Friday 26 October 2012

GOV.UK is not Government on the Internet, but of the Internet

Why haven't GDS announced their identity assurance strategy yet?
The suspicion is growing that they haven't got one.

In the absence of any news about the Government Digital Service's plans for identity assurance your gaze may fall upon ex-Guardian man Mike Bracken's blog post about the release last week of GOV.UK, the new single government domain, the partial implementation of Martha Lane Fox's "digital by default".

Why does GOV.UK matter?

Good question.

Local Authority Review – Citizen Online Identity Assurance
September 2012

[IdA = identity assurance
LA = local authority]

... Communication is seen as key and it was suggested that a national campaign run by trusted organizations (e.g. Citizen’s Advice Bureau and other voluntary organizations) would be helpful.

Communications to build citizen trust and highlight the benefits such as a reduction in bureaucracy for both citizens and the LA, are seen as key. Once a proven nationally recognised approach is in place with a recognised and trusted branding, it is suggested that the branding could then be integrated into LA websites. LAs would then feel more confident about communicating the concept at the local level. Through a variety of channels awareness raising could be undertaken. Suggested approaches include citizen training in libraries and other venues with high citizen footfall, contact through third sector and voluntary organizations, articles in free newspapers and council magazines, promotions through the housing advice bus visits and web promotion.

Another important step for LAs is to gain a sound understanding through customer research on how the idea of federated IdA might be received by different sectors of the population6. Usability and accessibility are also a key concern to ensure that processes are not over-complicated – it may be more appealing to undertake repeated simple registrations and sign-ons than one complicated procedure especially when the goal is to undertake a simple transaction ...


Whilst there is some mention of a national agenda, the most common drivers for online citizen IdA are cited as corporate strategy, service needs, cost reduction and efficiencies. Although there has been no explicit demand from citizens (other than around privacy concerns), improvement of the customer experience also appears to be a motivating factor.

In response to these drivers authorities have strategies either in place or in development to take forward service transformation, channel shift and/or improved customer service. Key principles of these strategies include digital by default (or at least by citizen preference), escalation of a self-service culture allowing greater focus on the more vulnerable, multiple channel access, and device independence.

IdA is not always discretely identified within these strategies although a number of authorities articulated its importance in terms of being an architectural building block and an enabler. Business cases do not tend to be written for IdA but rather it is included as an element within business cases for channel shift/service improvement programmes (e.g. Individual Electoral Registration Programme). So whilst it may not be explicitly referenced, there was general consensus that IdA is an important part of the infrastructure and is an integral part of channel shift which will allow a more coherent approach to the citizen.

The developing theme of single sign-on and a standardized approach to IdA is however juxtaposed with emerging imperatives. The advent of adult social care budgeting, and new government policies on troubled families is likely to drive LAs to seek further single service solutions to add to the mix.

”… because of the need to respond to welfare reform the view was that we can’t wait so we’ll do it and then fix it, federate it later.”

Lee Hemsworth, Chief Officer (Intelligence and Improvement), Leeds City Council ...

----------

6. Relevant studies include Group Identity Assurance – User tests results from the Happy Use Case, UCL Department of Computer Science Information Security Research and UC IDA claimant testing Findings, DWP Insight Team

And one which has obviously been occupying the executive director of GDS. In Why GOV.UK matters: A platform for a digital Government he writes:
GOV.UK has been designed with transparency, participation and simplicity at its core. It will always be based on open standards, and is unapologetically open source. This architecture ensures its integration into the growing ecosystem of the Internet. Inevitably, innovation will follow, driven from within and without. GOV.UK is not Government on the Internet, but of the Internet.
"GOV.UK is not Government on the Internet, but of the Internet". Does anyone have any idea what that means?

Would it help to try another preposition? "GOV.UK is not Government on the Internet, but under the Internet", perhaps?

It doesn't help, does it.

That's because whether we're talking about government deeply in debt to the internet or government carried out without even a passing interest in the internet, GOV.UK isn't government. It's a website.

