Citizens Advice response to the consultation: Making public services work for you with your digital identity
Every day, we help people access essential services. People come to us for advice, but in reality we often end up helping them navigate digital systems.
Digital ID could be a way to help make services more proactive and hassle free. But we help people every day who are locked out of benefits portals, unable to prove their visa status or struggling to secure housing online.
Digital exclusion affects millions of people in the UK. Although Digital ID may be beneficial for those who do not have access to traditional forms of ID, we are acutely aware of the risks and barriers that digitally excluded people may face.
We are concerned that the roll out of digital ID will erode non-digital channels, especially where groups of people move in and out of digital exclusion. Where access to Digital ID is limited by the cost of a smart phone, this could create an affordability barrier, not relieve it.
Our response to this consultation draws on our frontline insights. Our survey of 175 advisers found that:
82% of the clients they see don’t have access to reliable internet or struggle with online application processes and;
75% of people find it difficult to access help to complete their applications (e.g. long phone waits or lack of face-to-face support).
Our responses to this consultation include:
Risk of exclusion: Digital ID gives people an alternative way to prove their identity, but there are many groups of people it may negatively impact. Those without smartphones, limited internet access or low digital confidence will need to rely on strong non-digital options to be shielded from further digital exclusion. Support must be long term, and non-digital routes always need to be available.
A need for swift recovery: When phones get stolen or system errors happen, people get locked out of essential services. At Citizens Advice, we see the detriment to people’s lives when being locked out of a digital service means they can’t access their visa status, funds or housing. Swift recovery support will need to be an essential part of service design.
Trust will be essential for successful adoption. To build and maintain trust, the UK Government will need to offer ongoing community support and protect non-digital channels. Partnerships with organisations with impeccable data governance reputations will support trust.
Risk of data lockouts from data matching errors: The Government needs to consider how assumptions and errors in the system such as support being withdrawn or being asked to repay overpaid support, can create unfair outcomes for people and safeguard people from detriment.
Transparency will be key: Data matching needs to be treated with caution and be attuned to public concerns of monitoring and surveillance. For people to embrace the use of Digital ID, the system needs to be built on choice and trust. This will involve there being transparency on how data is shared, ensuring other channels of proving identity are left open and robust protection from fraud.
Risk of exclusion from new Right to Work Checks: Removing the option to use paper forms of ID for Right to Work checks carries a significant risk of excluding people from the labour market who may struggle to access Digital ID.
Recommendations summary - the UK Government must:
Protect non-digital routes to identification
Provide swift access to urgent non-digital recovery support when people are locked out of their Digital ID
Build proxy support into the design of ID services
Offer ongoing human, community support to help with adoption.
Provide transparent, easy to understand data and governance frameworks.
Create a clear communications plan which offers tangible benefits to users.