Information Sharing and Identity Management...Challenges and Solutions
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1 Information Sharing and Identity Management......Challenges and Solutions Plan Design Enable
2 In a democratic society an individual should be able to manage the use of their identity in the same way that, say, an artist can control their creations and organisations defend Intellectual Property. INTRODUCTION This paper sets out the main challenges for public sector data sharing and identity management and proposes some solutions to these challenges. It identifies areas where central government has a role to play in facilitating this initiative. We also outline the Atkins approach to delivering a successful information sharing programme. 2. Information Sharing and Identity Management
3 The success of these initiatives relies on the ability to accurately identify people in different systems and to be able to share data to create information with integrity. CHALLENGES AND SOLUTIONS Background The recent Varney Report has called for transformational change to government processes to improve efficiency and provide citizen focused public services. Many complementary initiatives, including shared services, common infrastructure and a breaking down of traditional silos, are necessary to ensure these goals are achieved. The success of these initiatives relies on the ability to accurately identify people in different systems and to be able to share data to create information with integrity. fig 1 Key Varney Themes and their implications This white paper presents some of the lessons learned from experience that includes: ContactPoint (formerly known as the IS Index) ONS Citizen Information Project Partnership in Action Barnsley Student Finance Modernisation Welsh Assembly Government Social Care Index Information Sharing and Identity Management 3
4 These are the major hurdles that often confront attempts to share data or track the identities of individuals. Atkins has undertaken differing roles on these and other projects in the data sharing area, but our experience encompasses a significant part of the Cross Government Enterprise Architecture Reference Model (xgearm) as shown below: fig 2 Atkins Information Sharing Experience and CTO Data Sharing Model 4 Information Sharing and Identity Management
5 There may also be cultural barriers i.e. where there is a belief that the data from another area will not be suitable, or that the supplying party may be held to account for consequences of inaccuracies that exceed their own purposes. Key Challenges Atkins have identified a number of key challenges common to all information sharing programmes, and we have divided these into three groups: 1. Initiation challenges These are the major hurdles that often confront attempts to share data or track the identities of individuals. They are the big Political and small political issues that can sink initiatives at inception. 2. Implementation challenges These are the challenges now being tackled by the leading projects that are at various stages of implementation. 3. Operation challenges These are the issues that data sharing programmes have during their ongoing progress; they might include information governance or changes in political landscape. In this paper we intend to address the first two sets of challenges as these are most current. Initiation challenges The big three initiation challenges are: Political these are frequently characterised by the tension between civil liberties and government plans. Opposition can take the form of parliamentary opposition or civil (organised) reaction to what is almost always termed big brother plans political e.g. silos within or between public bodies, where the status quo is threatened or where the public good often requires expenditure to be made out of one budget and benefits are accrued in another budgetary area. There may also be cultural barriers i.e. where there is a belief that the data from another area will not be suitable, or that the supplying party may be held to account for consequences of inaccuracies that exceed their own purposes. Information Sharing and Identity Management 5
6 Political Challenge Clarity on what is permitted where myths as to what is permitted in law can obstruct progress For the Political challenge, Atkins recommends a twin approach of: Focusing benefits on the individual so, for example, there are benefits to individuals in telling government only once, in having information available to support health interventions, to provide financial assistance etc and, more generally, in both making contact with public services simpler and in reducing the burden on the public purse. This comes from focusing on the active meeting of citizen needs rather than the simple provision of services. Architect to leave the individual in control this is always preferable to designing centralised solutions that serve government efficiency but leave the individual powerless and perceiving a loss of control. In a democratic society an individual should be able to manage the use of their identity in the same way that, say, an artist can control their creations and organisations defend Intellectual Property. The term Identity Management is not really a good way to describe government s role, it has been suggested that it may be better to use the term Identity Assurance. For the small political challenges and on the issue of clarifying what is permitted, we are pleased to see progress is already being made through the Varney recommendations, recent moves from the ICO and the DCA, and the work of the CIO and CTO groups, so they are not elaborated further here. Work we have done in the local authority environment, linking social services and health sector interests showed that it was possible for a group of focused professionals to be shown how to work in a way that met the regulatory framework while meeting the needs of information sharing in the interests of the citizens. This is an encouraging sign that progress can be made. Implementation challenges Once initiatives move into implementation the following challenges appear:...the new identity and location of an adopted child must be protected and all links back to the old identity broken. Policy differences in information governance, business context etc between different government bodies Technology variety too much variety in the patterns of data exchange between major public bodies Information diversity too much diversity of information and information standards 6. Information Sharing and Identity Management
7 Common categories for shielding include individual under witness protection, transsexuals etc. Discussions between departments have revealed that each department and system operates different policies as to which records should be shielded and what shielding means in terms of viewing such records. Policy differences There are policy differences between public bodies and their systems that frustrate attempts to link systems or to exchange data between them. