Friday 21 September 2012

The Government Digital Service, no time to fit in Universal Credit, too busy

They're a ruthless lot, GDS.
They have to prioritise.
Millions of people could be given the opportunity to make work pay?
Too bad.
GDS have a website to write.

----------  o  O  o  ----------

At last the technical IT problems with Universal Credit (UC) are beginning to be reported in the national press, please see selected examples below.

UC is important. "Make work pay" means rescuing people from the poverty trap, where dependency rots their souls, as Frank Field puts it. And tragically, as Mr Field also puts it, "UC is on course for disaster".

There are political problems with UC. That is a matter for Parliament, and Parliament is debating it – the House of Commons Work and Pensions Committee is considering 500 pages of evidence from 70 organisations.

Suppose that Westminster resolves the political problems. Then what?

Then UC will still fail because of the IT problems introduced by Whitehall.

Digital by default
Whitehall has decided that all public services, including UC, should be "digital by default". That is, public services should be delivered over the web, and only over the web, please see newspaper articles quoted below. But something like ten million people in the UK have still never used the web. They will be "excluded by default".

Assisted digital
Whitehall has invented a phrase to plug the gap between the unwebbed and UC – "assisted digital". There will be an assisted digital programme, they say, to help their web novice parishioners to register with UC and to claim. There is no such programme, there is nothing more than the phrase and Whitehall's actual response, as opposed to their promised response, is simply not to answer the telephone, please see newspaper articles quoted below. That, Whitehall believes, will force people to use the web.

Identity assurance
Once forced onto the web, how do claimants prove that they are who they say they are? If they can't, either we risk denying benefits to people who are entitled to them or we risk automating benefit fraud. That invidious choice is currently avoided on the web by using the UK Government Gateway, which requires user IDs and passwords.

Whitehall believes that the Government Gateway is old-fashioned and too difficult for most people to use, and has promised to replace it with a new "identity assurance" service. Another phrase, another promise, another failure, please see newspaper articles quoted below, no use to UC, there is no new identity assurance service.

Cybersecurity
In their more lucid moments, Whitehall departments warn individuals, businesses and each other that the web is a dangerous place to be. Identity theft, industrial espionage, viruses, man-in-the-middle attacks, hacking, distributed-denial-of-service, you name it, it's a cyberthreat.

GCHQ has established an academic institute for cyberdefence. GCHQ appear to understand the problem. And yet simultaneously, schizophrenically, Whitehall has decided to put all public services including UC on the web, please see newspaper articles quoted below.

Cloud computing
"Cloud computing" is the solution, whatever the problem, according to Whitehall. Whitehall wants a G-Cloud – a government cloud – and they want to put all our data in the cloud where, they claim, it will be secure, it will be maintained in real time, always up to date and always accurate, cloud computing is flexible and cheap and efficient and trusted and always available (resilient, no down time, always safely backed up) and green and modern and fit for the 21st century.

Cockpoppy.

Not in this 21st century. Not on this planet.

Whitehall's G-Cloud team hosted a lively debate about the problems of cloud computing, pulled all the questions together and tried to crowd source some answers. They can't have liked the answers submitted and published only one – the limiting case of a crowd. The problems remain, unresolved, even the founder of Google is warning Whitehall against cloud computing, and yet G-Cloud proceeds, ensuring maximum risks to UC.

Agile
It is a sad fact that IT projects tend to come in late and over budget. Staggeringly late and eye-wateringly over budget. UC is meant to be different. UC is using "agile" systems development methods and "agile" means that systems are flexible, delivered on time and within the budget.

"Agile" is just another word. Computer Weekly magazine reported in June on an emergency project of the US military's:
... the effort is part of an emergency reform of IT projects using agile methods, on orders issued by the Department [of] Defense last year after 11 major computer systems went $6bn over budget and 31 years behind schedule.
Transformational government
UC is the victim of "transformational government", the overall Whitehall plan which incorporates "digital by default" and "assisted digital" and "identity assurance" and "cloud computing" and "agile". Iain Duncan Smith, the Secretary of State for Work and Pensions, looks utterly sincere in his desire to make work pay but he has failed. His officials have prevailed and undermined UC.

Steve Dover, for example, the director of major programmes at DWP and clearly a card-carrying member of the Transformational Government cult, worshiping computers and full of contempt for human beings, is quoted in the Guardian on the subject of UC as saying:
The starting point, I said to our telephony collaboration teams based in Newcastle, was just think of a contact centre, but it has got no people in it and think of an operating model that has got no back office, and start from there.
Francis Maude, the Cabinet Office Minister, is in charge of both cybersecurity (don't use the web) and the Government Digital Service (GDS, only use the web). How does he reconcile the two? On 31 October 2011, he announced that he was funding the nascent identity assurance industry with £10 million taken from ... the £650 million cybersecurity budget.

When it comes to IT, our politicians are apparently helpless in the hands of their officials.

Officials like Steve Dover, and ex-Guardian man Mike Bracken, the executive director of government digital services and Senior Responsible Officer Owner of the identity assurance programme. Bracken trundled Francis Maude off to Estonia to see what transformational government looks like in action. Before that, Mr Maude was made to go to California to listen to Google talking about the identity ecosystem. Later, there was a trip to Washington for Bracken's Government Digital Service (GDS) team.

Estonia, of course, precisely because the country's government has been transformed and relies entirely on cloud computing, was brought to its knees by the Russians in a matter of days in 2007. Why does ex-Guardian man Mike Bracken wish to expose the UK in general and UC in particular to the same vulnerability?

The trip to California included a talk given by Google on identity management. If the suggestion is that perhaps Google could provide the identity assurance that UC and other public services require, it should be understood what that implies. Application for benefits and the administration of their payment would become dependent on Google, whose name could conceivably one day replace Her Britannic Majesty's in our passports. As custodians of our identity, the company would tend to become part of the Constitution. Is Constitutional change in the remit of ex-Guardian man Mike Bracken?

The Washington boondoggle included a photo opportunity in the White House library, enough to turn anyone's head, and was the occasion for groupthink with GDS's transformational government opposite numbers working on NSTIC, the US National Strategy for Trusted Identities in Cyberspace. The fact that the US administration is pursuing the same mistaken strategy as the UK's does not alter the fact that it is mistaken.

GOV.UK
GDS's serious responsibilities are set out on its website under the following headings – assisted digital, digital engagement, directgov, ID assurance, innovation and single government domain. They concentrate on the single government domain task, producing GOV.UK, a re-write of all the departmental government websites that already exist.

No time to waste on UC
When GDS aren't visiting Estonia or the US, they're re-writing websites. They're not promoting digital engagement, they're not providing assisted digital services and DWP don't have the new identity assurance system that they need and that they were promised.

They're a ruthless lot, GDS. They have to prioritise. Millions of people could be given the opportunity to make work pay? Too bad. GDS have a website to write.



A selection of recent newspaper reports on the state of UC:

Last Saturday's Guardian, 15 September 2012, Welfare bill won't work, key advisers tell Iain Duncan Smith:
Seventy organisations wrote to the Commons work and pensions select committee last week, raising a host of potential objections to the universal credit, including doubts about the ability of the government to successfully deliver the IT necessary to unify benefit payments or use real-time wage information to ensure that work always pays better than welfare.

Those working with the vulnerable said the insistence that the system be wholly internet-based will leave many unable to access benefits, and claim the government does not have a plan B.
Next day's ObserverUnemployed deliberately held in call centre queues to promote website:
Jobseekers are being kept hanging on the telephone for at least five minutes before they are connected to a member of staff in jobcentres – a deliberate move to encourage people to make online claims, internal documents obtained by the Guardian reveal ...

Charities said that vulnerable people often do not have internet access ...

Underlining the new policy is the government's target that 80% of new claims for unemployment benefit should be made online by September 2013 ...

The problem for the welfare secretary, Iain Duncan Smith, is that the online flagship universal credit policy will only work if claimants not only claim jobseeker's allowance and other benefits online but also manage their benefits and job searches online ...

The Department for Work and Pensions emphasised that the government tried to ensure that poor people could access jobcentre call centres ...
Monday's Telegraph, Cyber attacks threaten welfare reforms, ministers warn:
Cyber-attacks by criminal gangs and hostile states are the biggest threat to the Coalition’s welfare reforms, ministers have said.

Iain Duncan Smith, the Work and Pensions Secretary, said he had sought advice from major internet retailers such as Amazon about how to keep his Universal Credit systems running, despite electronic sabotage and fraud.

Universal Credit is due to replace scores of individual benefits from next year, simplifying claims and allowing claimants to keep more of their benefits when they take paid work. The regime will be internet-based, with ministers intending that most claimants apply and report a change in circumstances online.

Appearing before a Commons inquiry into the reform, Lord Freud, the welfare reform minister, was asked what was the biggest risk to the programme. “I’ll say what the challenges are, what we need to get right: to get the security system working properly,” he said.

Private security companies will be commissioned to develop a system of “identity assurance” to check that only real claimants can get benefits. “That’s one of the biggest challenges,” said Lord Freud.

Mr Duncan Smith said: “There are states that wish to attack things, criminals that want to commit fraud.”

Unlike retailers, he said, the new system would have to keep running regardless of disruption: temporary interruptions of service would harm claimants. “We must always be ready for the moment we need to pay people the money,” he said.

The Government Digital Service, no time to fit in Universal Credit, too busy

They're a ruthless lot, GDS.
They have to prioritise.
Millions of people could be given the opportunity to make work pay?
Too bad.
GDS have a website to write.

----------  o  O  o  ----------

At last the technical IT problems with Universal Credit (UC) are beginning to be reported in the national press, please see selected examples below.

UC is important. "Make work pay" means rescuing people from the poverty trap, where dependency rots their souls, as Frank Field puts it. And tragically, as Mr Field also puts it, "UC is on course for disaster".

There are political problems with UC. That is a matter for Parliament, and Parliament is debating it – the House of Commons Work and Pensions Committee is considering 500 pages of evidence from 70 organisations.

Suppose that Westminster resolves the political problems. Then what?

Then UC will still fail because of the IT problems introduced by Whitehall.

Tuesday 18 September 2012

Universal Credit, ex-Guardian man Mike Bracken and Sir Jeremy Heywood

At last the technical problems with Universal Credit (UC) are beginning to be reported in the national press:
Universal Credit is due to replace scores of individual benefits from next year, simplifying claims and allowing claimants to keep more of their benefits when they take paid work. The regime will be internet-based, with ministers intending that most claimants apply and report a change in circumstances online.

Appearing before a Commons inquiry into the reform, Lord Freud, the welfare reform minister, was asked what was the biggest risk to the programme. “I’ll say what the challenges are, what we need to get right: to get the security system working properly,” he said.

Private security companies will be commissioned to develop a system of “identity assurance” to check that only real claimants can get benefits. “That’s one of the biggest challenges,” said Lord Freud.
Who's in charge of identity assurance? The Cabinet Office. More specifically, the Government Digital Service (GDS). Why is identity assurance one of Lord Freud's "biggest challenges"? Because there is no identity assurance available to UC or any other public service. Lots of talk. Lots of blogging. No identity assurance.

Ex-Guardian man Mike Bracken is the executive director of government digital services and Senior Responsible Officer Owner of the identity assurance programme. He flew Francis Maude, the Cabinet Office Minister, out to California to see the future:
Andrew Nash, Google’s Director of Identity, ran us through the current issues facing identity.He explained how Google aim to grow and be part of an ecosystem of identify providers, and encouraged the UK Government to play its part in a federated system. The UK ID Assurance team and Google agreed to work more closely to define our strategy – so look out for future announcements. Andrew also took the opportunity to walk the Minister through the Identity ecosystem.
He may have walked through the "Identity ecosystem" but ex-Guardian man Mike Bracken hasn't produced an identity assurance system that DWP can use for UC.

That job has been left to Vince Cable's Department for Business Innovation and Skills (BIS). The idea is to incubate a whole new market of trusted companies whose business it is to maintain Personal Data Stores (PDSs). We will each have a number of PDSs, according to BIS, and these will allow us to transact with government. PDSs will allow us to register for UC, for example, and for benefits to be paid computer-to-computer, with no messy human intervention adding "friction" to the system.

What companies? Who is going to maintain all these PDSs? BIS don't say. They don't say who and they don't say when. How long does it take to grow a mature identity assurance ecosystem from scratch? How long can UC wait?

UC faces any number of political problems. They may or may not be solved. Even if they are, UC will still be snookered by an unworkable IT system design. That design must have been agreed by Iain Duncan Smith's officials at DWP. They must have agreed to implement GDS's infantile science fiction ideas. And BIS must bravely have agreed to try to create a PDS industry overnight.

Obviously Iain Duncan Smith will get the blame for the failure of UC. And that failure will be a tragedy. The opportunity for people to escape the poverty trap will have been lost. If work can't be made to pay, says Frank Field, then the resulting state of dependency will rot people's souls.

But the failure is Whitehall's. N [please see comments below] And according to the Spectator, that failure is countenanced and even encouraged right from the top, by Sir Jeremy Heywood, Cabinet Secretary:
Sir Jeremy Heywood, the civil servant effectively running Britain, is letting it be known that he is ‘sceptical’ about Duncan Smith’s mission. This, in Whitehall, is the equivalent of a go-slow order. Civil servants will not waste time or personal capital on anything likely to join the identity cards and the NHS supercomputer in the graveyard of ministerial follies.

... [David Cameron] should throw his weight behind Duncan Smith rather than seeking to remove him. He ought to remind Sir Jeremy that, as head of the civil service, he is paid not to be ‘sceptical’ about government policy but to implement it. Welfare reform is the thorniest problem in government, which is why so many ministers have ignored it. It is far safer, politically, to leave the poor to rot.