When he uses the words "transparency", "participation", "simplicity", "open standards", "open source", "ecosystem" and "innovation", this is ex-Guardian man Mike Bracken presenting his credentials. It is a homage to what he describes as Tim O'Reilly's "seminal work Government as a Platform".

Mr O'Reilly's seminal work, if you care to read it, is many things:
  • A gratuitous endorsement of President Obama's healthcare legislation.
  • A cod history of commerce and civic action since the days of Benjamin Franklin.
  • An attack on IBM and Microsoft for being monopolies (nearly).
  • Praise for Amazon, Google, Facebook and Apple for being monopolies (nearly).
  • An expression of Mr O'Reilly's fascination with technology.
  • And of his belief that only crowds have wisdom.
  • And that individuals know nothing.
  • Apart, presumably, from Mr O'Reilly.
That's not quite fair, actually.

There has been some news about identity assurance.

Amanda Derrick OBE, a fairly recent addition to the GDS team, an escapee from the Gove Terror at the Department for Education, presented a report yesterday on Identity assurance for local government services.

Who wrote this report?

Someone too bashful to tell us. Someone lacking the assurance to identify themselves.

Whoever it was rang up 16 local government officers and had a chat with them. A long extract from the resulting report is quoted alongside. It doesn't make much difference if you read it forwards or backwards.

Digital by default is about delivering public services. Most public services in the UK are delivered by local government and yet GDS left it until July 2012 to commission this report.

What it tells them is that they don't know much about what is needed, by way of identity assurance, by the people who actually deliver public services and by their parishioners.

Why haven't GDS announced their identity assurance strategy yet? The suspicion is growing that they haven't got one.

GOV.UK is not Government on the Internet, but of the Internet

Why haven't GDS announced their identity assurance strategy yet?
The suspicion is growing that they haven't got one.

In the absence of any news about the Government Digital Service's plans for identity assurance your gaze may fall upon ex-Guardian man Mike Bracken's blog post about the release last week of GOV.UK, the new single government domain, the partial implementation of Martha Lane Fox's "digital by default".

Why does GOV.UK matter?

Good question.

Wednesday 24 October 2012

HMRC and Skyscape 2

The following open letter has been sent by email and by post to Phil Pavitt in his capacity as HMRC Director General Change, Security and Information with a copy to Lin Homer, Chief Executive, HMRC:

[Skyscape has subsequently changed its name to UKCloud: "London – August 1, 2016 – Skyscape Cloud Services Limited, the easy to adopt, easy to use and easy to leave assured cloud services company, has today renamed and relaunched as UKCloud Ltd (www.ukcloud.com), to reinforce the company’s exclusive focus on supporting the UK public sector in the digital transformation of services".]

Open letter [1]

Phil Pavitt          Your ref. CETO /03531/2012
HMRC Director General
Change, Security and Information
100 Parliament St
London SW1A 2BQ          24 October 2012

Dear Mr Pavitt

HMRC and Skyscape Cloud Services Ltd

Thank you for your letter dated 22 October 2012 [2] in response to my letter to Lin Homer dated 11 October 2012 [3].

The point is well taken, of course, that for security reasons HMRC can’t say what data is held where. We're in we-can-neither-confirm-nor-deny territory here. It’s difficult but, given the bizarre nature of the Skyscape contract, HMRC are going to have to find some way to reassure the public about the security with which our tax records, both personal and corporate, are being held.

“The data will continue to be kept in accordance with existing legislation and HMRC security policies”, you say. I should hope so, too – the public want, need, deserve and pay for nothing less.

But your statement begs the question.

The public is bound to assume that the data to be stored at Skyscape’s cloud computing facilities is the tax records of every individual and legal person in the country. What other data does HMRC have?

And the public is bound to assume that our data is intended to be stored at Hartham Park, Corsham, Wilts SN13 0RP because that’s the address of the registered office of Skyscape Cloud Services Ltd and it’s the address of the registered office of its “ally” ARK Continuity Ltd and it’s the address of ARK’s Spring Park data centre as noted for everyone to see on ARK’s website [4]. If that isn’t a breach of security, what is?

