Government ministers have a choice about how they use the welfare system to help people who have lost their jobs or businesses get back to work. That choice includes questions of ethics, efficacy and trust.
The working-age welfare system has always existed as a set of rights and responsibilities. Since the Welfare Reform Act 2012 and the introduction of Universal Credit, the responsibilities side was dialled right up. DWP gets to set a set of tasks and expectations for each household claiming and is the arbiter of if they have been met. If people fail to meet their ‘responsibilities’ — if they fail to take a job that is offered to them, or fail to spend up to 35 hours a week searching for work — then households have their benefits reduced in the form of sanctions. This does not just apply to people out of work, but people on low incomes too.
It’s crude, but Universal Credit is basically Task Rabbit for government. The question for ministers is how they use this system in a world where:
- There are significantly more claimants, many of whom may be new to the welfare system and may have different expectations now they find themselves reliant on it
- There are substantially fewer jobs, and many of those that are may carry a risk of exposure to COVID-19
Some of the ethics of this are hopefully obvious — when is it acceptable to force people into essentially taking a job that may carry a health risk? What assurances should DWP have about the social distancing practices of an employer and the exact location of the work, before applying sanctions against a household?1
The efficacy question comes from the fact that (at best!), the jury is out on sanctions and their effect on people’s long-term prospects. (How they will work in the context we find ourselves today, we can only guess). Ministers need to decide what their offer will be to the public. If they want to get people into work, potentially in totally different professions, they will need to give DWP staff other tools than the sanctions hammer.
On trust, ministers need to understand that people’s trust in the government’s response will not come from the simple employment figures. The way the process makes them feel and the sense that it feels like a fair deal will become an issue of long-term trust.
Job adverts are going to need to change to include this information↩︎
The tech-twitter conversation about contact tracing apps has focused on privacy and decentralisation. Regardless of the form it takes in the UK — and it looks like for now it will be a centralised system, (hopefully with some very strong legal constraints) — there are eight things* that the NHS should do to make sure the process enables a healthy and open public debate.
Publish a list of all the names of the different bits of technology (app, admin system, design system, etc) used to deliver the service along with the current version number and the date and time it was updated. This should be kept up to date each time a new version is deployed.
In line with the Government Service Standard, wherever possible, the source code and database schema for each of these should be published in the open. Given the NHS will be likely using modern development practices and deploying updates regularly, publishing as a one-off will not be sufficient. Source code should be published as soon practically possible after each release. Commercial ownership of bespoke or customised code developed for the service should be not a valid reason for not publishing.
Any data sharing agreements used to deliver the service should be published in one place on either GOV.UK or NHS.UK.
Elements with a user interface (e.g. public-facing apps and admin systems) should display the current version number. The NHS App already does this). For each version, the NHS maintain an archive of the user interface changes. This is important because mall design choices can have big impacts on how people access and understand services. If the tinkering with the branding/advertising campaign is anything to go by, the temptation to tweak will be strong (and there may also be legitimate uses of A/B testing). As such, it is important that a record is maintained of how people are experiencing the service.
The design should clearly explain when notifications have been triggered automatically, vs when it has been done by a person. It doesn’t need any wizzy design; words should do it. (Maybe something could be fast-tracked through the GOV.UK/NHS design system?)
Given this will be a real-time system, it should regularly publish data about how the service is being used. This should include the number of users, but also information that will help the public understand if it is advantaging or disadvantaging particular groups. (This is a knotty problem and runs counter to some of the debate around privacy — sometimes you need to collect more data to know if you’ve built something discriminatory).
Relevant civil society organisations should have access to the categories and absolute numbers of issues that users are reporting.
There should be a clear, well-designed process for users and those involved in delivering the service to understand their rights and raise or escalate concerns about how data is being used. This should be part of the design of the service, not an add-on.
* This is not an exhaustive list. I’m hoping people will have their own.
The thing about infrastructure is that it fades into the background to the point where people stop questioning how it works. So when the US government announced plans to make payments to citizens, the focus has been on delays needed to change the printing process to include the president’s signature, rather than the fact that cheques are being printed at all.
Similarly, when the UK Chancellor was asked yesterday about the dates for Job Retention Scheme payments to companies, he cited the need to include the delay required by the BACS electronic transfer system (which typically takes three working days). BACS is the same system that contributes to the five week wait for Universal Credit payments.
Since 2009, the UK has had a system for immediate bank transfers called Faster Payments. Despite this, the vast majority of UK government payments to the public and companies are done via the older BACS system (although DWP does use Faster Payments for advance Universal Credit payments).
This probably comes down to cost. While banks do not charge the public for Faster Payments, this does not appear to be the case for government. Data about costs are not easy to come by, but based on an answer to a written question from an MP in 2014, the costs to DWP of a BACS transfer was £0.004, compared to £0.16 per transaction for Faster Payments.
In much the same way that the government has successfully secured the removal of data charges for NHS websites, it should secure free payments for government services to access the Faster Payments system to speed up payments to those in need. This should apply to all benefit payments for the duration of the crisis as well as exceptional payments such as the Job Retention Scheme.