Universal Credit, ex-Guardian man Mike Bracken and Sir Jeremy Heywood

At last the technical problems with Universal Credit (UC) are beginning to be reported in the national press:
Universal Credit is due to replace scores of individual benefits from next year, simplifying claims and allowing claimants to keep more of their benefits when they take paid work. The regime will be internet-based, with ministers intending that most claimants apply and report a change in circumstances online.

Appearing before a Commons inquiry into the reform, Lord Freud, the welfare reform minister, was asked what was the biggest risk to the programme. “I’ll say what the challenges are, what we need to get right: to get the security system working properly,” he said.

Private security companies will be commissioned to develop a system of “identity assurance” to check that only real claimants can get benefits. “That’s one of the biggest challenges,” said Lord Freud.
Who's in charge of identity assurance? The Cabinet Office. More specifically, the Government Digital Service (GDS). Why is identity assurance one of Lord Freud's "biggest challenges"? Because there is no identity assurance available to UC or any other public service. Lots of talk. Lots of blogging. No identity assurance.

Wednesday 12 September 2012

Universal credit, national apathy

Writing in Monday's Guardian, The universal credit programme is on course for disaster, Frank Field concludes that:
It was brave of IDS [Iain Duncan Smith, Secretary of State at the Department for Work & Pensions (DWP)] to insist on occupying the command on the bridge, but it was the prime minister's wish to avert a catastrophe that drove him to try to move his work and pensions secretary so that the government could quietly shut down the whole reform. His failure to act leaves the disaster on course.
Mr Field believes that means-testing systems like UC, universal credit, create dependency and rot the souls of their parishioners. As the acknowledged authority on welfare, called upon by both the coalition government and their predecessors, his opinion is worth considering.

The idea behind UC was to "sweep together the main means-tested benefits and tax credits into one 'universal' benefit", Mr Field says, but DWP have given up on that.

In the unlikely event that UC is deployed, it won't do what it was meant to do and it will rot people's souls. That's what Mr Field says, and he says that the Prime Minister believes it, too – UC is on course for disaster.

They are not alone, Messrs Field and Cameron.

Intellect, the trade body of the UK IT industry, investigated UC and reported to DWP that the timescales for the project are unlikely to be met and that the promise that no-one will be worse off under UC is unlikely to be deliverable.

So that's Mr Field, Mr Cameron and Intellect. And the Local Government Association (LGA), who describe DWP's insistence on using so-called "agile" systems development methods for UC and on UC being online only – no old-fashioned paper forms to fill in – as:
... not grounded in reality.
The LGA isn't alone, either. It is one of no less than 70 organisations that have criticised UC.

70 organisations, and Liam "there's no money left" Byrne, who says:
Universal Credit is overdue and over budget and now everyone from the chancellor to charities, the CBI to local councils is warning this is a car-crash about to happen.

We've been warning of this for months and we're summoning Iain Duncan Smith to the Commons for a full scale debate.
DWP's response is that there's nothing to worry about:
Liam Byrne is quite simply wrong. Universal Credit is on track and on budget. To suggest anything else is incorrect.
But that's not their only response. DWP also commissioned reports on UC by IBM and McKinsey. Can we see these reports, please, Tony Collins, the campaigning journalist, asked and was told by DWP:
Disclosure would ... give the general public an unbalanced understanding of the Programme and potentially undermine policy outcomes, cause inappropriate concern (which in turn would need to be managed) and damage progress to the detriment of the Government’s key welfare reform and the wider UK economy.
Ministers may to some extent devise policy but it is officials who implement it, as the BBC's Nick Robinson was told in no uncertain terms by Rachel Lomax, the former mandarin. "To suggest anything else is incorrect". It is officials and not IDS:
  • who decided that they couldn't "sweep together the main means-tested benefits and tax credits into one 'universal' benefit" ...
  • and who decided that waving the magic word "agile" around would keep UC "on track and on budget" ...
  • and who decided that UC should be available online only.
How will DWP identify people online? As we now know, DWP hope that it will be through the Cabinet Office's Identity Assurance programme, currently being spearheaded for them by the Department for Business Innovation and Skills's midata initiative. According to midata, everyone will have a PDI, a personal data inventory, and so UC will work. Maybe. But not in this world, it's just "not grounded in reality".

It seems likely that, as we all sit around with our rotting souls and our "unbalanced understanding", ruminating on our summer holidays, the Olympics and the Paralympics, billions of our pounds are once again being incinerated by Whitehall. We can't hear the crackling or see the smoke. All in good time. The National Audit Office report will be published in five years time. Plenty of time to worry about it then.

And while they survey the olympically apathetic British public – no sign of concern at all, not even "inappropriate concern" – what are Whitehall thinking about?

Themselves.