Skyscape is a young start-up, it hasn’t yet submitted any accounts to Companies House, it has no track record, it has only one director and he owns all the shares in the company. If the Government Procurement Service (GPS) and HMRC believe that Skyscape is an appropriate company to trust with the care of our tax records, then there is something wrong with GPS’s and HMRC’s selection criteria.

CloudStore make the point that the inclusion of a company and its services in its on-line store is not a warranty of appropriateness. It’s up to the customer – in this case HMRC – to determine appropriateness. Eleanor Stewart, the Assistant Director of G-Cloud, says [5]: “as with everything on the G-Cloud framework the customer can determine whether they are happy with any associated risk at the point of selection”.

The references to GPS and to CloudStore in your letter can provide the public with no comfort.

You mention the Skyscape Cloud Alliance [6] in your letter.

Goodness knows what ARK Continuity is doing in the Alliance. HMRC doesn’t promote itself as being in an alliance with Mapeley. Why does Skyscape expect the public to find it commercially persuasive to include its landlord in the Alliance?

QinetiQ, VMware, Cisco and EMC on the other hand are all industry leaders and if HMRC had entered into a contract with a joint venture company involving them then we wouldn’t be having this correspondence.

But you haven’t.

HMRC have entered into a contract with a one-man start-up. That was the case before you wrote your letter and it remains the case subsequently. The question therefore persists, how can HMRC make such an odd-looking decision? How can they risk the nation’s tax records on Skyscape?

There’s no joint venture company there for a Tax Inspector to get his or her teeth into. Just an “alliance”. What is an alliance in this case?

The contract is to provide cloud computing services. “Cloud computing” means losing control [7]. Whitehall promotes cloud computing on the basis that it turns IT into a utility [8]. That is not attractive, as this month’s news about gas and electricity prices will confirm.

None of us has control over the price our suppliers charge for gas and electricity at home or control over their staff. If HMRC enter into a cloud computing contract with any supplier, big or small, they will have the same problem. How can HMRC risk the nation’s tax records on cloud computing?

Salesmen sometimes unfortunately make over-enthusiastic claims about cloud computing being more resilient, secure and efficient than the alternatives. Lawyers don’t believe them. Lawyers don’t use cloud computing. Lawyers are paid to keep their clients’ data under control and confidential. So are public authorities like HMRC.

As I write, I note that the latest cloud computing débâcle is unfolding. Amazon are the biggest cloud computing suppliers in the world and they’ve just had a 12-hour outage [9].

Our tax records are currently stored on hundreds of servers at “multiple” HMRC offices, you say. Good. That looks secure. Much more secure than storing them all in one place with a one-man start-up in some sort of nugatory alliance. And, since you mention it, the allegedly dainty carbon footprint of cloud computing will be no consolation if our records go up in smoke.

According to HMRC’s press release [10] the Skyscape contract will save £1 million a year on running costs. We need to be guided here by the National Audit Office (NAO) report on HMRC’s on-line filing [11].

The NAO examined HMRC’s £8 billion 10-year ASPIRE contract with Capgemini and said:

HMRC uses a range of indicators to measure the performance of its ICT services, which include online services, and it measures availability that relates specifically to online filing. HMRC has a high-level view of the overall costs of ICT provision through the ASPIRE contract. It has been taking steps to improve that information and achieve cost savings. It does not yet have a detailed breakdown of the costs of online filing services, so it cannot benchmark those costs to assess their value for money. HMRC is currently negotiating with the ASPIRE contractors to obtain a clearer breakdown of the costs of ICT services provided. (p.8)
Also:

[HMRC] should proceed with its plans to identify ICT costs specific to online filing services and ensure that current negotiations with the ASPIRE contractors provide sufficient breakdown of cost information for regular benchmarking of costs. (p.13)
In the circumstances, with the suppliers not even prepared to tell HMRC what they are charging for, some scepticism is in order about claims to be able to identify £1 million of on-line filing costs in among the £8,000 million.

