The Association of Consumer Support Organisations (ACSO) has responded to the Department for Culture, Media and Sport (DCMS) consultation on digital identity and attributes.
Cara Elliott, policy and public affairs advisor at ACSO, said "We welcome the government's commitment to harness the power of responsible data use and enhancing the digital use of personal identity information. We agree that online authentication, identity and eligibility solutions could increase security, ease of use and accessibility to public services.
"However, regarding complaints and redress, the consultation fails to outline explicitly which redress cases a digital identity governing body could become involved in. It is crucial that this does not result in gaps in accountability between scheme owners and the governing body and, consequently, consumer confusion regarding where to turn for redress.
"Appropriate, accessible and simple redress mechanisms are essential for members of the public whose data is inaccurate and who therefore need to know where to go should something require amendment. As the consultation states, ‘there is already a statutory requirement to respond to a request for rectification within one calendar month under data protection legislation, with possible extension if the request is complex or multiple requests have been received’. It is crucial that rectification is seamless and easy to access.
"While a digital identity solution is capable of reducing fraud, if it is not designed with the appropriate privacy and security controls in place, it could serve to increase fraud. The consultation provides a solid step towards recognising the importance of good design; however, there is little mention of the support administered to those whose data has been lost or stolen. In the event of fraud, the governing body should not only be required to tell users that their data has been lost, but also to support them in responding to this. This could include communicating with users what the cause of the mishap was, the potential impact on them, next steps they should take and any support available."
Elliott highlighted the need to ensure that the technology is accessible, attractive and trustworthy to all; "A number of actions should be taken to ensure this is the case:
- The trust framework should mandate practical rules for ensuring the readability of terms, such as achieving a certain readability score or summarising key points in a reasonable number of words to ensure it is largely understandable;
Help should be given to those potentially vulnerable people who have ‘thin files’ (i.e., a small digital footprint) to ensure they can access a digital identity. At present, it is estimated that 1 in 4 people living in the UK do not have a traditional form of identity;
A public-awareness campaign is needed to reassure and educate the public on the details and advantages of digital identities. This will be needed to unlock fully the benefits they can offer;
Information on how to access and use the digital identity must be provided to the public, not least to combat Britain’s digital divide. The Legal Services Consumer Panel estimates that 20 per cent of the UK population lack basic digital skills while around 9 per cent are considered to have no digital skills whatsoever.
It is crucial that digital ID technology is as accessible as possible to such consumers."
ACSO members can download the full submission from the members' area of the website.