FCSA welcome the Government’s intention to harness the potential of new digital forms of identification. Digital ID is not something new, it has been a reality for a number of use cases for over a decade and there is significant potential for its application to reduce costs and burdens for; individuals, businesses, and the state.
The use cases FCSA can most effectively speak to is those relating to Right to Work Checks (RTWs), as well as Disclosure and Barring Services (DBS) checks. There is significant potential for Digital ID to make both of these types of checks cheaper, more efficient in a range of use cases.
A key principle should be that the ‘Data Subject’ is in control and decides who gets to see which data points, and that they are able to time-limit access. That is unless criminality has been detected, in which case it would be legitimate for authorities to follow evidence trails. Generally, data should only be accessed on a ‘need to know basis’, with the Data Subject in control of any master permissions.
There are a number of challenges that exist within Government, particularly around existing infrastructure and technical integrations to facilitate a better cross-government joined up approach. A key aim should be to make better use of the information already available to Government. Following a use-case-based approach to establishing what new information is required before seeking any will be key.
Whilst FCSA believe that changes do need to be made, and we are broadly supportive of increased use and ease of Digital ID, we believe that an approach that maintains respect for individual civil liberties is vital and that there is a clear and viable need and use-case for the collection and storage of any new data points.
