When DHSC specified the NHS App’s features, it was was a near-certainty that GDS would (eventually) copy the game plan: a cross-GOV.UK app – a webview onto existing GOV.UK information and services – being almost inevitable due to the machinations, and lack thereof, by Whitehall Departments.
Unsurprisingly, in the closing weeks of a spending review, with new digital management, and after a crisis in which such an app probably wouldn’t have made much difference, but in a world where HMG wants to own vaccine certificates, and NHSX(etc) very much wishes not to, the GOV.UK ‘black’ app was announced.
The approach being taken will in all likelihood dissolve the ‘hard boundary’ between the NHS and government – but, of course, do nothing to actually help social care where that boundary is already blurry…
A GOV.UK app won’t provide anything an online GOV.UK service doesn’t do already – or will do, by the time you are ‘nudged’ to use it – but it will give the Cabinet Office new and greater powers over other Departmental services. And with these new powers will come (some) new responsibilities, such as for the hostile decisions Departments make in their own narrow interests (which our work elsewhere has found widely: e.g. 1A, 2A, 4D, 4E, 5E, 5J, 5L).
On the one hand, GDS’s excuse of “It’s not our service” will cease to be sustainable; on the other, the “One Login” for the (whole of) GOV.UK will give it a stick with which to rein in the worst of the Home Office / DWP digital divide…
Will the dark arts permeate the Black App? And since the answer is yes, where?
Cross-service tracking and analytics
The introduction of cross-service tracking and web analytics will allow unprecedented monitoring and investigation of causality and consequences, such as:
- Does being sanctioned cause you to look up food banks?
- How many people do that in the app each week?
Even if it chooses not to publish the statistics – as it really should for public services, paid for by public money, serving members of the public – civil society will be able to FOI official Government analytics to show how harmful a policy is, down to specific constituency level…
Also, when one service accessed via the Black App asks about a vulnerability, and when there is a ‘single view of Government’ via the app, will the legal position be that “all” of Government should then know about it?
- Will DVLA be permitted to maintain institutional ignorance?
- Will DWP?
- What about where one Department accepts a UK resident is a victim of modern slavery, but another Department on the next screen refuses to believe it?
- What about Settled Status?
Where will the balance of benefits between the citizen and state lie?
As Richard Pope highlighted in his investigation of the systems of Universal Credit, “are the advantages of digitisation being shared fairly”, or will Government’s focus on automation once again prioritise its own ‘efficiencies’ over those of the public – offering no substantive benefit to citizens beyond “Look, it’s an app!”.
User-hostile design choices
Typical of the world view of many we deal with, Home Office front line officers have demanded to see the e-mail that the Home Office itself sends out about Settled Status as “proof” of people’s Settled Status. Yet that e-mail clearly states that it and the letter attached to it are not proof of status.
We revisited the Settled Status scheme, where refusal to provide offline alternatives to a ‘digital first’ service is causing widespread difficulties, distress and discrimination – which could be avoided by something as simple as recognising paper credentials, which is the way Home Office officials appear to be treating the letter from Home Office in any case. Initiatives such as the ‘COVID Pass’ in the NHS App have demonstrated it is entirely feasible to provide a signed credential for people to hold on their phone at high volume events.
Of course, such user-hostile choices are not just made by the Home Office but across Government.
Those who encounter the greatest burden in one place will face it in many (Annex 2 and 2A). At some point, someone will have justified adding each one of the different procedural burdens that we list in Annex 5; sometimes those justifications may even have made sense. But some of those justifications will have included a Departmental assumption that it is the role and function of citizens and service users to satisfy the whims of the Department…
That those who encounter the greatest burden in one place face it in many is one reason we focused on parents of newborns in Annex 7: “Baby then bureaucracy – the paperwork of new parenthood”, where one would think (or at least hope!) that the policy intent would be closer to, “We’re keen to help, we just need to check a few things first”.
The choice of permissions for Geolocation
While many are accustomed to using them in their daily lives, apps introduce scope for unprecedented levels of surveillance. One of the things a permanently-installed app on your phone can do that a web page cannot do is permanent geolocation. While it’s impossible for a web page to track your location (‘with permission’, of course) when it is not open; an app can do so.