Peter Thomas is Director – Whitehall Transformation at the Institute for Government. He was previously Director then Interim Head at the Prime Minister's Delivery Unit in the Cabinet Office, Non-executive Director at the Improvement and Development Agency, Director of Performance Development at the Audit Commission, Associate Director then interim Director of the Public Services Research Directorate at the Audit Commission, Director of Policy and Regeneration at Westminster City Council and Head of Strategy and Support at Westminster City Council.

And meditating on a number of permanent secretaries jumping ship, Mr Thomas soliloquises as follows, although it's hard to see why:
Senior civil servants are people, not just bloodless lightning conductors, punchbags or beasts of burden for downsizing and cuts. They need to feel engaged, supported and valued at a time when more is being asked of them than ever – and their number is being reduced by as much as a third in some departments ...

We should watch the ranks of director, director general and permanent secretary to judge whether the Civil Service is beginning to see an exodus of too many of its best and brightest to somewhere they feel more valued and better supported to perform – somewhere that allows them to restore their dwindling sense of personal accomplishment.

Such an exodus would be bad for ministers, advisers, parliament and the country.

Universal credit, national apathy

Writing in Monday's Guardian, The universal credit programme is on course for disaster, Frank Field concludes that:
It was brave of IDS [Iain Duncan Smith, Secretary of State at the Department for Work & Pensions (DWP)] to insist on occupying the command on the bridge, but it was the prime minister's wish to avert a catastrophe that drove him to try to move his work and pensions secretary so that the government could quietly shut down the whole reform. His failure to act leaves the disaster on course.
Mr Field believes that means-testing systems like UC, universal credit, create dependency and rot the souls of their parishioners. As the acknowledged authority on welfare, called upon by both the coalition government and their predecessors, his opinion is worth considering.

Monday 10 September 2012

midata, the loneliest initiative in Whitehall – 12 and last

Today is the deadline for submitting responses to the Department for Business Innovation and Skills (BIS) consultation on midata. That doesn't make it an important day. BIS will not be dissuaded by any adverse comment in the responses. But for what it's worth:

midata 2012 review and Consultation - response form

Consultation on legislating to give consumers access to data in an electronic, machine readable form

For your ease, you can reply to this consultation online at: https://www.surveymonkey.com/s/midata
Alternatively you can email, post or fax this completed response form to:

Email

Postal address

Craig Belsham,
Head of Consumer Empowerment,
Department for Business, Innovation and Skills,
1 Victoria Street,
London,
SW1H 0ET

Fax

020 7217 2234
A copy of this consultation can be found at:
The Department may, in accordance with the Code of Practice on Access to Government Information, make available, on public request, individual responses.
The closing date for this consultation is 10 September 2012.


Your details
Name: David Moss
Organisation (if applicable): Not applicable
Address: xxxxxxxxxx
Telephone:    xxxxxxxxxx
Fax:    xxxxxxxxxx        
email: BCSL@blueyonder.co.uk
Please tick a box below that best describes you as a respondent to this consultation:

             
Business representative organisation/trade body

Central government

Charity or social enterprise
ü
Individual

Large business (over 250 staff)

Legal representative

Local Government

Medium business (50 to 250 staff)

Micro business (up to 9 staff)

Small business (10 to 49 staff)

Trade union or staff association

Other (please describe)

Question 1: Do you agree with the principles of midata?
No                          
Have you any comments on the proposed approach?

The Department for Business Innovation and Skills (BIS) say that midata would force suppliers to make transaction data available to consumers. They already make that data available and have done for decades. midata is unnecessary.

BIS say that midata will make the economy grow. They give no reason to believe that and provide no figures. What is the target? How would BIS know if midata had succeeded?

They say that midata would empower consumers. The examples of empowerment given concern switching between mobile phone suppliers and between energy suppliers. There are already applications which support this switching and BIS themselves describe the energy companies as already blazing the trail. Again, midata is unnecessary.

Even its promoters have trouble explaining what midata is for. Professor Shadbolt, chair of the midata programme, was interviewed on BBC Radio 4’s You and Yours on 5 September 2012 and cheerfully announced that he couldn’t give examples of any other applications.

We already have Ofcom and Ofgem. Why do we need midata as well? Are BIS saying that Ofcom and Ofgem don’t do their job properly?

BIS still can’t answer the questions raised by Rory Cellan-Jones of the BBCon 3 November 2011: “what's the catch for consumers and why is the government getting involved?”.

Which may in turn explain the lack of take-up by suppliers, not a single new adherent having been announced since BIS’s 3 November 2011 press release.

Which leaves this respondent to the consultation wondering why BIS want midata, and want it so much that they have switched from midata being a voluntary scheme to proposing to make it compulsory.

And wondering what the rôle of the Behavioural Insights Team is in midata – they’re meant to nudge, not legislate.

And wondering how BIS can describe this proposed additional regulation of UK business as having a deregulatory effect.