CESG have rescued the nation before from other-worldly decisions taken by Whitehall. The Home Office wanted to use DWP’s National Insurance number database as the National Identity Register for the ID cards scheme. CESG pointed out that it was inappropriate and that was the end of that [12].

Let’s hope that they repeat the trick in their review of Skyscape. I look forward to a small piece appearing in the technical press somewhere out of the way regretting that for security reasons which cannot be given the HMRC contract with Skyscape has had to be revoked.

Yours sincerely
David Moss

cc      Lin Homer, Chief Executive, HMRC
          Chartered Institute of Taxation
          Institute of Chartered Accountants in England and Wales




[7]Cloud computing and the Gadarene lemmings of Whitehall, http://www.dmossesq.com/2012/10/cloud-computing-and-fashion-conscious.html
[8]Cloud computing turns IT into a utility, and that's a good thing?, http://www.dmossesq.com/2012/10/cloud-computing-turns-it-into-utility.html
[9]Amazon outage started small, snowballed into 12-hour event, http://www.networkworld.com/news/2012/102312-amazon-outage-263617.html
[11]HM Revenue & Customs – The expansion of online filing of tax returns, http://www.nao.org.uk//idoc.ashx?docId=cd237708-5c6b-472a-af13-f432f80d80cc&version=-1
Updates:
24.5.12
Phil Pavitt says "we don't currently have ID authentication in UK government".
24.10.12
Letter emailed to Phil Pavitt and Lin Homer
25.10.12
Hard copy of letter posted to Phil Pavitt and Lin Homer, links sent to Eleanor Stewart, CIOT and ICAEW
28.10.12
Re last two paragraphs of letter, see Andy Smith affair.
4.11.12
US government argue that signing a cloud services agreement reduces your property rights in the data stored in the cloud, according to EFF.
13.11.12
Cloud computing, and GDS's fantasy strategy: "To which, all one can say is that there must be something wrong with the Cabinet Office, GPS and HMRC procurement criteria ...".
23.11.12
UK.gov to upgrade buying tool after mega cockup downs £1bn deal – Government Procurement Service computer system incapable of handling tenders for government procurement.
26.11.12
HMRC soon to be Pavittless – will Aviva store all our insurance details with Skyscape?

HMRC and Skyscape 2

The following open letter has been sent by email and by post to Phil Pavitt in his capacity as HMRC Director General Change, Security and Information with a copy to Lin Homer, Chief Executive, HMRC:

[Skyscape has subsequently changed its name to UKCloud: "London – August 1, 2016 – Skyscape Cloud Services Limited, the easy to adopt, easy to use and easy to leave assured cloud services company, has today renamed and relaunched as UKCloud Ltd (www.ukcloud.com), to reinforce the company’s exclusive focus on supporting the UK public sector in the digital transformation of services".]

Is GOV.UK a work of art? With no identity assurance services, that's the best it can hope for ...

... at which point GOV.UK starts to look pointless ...

DWP are waiting for identity assurance services, to make progress on Universal Credit.

We were expecting the suppliers of identity assurance services to be named by 30 September 2012 latest. It didn't happen. Then we were expecting them to be named on 22 October 2012. It didn't happen. We're expecting Universal Credit to make work pay but at the present rate that isn't going to happen either.

Last week's release of GOV.UK was "the start of a new era of digital services" according to ex-Guardian man Mike Bracken, executive director of the Government Digital Service (GDS) – not without identity assurance services it isn't.

We know that GOV.UK is hosted on Skyscape. Or Akamai. But who's going to access it?

25 million hits per month we're expecting on GOV.UK. Maybe more. There's plenty of real estate on screen for Google to serve up ads. But who's going to click on them?

GOV.UK is meant to improve the user experience of dealing with public services. Without identity assurance services, there aren't any users to enjoy the experience.

That's an exaggeration. There will be people browsing the site anonymously. But they've been able to do that on Directgov and Business Link for years.

No users? There's an important way in which that's not an exaggeration. The point of digital by default, Martha Lane Fox's dream, and Francis Maude's too, is to have people registering for services and applying for student loans and paying their VAT using GOV.UK. For that, they need to be identified.