Our work on UC shows DWP will use any form of algorithmic cruelty it can find. Requiring UC claimants to submit to permanent geolocation is exactly the type of thing DWP would demand, and keep demanding, until it got permission. Could the Central Digital and Data Office and GDS, as a split leadership, reject those demands? (Noting the Home Office will probably find a reason to access geolocation too…)
In response to COVID-19, DWP figured out that the easiest option for DWP is to treat claimants like hostage takers and demand ‘proof-of-life’, with selfies holding up newspapers.
As an aside, when the postcode centroid algorithm (and the errors therein) is compared with the GPS location (and the errors therein), who will suffer? UC would rather punish claimants than admit systemic failings.
For these and many other reasons, prior to launch, GDS must therefore explicitly ban any geolocation that isn’t on an “allow once while using the app” basis – and for platforms without that as an option, GDS must design and implement a best-quality user journey which takes the user via their system web-browser to perform a one-time location and then return them and the single-use coordinates to the app.
Departments may be even less accountable for user hostile decisions than facebook or youtube, as the view of the Government’s internal ‘Fraud Profession’ is that citizen requests are frauds until proven otherwise, beyond doubt – and that the civil service never makes an error, until proven otherwise beyond a reasonable doubt. (And for the latter, such investigations rarely take place.)
The use of devices and device services to exploit users by underhand means in pursuit of power and profit has been led by Facebook. Unfortunately, unless abusive techniques are explicitly forbidden, Home Office and DWP acolytes will most likely see the ‘ingenuity’ of Facebook’s engineers as a playbook, and a feature list – not a recognition of the moral decrepitude of their monster factories.
Civil Service silos
That DWP is forced to accept a GOV.UK Account for Single Sign On via the Black App means it will also have to accept it via the main UC website – both because the app is at its core just a view onto a web page, and because it would be untenable to force people to only ever use the app if they first used the app.
As soon as the Black App is launched, absent formal monitoring and enforcement otherwise, any Department will be able to exploit the full range of sensors in any device on which it is installed. The delegated nature of services means the Home Office, DWP, et al. do not and will not need to ask for central permission; what the web view does will be entirely within their control, especially on Android where protections are weaker.
Meeting whose needs?
An app satisfies the CDO / CDDO / CDIO / CDEI / EIEIO / etc. need for the perception of institutional simplicity. Commentary on Twitter suggests at least some civil servants have read ‘Seeing Like a State’, which illustrates and explains how Governments do things because they make Government’s job easier, rather than necessarily helping the people they claim to serve.
In this context, Zacka’s ‘When the State meets the Street’ should also be required reading, as the business GDS is getting into with the Black App is front line service delivery for all of Government, at a level far deeper than just “meet user needs*”.
In terms of needs, both individual and institutional, and given so much time in public services is taken up by complex cases – those with past traumas causing current difficulties – what would a trauma-informed interface look like?
It’s unlikely to appear in the Black App, but it could well do somewhere else…
For more detail and background, see our core report, ‘Decoding the Algorithm and Data Choices in DWP’s Monster Factory’ and complete list of Annexes – of which these are most relevant:
- Annex 2: Risk Based Verification (RBV) – how RBV is used both by local authorities and across DWP, and how to examine its use (and misuse) in practice. Also how it is outsourced.
- Annex 3: Responding to Fraud and Error as a Government Profession and in Practice– Government has created a ‘profession’ out of fraud hunting; we examine the practical effects of the culture and practices of this ‘profession’ across DWP and more widely.
- Annex 5: Burdens upon Burdens: (December 2021)
- Annex 5A: DWP and health (April 2021)
- Annex 5B: DWP’s UC release schedule (March 2021)
- Annex 5C: DWP’s planning timescale (March 2021)
- Annex 5D: Digital failure – Home Office (April 2021)
- Annex 5E: HMRC’s CH2 form (June 2021)
- Annex 5F: Complaint numbers and tribunal losses (August 2021)
- Annex 5G: Access to Forms (August 2021)
- Annex 5H: Carers Allowance and Attendance Allowance (December 2021)
- Annex 5J: Settled Status Revisited (December 2021)
- Annex 5K: Changes to the UC Taper Rate (December 2021)
- Annex 5L: NCC1 form (December 2021)
- Annex 5P: A/B testing has legal obligations that are not being met (March 2021)
- Annex 5Q: A/B test example – two factor authentication for claimants (March 2021)