The practical effect of midata on the public would be to require us all to maintain a number of PDIs, personal data inventories, each recording sufficient data to identify us.

The PDIs would be maintained on the web, we are told, in the cloud, by trusted third parties – i.e. complete strangers – and they would be in permanent contact with all our suppliers, disseminating changes to our data automatically, without our being involved, to everyone who needs to know about the changes, and occasionally making recommendations to change our phone contract or energy contract.

It takes years to inspire trust and BIS provide no reason to trust these suppliers. They don’t even name them. If midata was a company, no reputable broker would sponsor it and no reputable stock exchange would list it.

The web is an inherently dangerous place to store personal data. BIS and the Cabinet Office, together with the Foreign Office/GCHQ, held an event on 5 September 2012 advising businesses to take effective precautions against cyber threats. At that event BIS promoted a set of GCHQmanuals, in which they give it as their opinion that most businesses have failed to implement cyber security properly.

ENISA, the EU’s information security arm, advise that no valuable data should be entrusted to the cloud and that cloud computing should only be embarked on with a clear exit strategy. The OECD also have their reservations about cloud computing: “cloud computing creates security problems in the form of loss of confidentiality if authentication is not robust and loss of service if internet connectivity is unavailable or the supplier is in financial difficulties”.

If BIS believe GCHQ, ENISA and the OECD, their simultaneous advice to consumers to entrust our personal data to cyberspace is inconsistent and irresponsible.

The Cabinet Office make the unlikely claim that cloud computing is the key to transforming government by making all public services digital by default and delivering them through the G-Cloud, the government cloud, and a number of public clouds, P-Clouds.

For that, they need identity assurance, they need to be able to identify the consumers of public services online. They need the equivalent of the Home Office’s failed National Identity Service. They need us all to have PDIs. That’s what the Cabinet Office say, even while simultaneously acknowledging how dangerous it is and warning people against it.

It’s all very well BIS telling us consumers that we are hopeless at making choices and that we need midata apps to improve our lives. But BIS and the Cabinet Office might do well, equally, to ask themselves how on earth they decided to adopt PDIs, against their own advice, ignoring GCHQ’s advice, ENISA’s and the OECD’s. Better decision-making begins at home, in this case at No.1 Victoria St London SW1.

BIS should drop the ill-thought out midata initiative forthwith, it would do nothing for the economy and it would not empower consumers. Instead, it would expose us all to the risks of identity theft. If the Cabinet Office want us all to have PDIs, let them argue their confused case themselves. There is no good reason for BIS to do the Cabinet Office’s dirty work for them.

Question 2: Do you have a view on whether particular sectors or types of business should or should not be covered?
Yes                         
Comments:
The question doesn’t arise, midata should be abandoned.

Question 3: What is your view on the likely impact of the proposed approach on privacy, consent and information security and the implication for data protection

It would be disastrous. It courts all the dangers that BIS/the Cabinet Office/GCHQ/ENISA/the OECD warn against.

Question 4: What is your view on who should have the right to request data?
Consumers should and already do have the right to request data, midata is unnecessary.

Question 5: Some consumers already shop around, though may not always switch to the best deal for them. What additional proportion of consumers is likely to become empowered by this data?
None.

Question 6: What types of new services might be offered by intermediaries (such as, price comparison websites) and what could be the value of this new market?
The question doesn’t arise, midata should be abandoned.

Question 7:Should a consumer be able to require the business to supply the data in electronic format directly to a specified third party?
No                          
Comments:
It is irresponsible of BIS to incite people to hand over control of our personal data to third parties.

Question 8:Should a third party who is duly authorised by the consumer be able to seek the consumer’s data in electronic format directly from the supplier?
No
Comments:
The consumer is being cut out of his own life in the midata scenario BIS suggest. A number of computers would be exchanging reams of information about the consumer without him or her being involved. Anybody naïve enough to embrace this potty vision of the future should be protected from themselves and not exploited by BIS.

Question 9: What, if any, requirements should be placed on the secondary users of such data, albeit under the direction of consumers e.g. switching and advice sites?
The question doesn’t arise, midata should be abandoned.

Question 10:The Government is minded to require businesses to give their customers access to transaction and consumption data, in order to help them better understand their behaviour.

a)         What types of data would be most helpful? Customers already have access to their transaction data, the question is wrong-headed.

b)         Over what period should the data refer to? That is a matter for the market to decide. It already has decided. Where the period is too short, wise suppliers will heed their customers’ requests to lengthen it.

Question 11: Should other types of information, such as warranties or terms and conditions, be included?  
No
Comments: The question doesn’t arise, midata should be abandoned.

Question 12: Should the Government specify a particular electronic format beyond a machine readable open standard format in which the data has to be supplied?
No
Comments: The question doesn’t arise, midata should be abandoned.