No identity assurance services, no digital by default. At which point GOV.UK starts to look pointless.

The deadlines come and the deadlines go. How much longer is everyone going to have to wait? In particular, how much longer are the millions stuck in the poverty trap going to have to wait?

----------

Update 17.11.13:
A year of departments and policy all in one place
A year of departments and policy all in the same place. A place with no identity assurance.

Update 18.11.13:
HMRC set to go digital:
Mark Dearnley, the new Chief Digital and Information Officer for HMRC, announced ... that HMRC will “become a fully accessible digital business ... The multi-channel digital tax platform will have security at the heart of it. The new Government Identity Assurance Programme platform will be part of that.”
It would help, or at least it should help, but just for the moment there is no identity assurance platform and no sign of it turning up.

Is GOV.UK a work of art? With no identity assurance services, that's the best it can hope for ...

... at which point GOV.UK starts to look pointless ...

DWP are waiting for identity assurance services, to make progress on Universal Credit.

We were expecting the suppliers of identity assurance services to be named by 30 September 2012 latest. It didn't happen. Then we were expecting them to be named on 22 October 2012. It didn't happen. We're expecting Universal Credit to make work pay but at the present rate that isn't going to happen either.

Last week's release of GOV.UK was "the start of a new era of digital services" according to ex-Guardian man Mike Bracken, executive director of the Government Digital Service (GDS) – not without identity assurance services it isn't.

Tuesday 23 October 2012

Reminiscing about IdA while we wait to find out about our identity providers

30 September 2012 has come and gone. Everyone was looking forward to discovering which companies would be the UK's "identity providers" but the deadline passed and we're none the wiser.

Then it seemed as though we would be told on 22 October 2012. That's what it said in the Independent and the Government Digital Service (GDS) seemed quite happy with that coverage but no, still no answer.

While we're waiting, it's tempting to reminisce about the history of GDS's Identity Assurance project (IdA).

IdA started as part of the G-Digital programme. A number of private sector organisations were inveigled into  collaborating on the programme, groups of them were sent away to work on different tasks and in January 2010 a report of their findings was produced.

Worthily written, the report ploughs relentlessly through its ten objectives. Stop for a while at Objective #4 – To determine any gaps in our Business Services on p.9. On-line payments? Got it. Enrolment? Got it. Search engine optimisation? Etc ... All the business services are there, no gaps, including Adserver.

Adserver? In the public sector? In the UK?

Take a look at GOV.UK. Lots of space down the sides on the screen, left and right. Bit of a shock at first to be sure but, think about it, why not, this is the world of Facebook and Google now, and Amazon and eBay, very handy for advertisements.



Extract from G-Digital Market Investigation High Level Analysis & Findings




What would it look like if GOV.UK carried advertisements?

Here, for example, is a serious Simon Jenkins article on the Guardian's Comment is free forum topped off and flanked with advertisements for holidays in Kenya. Suppose you were browsing GOV.UK instead of the Guardian. Suppose it was your tax return on the screen instead of a Simon Jenkins article. And suppose that the same advertisements were there.

That couldn't happen, could it?

Yes it could. There didn't used to be advertisements on Comment is free until someone came along and re-designed it:



The future look of GOV.UK?

Reminiscing about IdA while we wait to find out about our identity providers

30 September 2012 has come and gone. Everyone was looking forward to discovering which companies would be the UK's "identity providers" but the deadline passed and we're none the wiser.

Then it seemed as though we would be told on 22 October 2012. That's what it said in the Independent and the Government Digital Service (GDS) seemed quite happy with that coverage but no, still no answer.

While we're waiting, it's tempting to reminisce about the history of GDS's Identity Assurance project (IdA).

Monday 22 October 2012

Things happen when Lin Homer's in the loop. Fast.

An open letter was sent to HMRC by email and by post asking about the advisability of contracting with Skyscape Cloud Services Ltd.

An acknowledgement was received today by post promising a response within 15 working days.

