Cabinet Office consultation on making public services work for you with your digital identity - Which? response

Summary

Which? welcomes this opportunity to respond to the Cabinet Office consultation on ‘Making public services work for you with your digital identity’. The government is proposing an optional digital ID (the national digital ID) that will be a government-owned product in the form of a credential that can be held in the GOV.UK digital wallet covering attributes of name, date of birth, nationality and a biometric facial image. The consultation sets out that the government primarily intends the national digital ID to streamline citizens’ access to public services and support digital right to work checks. However, the government also suggests that the national digital ID could end up being used in consumer use cases (such as verification of age for age-restricted purchases like alcohol); so we believe it is important that the government considers outcomes for consumers and we find the lack of consumer recognition in the consultation concerning. Our response specifically focuses on consumers and consumer use cases rather than citizens or the wider public. A summary of the key points we make in our response follows. 

Consistent high standards across the entire market:

We agree that a national digital ID has the potential to offer benefits for consumers. This could be through more streamlined, frictionless services when attribute or identity verification is required in consumer use cases, such as verifying age for alcohol purchasing. It can also reduce the risks of loss or damage to important physical ID documents, as well as give consumers more control over their data through adherence to the principles of data minimisation and selective disclosure. It is vital that the national digital ID is held to at least the same standards as private providers accredited against the UK digital verification services trust framework (DVSTF).This will prevent the creation of a two-tier system where consumers may have different experiences using the national digital ID versus using certified private providers, yet currently DVSTF accreditation is not required of the national digital ID. 

Digital inclusion for consumers, and consumers’ experiences of creating and using the national digital ID:

We support the plan for alternative access routes (provided they are sufficiently secure), but also wish to highlight that digital exclusion in relation to the national digital ID can play out in two ways: it may be difficult to get and use the digital ID, or it may be difficult to access other services that rely on digital ID. Processes for creating, updating and deleting the national digital ID must be user-friendly and straightforward for consumers, and the onboarding process must be secure to prevent infiltration by fraudsters. We believe the proposal for a legal requirement for national digital ID users to inform the government of changes in their attributes is too onerous for consumer use cases. We believe that for consumer use cases, users should only have a duty to ensure their attributes are up to date at the point of use. It is important that the government considers and monitors consumer outcomes and use cases as it develops the national digital ID. This may help inform decisions about digital inclusion and redress, while also aiding considerations about which attributes to include and the processes for creating, updating and deleting the national digital ID.