This is a quick blog post to write up some ideas from a conversation between Dan Barrett and Richard Pope about how civil society organisations can better work together on data.
To respond to the COVID19 crisis, dedicated teams across central, local and devolved governments are developing new services and making changes to existing ones, all at great speed. This includes everything from transactional services like the NHS’s “Get an isolation note” service, to complex federated efforts like “Get coronavirus support as a clinically extremely vulnerable person”. Shortly it could include contact-tracing services that raise significant civil liberties and equality issues. Existing services, such as Universal Credit, are coming under new pressure and will need to adapt.
Service design at speed necessitates advocacy and support at speed. Charities and support organisations will need to change their work as the needs of the public change. This will only be possible if civil society has a good, collective, understanding of these changes, share what they are learning from users of those services, and understand what other organisations are by way of offering help. In short, there is a need for better data.
There are no doubt many opportunities for this, this blog post is a way of testing people’s appetite and suggesting three places to start.
1. Documenting new government services
Civil society organisations can provide an important role in documenting how new government and NHS services are designed and function. Collaboratively documenting what services have been created and how they work (aka ‘service teardowns’) could prove a useful tool for those advocating for policy changes. This could be particularly important for any new services that have civil liberties or equality implications, and for changes to existing critical services such as Universal Credit.
2. Shared early warning systems
The new circumstances created by COVID19 and new public services will be creating new issues for the public and new demands on public services. It is critical that this knowledge is not locked within a single organisation, but is available across the sector. An open approach like this could help to build more consistent language for issues over time, enabling collaboration. A shared early warning system could take various forms - anything from a weekly zoom call to a Google Form. The important thing is that someone is acting in a convening function to ensure issues are shared.
3. Improving the discovery of support services
As charities and support groups start to offer new support services or expand existing ones, there is an opportunity to capture this as structured georeferenced data. Services data could aid triaging between organisations, but also be surfaced on websites like GOV.UK and Citizens Advice.
What other opportunities are there for charities and support groups to work together on datasets during the COVID19 crisis?
Following from my previous post about the ability of the UK planning system to deal with digital infrastructure like the InLink, it seems there may be a mechanism to give communities a say over what sensors, data collection practices and targeted advertising they invite in.
It’s the same one we use to regulate things like the opening hours of shops: ‘[planning conditions’.
Planning conditions allow a local authority to list the things that must not change without prior agreement - things like opening hours or the number of carparking spaces in the car park.
Own a shop and want to open after 23:00? Then you’ll need to submit a new application to the council for public comment.
Want to add a couple more parking spaces to the carpark?
Time for another application.
So, could planning conditions be used to regulate important changes to digital infrastructure?
Could they be used to, for example, force the maintainer of a connected phone box to apply for permission to enable the use of facial recognition cameras?
Maybe.
There are not many examples of planning conditions being used to regulate connected infrastructure, so back in December Adrian Short, myself and others started writing a ‘model condition’ using a public Google Doc. Several people have helped by adding to it.
You can view and improve it here and hopefully. Given the increase in ‘phone box’ applications, hopefully some local authorities might find it useful.
Our local high street is going to have one of its phoneboxes replaced with an ‘InLink’.
InLink is a public wifi network provided by BT through on-pavement ‘structures’ and funded through advertising displayed on a big screen on the side of them.
They have some additional functions, like making a free phone call or looking up local information, but given smartphones are a thing most people now have, advertising and wifi are the main play here.
According to the FAQs advertising will be targeted based on data about how people use the InLinks:
We may use anonymized Technical Information to … Deliver relevant advertising on the Structures
That will presumably include some tracking of individual devices:
we collect your email address, your device unique identifier (MAC address), and your device type during the registration process. We collect this information to help us operate and provide services to you.
In the same way as other ISP’s anyone using the service will have the websites they visit logged:
In order to comply with laws and regulations, we must capture this information. We will only share this information in response to a lawful request or legal process, including from government and public authorities.
What is less clear is if this data will be used to tailor what adverts get displayed on specific InLinks.
There are also three cameras, which will be disabled at launch:
There are two security cameras above the ad displays as well as one built into the tablet. All three cameras are turned off at the moment and will not be activated without express notice to the public.
In New York, where there is a large deployment of InLinks, cameras are used for security and “to improve Services”.
Given attempts by similar services to use cameras to guess people’s age and gender and to use that to target adverts at people, it’s reasonable to question what those cameras could be used for in the future.
Now, better public wifi is much needed, and it’s great to see investment in it. But there are three questions that InLink raises for me:
- As a society we have not yet dealt with the implications of targeted advertising online. Are our institutions ready to facilitate a healthy debate about what inviting targeted advertising into our public spaces will mean?
- Is provision via a private company and funded by advertising the only model for doing this? Given there is a strong argument to be made that wifi is important infrastructure, shouldn’t we at least have the conversation about treating it in the same way as we do the London transport system - directed by and accountable to the city government?
- Each InLink will require planning permission, but given the very essence of the thing can be changed remotely at a later date (the cameras can be enabled/disabled, how targeted the adverts are can change), is the UK planning system really set up to deal with digital-physical infrastructure like this?