Question 13: Should the Government specify a period within which data must be released electronically following a consumer’s request?
No
Comments: The question doesn’t arise, midata should be abandoned.
b) If so, what would be a reasonable period within which data must be released?

Question 14: Please provide information about cost:
- Where your business already collects the relevant data, please estimate:
a) Additional one- off costs of making the data available in an open standard format (such as, purchasing new IT, hiring IT staff) – not applicable.
b) Additional ongoing costs (such as of additional staff) – not applicable.
c) If not already stated, please state here the approximate number of customer accounts that these costs are estimated for. For example, number of UK accounts – not applicable.

Question 15: Should businesses be permitted to charge a consumer for providing them with the data in electronic format?
Yes
Comments: If midata were deployed, then yes, of course, but the question doesn’t arise, midata should be abandoned.

Question 16: Should any such charges be constrained by the legislation?
No
If so, do you have a view on how a maximum charge should be set or adjusted?
The question doesn’t arise, midata should be abandoned.

Question 17:Which body/bodies is/are best placed to perform the enforcement role for this right?
The question doesn’t arise, midata should be abandoned.

Question 18:Should the Government specify a lead enforcement body?
No
If yes, who:

Question 19: How should the right be enforced by any such body? Will they need any new powers to enable them to enforce it?
The questions don’t arise, midata should be abandoned.

Question 20:  What examples of existing regulatory actions could be reduced or removed if the power being consulted on was exercised?
The question doesn’t arise, midata should be abandoned.

Question 21: Should a consumer be able to launch independent action (and, if so, what sort of action) in relation to non-compliance with the duty?
No
Comments: the questions don’t arise, midata should be abandoned.

Question 22: Do you foresee any risks or undesirable consequences from exercising a power to require certain data to be released electronically?
Yes
Comments: please see answer to Questions 1 and 8.


© Crown copyright 2012
You may re-use this information (not including logos) free of charge in any format or medium, under the terms of the Open Government Licence. Visit www.nationalarchives.gov.uk/doc/open-government-licence, write to the Information Policy Team, The National Archives, Kew, London TW9 4DU, or email: psi@nationalarchives.gsi.gov.uk.This publication is also available on our website at www.bis.gov.uk
  Any enquiries regarding this publication should be sent to:
Department for Business, Innovation and Skills
1 Victoria Street
London SW1H 0ET
Tel: 020 7215 5000

If you require this publication in an alternative format, email enquiries@bis.gsi.gov.uk, or call 020 7215 5000.
URN 12/943RF

midata, the loneliest initiative in Whitehall – 12 and last

Today is the deadline for submitting responses to the Department for Business Innovation and Skills (BIS) consultation on midata. That doesn't make it an important day. BIS will not be dissuaded by any adverse comment in the responses. But for what it's worth:

Sunday 9 September 2012

Andrew Dilnot and honest political debate in the UK – 2

Whitehall officials are impervious to all requests to explain their mistaken choices.
And yet they are happy to tell us that we need midata to correct our errors.
After you, Whitehall.
After you.

--- o O o ---

We all make mistakes.

That's what the Department for Business Innovation and Skills (BIS) say. Faced with a choice, we make the wrong decision. We need help. Computerised help. And BIS aim to provide that help, through their midata initiative. Applications will process our historical transaction data, they will take into account the products and services currently available from the suppliers, and the right transaction will be brokered for us.

It's not just us proletarians. We all make mistakes. Even Whitehall officials.

It's 10 years since the Home Office published their consultation on what became known as "ID cards", Entitlement Cards and Identity Fraud – A Consultation Paper. Crucial to the system was the belief that all 60 million of us in the UK could be identified by various biometrics, specifically facial geometry and flat print fingerprints.

Utter cockpoppy, the technology's simply not up to it. But the choice had been made. By December 2010, when the Identity Cards Act 2006 was repealed, the Home Office confessed to £292 million of our money having been wasted on the scheme, with nothing to show for it.

The waste goes on. We're wasting money on biometrics in Sarah Rapson's ePassports. We're wasting money on Jackie Keane's Immigration and Asylum Biometric System. That takes in eGates that don't work at UK airports and UK visa application checking systems that don't work all over the world. As part of Project Lantern, the police are deploying mobile fingerprinting equipment that doesn't work. And DWP are threatening to use voice biometrics that don't work for their new Universal Credit system.

It goes on because of one wrong choice made 10 years ago. The reliability of the products wasn't checked properly and adverse evidence was ignored. Typical headstrong proletarian behaviour, no idea what's in anyone's best interests, naïve consumers, too much money burning a hole in their pocket, just buy it because it looks good on TV and sounds modern.

