the Government Digital Service (GDS) started its GOV.UK Verify (RIP) trials with local government. How's it going?

Answer, please see Local authority use of GOV.UK Verify – Discovery case for transforming local public services using GOV.UK Verify, published by the Local Digital Coalition (LDC).

The LDC say: "This document is the first iteration of the case for local authorities to transform their digital services through the use of GOV.UK Verify [RIP] and other common components". It's a piece of sales literature. What's the pitch?

GOV.UK Verify (RIP) provides "strong online identity assurance", apparently. Local government will be able to create "secure, safe, fast and convenient" digital services thanks to GOV.UK Verify (RIP) and other GDS gifts. Their costs (i.e. staff) will be reduced and they will save billions. Privacy will be protected and trust will be ensured.

A traditional sales line, everyone's seen it before, and some people may even still believe it.



The LDC add weight to their claims by citing supporting documents:
  • A combination of GDS gifts "lowers the barriers to ‘moving between suppliers’ and allows to switch from underperforming contracts4", for example, refers the reader to another document produced by the LDC.
  • And something else the LDC recommend "can achieve reductions of up to 5% of savings in local authorities expenditure5" is supported by reference to a CIPFA document. (Savings will be reduced by 5%?)
This is laudable practice, to provide independent support for your argument, but it makes it stand out like a sore thumb when you fail to.

The LDC give four examples (p.6) of how savings have been achieved by using GDS products, services and standards. Three of them have supporting citations ...

... and this one doesn't: "£111.44 million National Audit Office (NAO) approved savings through GOV.UK Verify [RIP]". No evidence of any such NAO approval has been found yet. This may explain the lack of a citation.


Updated 13.4.17

As noted above last October, 11 local authorities were going to try to use GOV.UK Verify (RIP) to issue concessionary travel passes. And 14 local authorities were going to try to use it to issue residents' parking permits:

Residents’ Parking Permits Concessionary Travel Pilot
Brighton and Hove City Council Brighton and Hove City Council
Buckinghamshire Councty Council Buckinghamshire Councty Council
Southampton City Council Southampton City Council
Northumberland County Council Northumberland County Council
Camden Camden
Hillingdon London Hillingdon London
Chelmsford City Council Luton
Barnet London Borough Central Bedfordshire
Oxfordshire County Council Essex County Council
Canterbury City Council Hertfordshire
Tunbridge Wells Borough Council Warwickshire Councty Council
Wigan Council
Newcastle City Council
Sunderland City Council

Next month the Local Digital Coalition (LDC) are going to lay on a showcase to "share the products we've delivered during the alpha phase of #VerifyLocal work - from prototypes to user research, and technical patterns to business case findings".

Will all 19 local authorities be there?

No.

It can be inferred from the LDC website that many local authorities have pulled out of these pilot schemes:

Residents’ Parking Permits Concessionary Travel Pilot
Brighton and Hove City Council Brighton and Hove City Council
Buckinghamshire County Council Buckinghamshire County Council
Southampton City Council Southampton City Council
Northumberland County Council Northumberland County Council
Camden Camden
Hillingdon London Hillingdon London
Chelmsford City Council Luton
Barnet London Borough Central Bedfordshire
Oxfordshire County Council Essex County Council
Canterbury City Council Hertfordshire
Tunbridge Wells Borough Council Warwickshire County Council
Wigan Council
Newcastle City Council
Sunderland City Council
Cambridgeshire County Council (new entrant)

Eight of the original 14 local authorities (57%) have pulled out of the residents' parking permits pilot scheme and six of the original 11 (55%) have pulled out of the concessionary travel scheme.

An unwary observer might believe that there are still 19 local authorities taking part in these GOV.UK Verify (RIP) pilots. Neither GDS nor the LDC have blogged to tell us that 10 of the original 19 local authorities (53%) are no longer involved.

That's a pretty hefty attrition rate that's going to be showcased.



Updated 28.4.17

There's no progress on the concessionary travel pilot that the Government Digital Service (GDS) is conducting with local authorities. Or, at least, with the five local authorities left, out of the 11 that started.

But there is progress on the residents' parking permits pilot, we learn today, please see Verify parking permit prototype to move to beta.

Eight of the original 14 local authorities have pulled out but for the survivors: "A key step has been reducing the level of assurance required for parking permit applications, reflecting the fact that permit applications are less sensitive than other services for which Verify could be used". I.e. GOV.UK Verify (RIP) is the wrong product to be using ...

... all a local authority really needs to know is that a car is registered at an address in their area. But, wait for it: "Plans for the [Driver and Vehicle Licensing Agency (DVLA)] to enable checking of the vehicle registration to a given address have not been included in the current prototype as the agency is going through a transformation programme".

The residents' parking permits pilot is using the product it shouldn't be using and it isn't using the product it should be using. Good luck to the guinea pig residents of Buckinghamshire, Northampton, Sunderland, Oxfordshire, Tunbridge Wells, Sunderland and Cambridgeshire with that.

"The Theatre of the Absurd attacks the comfortable certainties of religious or political orthodoxy. It aims to shock its audience out of complacency, to bring it face to face with the harsh facts of the human situation", as we used to say.

GDS's religious/political orthodoxy has been confronted with the harsh fact that they have promised to sign up 25 million people to the unwanted moribund GOV.UK Verify (RIP) in three years time. Shocked out of their usual ineffable complacency, their absurd response is to reduce the already low level of assurance offered by GOV.UK Verify (RIP) and to ignore the essential DVLA product that is needed to meet residents' parking permit needs.

Absurd. It makes for amusing theatre. But the digital transformation of government in the UK it ain't.

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