And then the response was received, as shown below, dated today. Unprecedented.

With thanks to Phil Pavitt, responding on behalf of Ms Homer, and no further comment for the moment:

[Skyscape has subsequently changed its name to UKCloud: "London – August 1, 2016 – Skyscape Cloud Services Limited, the easy to adopt, easy to use and easy to leave assured cloud services company, has today renamed and relaunched as UKCloud Ltd (www.ukcloud.com), to reinforce the company’s exclusive focus on supporting the UK public sector in the digital transformation of services".]

HMRC and Skyscape Cloud Services Ltd

Dear Mr Moss

Thank you for your letter of 11 October 2012 expressing your concerns in respect of HMRC’s recently announced contract with Skyscape Cloud Services Ltd. I am replying on behalf of HMRC’s Chief Executive, Lin Homer.

Skyscape were selected by HMRC and awarded a 12 month contract due to their innovative, inventive and value for money solution. In terms of the suitability of Skyscape hosting HMRC data I can confirm that HMRC procured the services of Skyscape via the HM Government “G-Cloud” Framework, also referred to  as the CloudStore. The G-Cloud was created by the Cabinet Office and the Government Procurement Services (GPS) via a formal competition process through the Official Journal of the European Union under the Open Procedure.

G-Cloud was established to make government procurement easier and more transparent and was, in part, created as a means of encouraging small and medium sized enterprises (SMEs) to compete on a level playing  field with multi-national organisations.

In order to deliver services through G-Cloud, all suppliers on the Framework, Skyscape included, were required to meet a set of mandatory criteria set out by GPS including their financial standing and Experian risk assessments. Additionally, HMRC carried out its own standard taxation and financial compliance checks  before awarding the contract and Skyscape passed the standard set by the G-Cloud Framework and HMRC.

Skyscape’s services are provided through a number of key, or “Alliance”, Partners. These partners are industry leading organisations that provide services in the data centre or “cloud” arena such as EMC (storage  and security services), Cisco (networking) and Ark Continuity (UK based high security data centres). Ark Continuity therefore are one of a number of partners who supply Skyscape with their products and services which are key to Skyscape’s overall assured cloud computing services.

However, data security remains integral to HMRC and a pre-requisite of any of our data being migrated to Skyscape is for their solution, including all the constituent parts, to be formally accredited by CESG (the Communications-Electronics Security Group) to Impact Level 3 (IL3). For more information please see the link below:

http://gcloud.civilservice.gov.uk/2012/03/09/so-what-is-il3-a-short-guide-to-business-impact-levels/

This accreditation is expected imminently, at which point HMRC will be in a position to begin securely moving data over to Skyscape and decommissioning our old servers. Once the data has been moved it will remain there for the contract duration (12 months) during which time any subsequent data storage contract will be re-competed to ensure HMRC continues to take advantage of innovative, secure and low cost solutions, available within the marketplace, which allow HMRC to easily store, manage and transfer its data.

It should also be noted that for security reasons HMRC does not discuss details of the data that it holds, or where it stores it, however we are able to confirm that by using Skyscape HMRC data will continue to be kept in accordance with existing legislation and HMRC security policies.

Finally, I can confirm that the claims within HMRC’s press release of 26 September are fully justified. The data, which will be securely stored by Skyscape, currently resides on several hundred servers, across multiple HMRC office locations. This change will consolidate that data and place it into a small number of secure and highly resilient cloud data centres hence improving the security of the data, the efficiency of managing that data as well as improving HMRC’s carbon footprint.

I trust that this answers your queries in full and I hope that you can now appreciate that HMRC’s decision to contract with Skyscape was not dangerous, ill-advised or irresponsible.

Yours sincerely,
Regards
Phil Pavitt
HMRC Director General Change, Security and Information

Things happen when Lin Homer's in the loop. Fast.

An open letter was sent to HMRC by email and by post asking about the advisability of contracting with Skyscape Cloud Services Ltd.

An acknowledgement was received today by post promising a response within 15 working days.

And then the response was received, as shown below, dated today. Unprecedented.