How can you help?

You can write to ministers and their officials. That doesn't help. You can write magazine articles and letters to newspapers and comments on blogs and you can write your own blog. You can speak at public meetings and on the radio. That doesn't help. You can have meetings at the Home Office and ditto. You can respond to government consultations and attend government briefings. Fat lot of good it'll do you. You can write to your MP. He or she will get an answer for you. But it won't help. Whitehall wants biometrics and Whitehall's jolly well going to have biometrics, never mind if they don't work.

So then you have another idea. Get reinforcements. Call on organisations that have institutional power.

When the Home Office start advertising their misbegotten ID cards scheme and making unrealistic claims for the reliability of today's mass consumer biometrics, you report them to the Advertising Standards Authority. Brilliant. Except that there's nothing the ASA can do in this case.

So then you submit a freedom of information request asking what justification the Home Office have for investing public money in expensive systems which depend for their success on biometrics being reliable which they aren't and the Home Office know that perfectly well and therefore know that all or some of our money will be wasted. 2½ years later, thanks to the First-Tier Tribunal (Information Rights), you're 2½ years older and none the wiser, Whitehall continue bone-headedly against all the evidence to waste our money on biometrics.

Then Sir Michael Scholar, chair of the UK Statistics Authority, makes an important point:
One of the reasons I took this job is that having good statistics is like having clean water and clean air. It’s the fundamental material that we depend on for an honest political debate.
Honest political debate? Maybe the UKSA can help. Maybe if they or the Office for National Statistics said that the biometrics technology being considered is not reliable enough, then the Home Office would stop wasting our money? No good. The UKSA can only comment on official statistics. And the statistics adduced from the UK Passport Service biometrics enrolment trial aren't official.

This attempt to help the Home Office to make evidence-based policy and to face up to their mistake – choosing to rely on flaky biometrics – clearly goes back years. Lots of effort. No results. The fundamental material that we depend on for an honest political debate still eludes us.

And then Andrew Watson succeeds through a freedom of information request in getting the National Policing Improvement Agency's own internal report on mobile fingerprinting equipment published.

The report is full of statistics, it's marked "Restricted-Commercial", it's got Northrop Grumman's logo on it and it's been prepared for the Police Information Technology Organisation (the old name for the National Policing improvement Agency). Official, or what?

By this stage, Sir Michael Scholar has been replaced by Andrew Dilnot as chair of the UKSA. Can Mr Dilnot comment on the reliability of mass consumer biometrics? No. The statistics still aren't official enough:
From: xxxxxxxxxx On Behalf Of authority enquiries
Sent: 01 August 2012 23:19
To: 'David Moss'
Subject: Re: Misleading use by the Home Office and others of statistics associated with biometrics

Dear Mr Moss

Thank you for your email to Andrew Dilnot regarding biometric information. I am replying on Andrew's behalf. We have considered this matter in discussion with David Blunt, the Head of Profession for Statistics at the Home Office. We share Mr Blunt's view that the studies to which you refer are not official statistics, and we understand from the Home Office that there are no current plans for official statistics in this area to be produced. As you will be aware from our earlier replies, the Authority's statutory remit covers official statistics as set out in the Statistics and Registration Service Act 2007. Our view therefore is that this remains a matter about which we would continue to encourage you to maintain a dialogue with relevant Home Office officials directly. We understand that you attended a meeting with Home Office officials in spring 2010 and, following further correspondence, you received a reply from the National Policing Improvement Agency in June 2010 regarding the specifics of the issues that concerned you.

I am sorry that we are unable to assist you further at the present time.

Kind regards

xxxxxxxxxx
Private Secretary to Andrew Dilnot, Chair of the UK Statistics Authority
UK Border Force staff are laid off in the expectation that they can be replaced by biometric technology, then the queues at the airport get too long because the technology doesn't work and the staff have to be re-hired, but still Whitehall remains incapable of justifying its investment of public money in biometric technology which is too unreliable to do the jobs demanded of it. Incapable and unwilling.

Whitehall officials are impervious to all requests to explain their mistaken choices. And yet they are happy to tell us that we need midata to correct our errors.

Andrew Dilnot and honest political debate in the UK – 2

Whitehall officials are impervious to all requests to explain their mistaken choices.
And yet they are happy to tell us that we need midata to correct our errors.
After you, Whitehall.
After you.

--- o O o ---

We all make mistakes.

That's what the Department for Business Innovation and Skills (BIS) say. Faced with a choice, we make the wrong decision. We need help. Computerised help. And BIS aim to provide that help, through their midata initiative. Applications will process our historical transaction data, they will take into account the products and services currently available from the suppliers, and the right transaction will be brokered for us.

It's not just us proletarians. We all make mistakes. Even Whitehall officials.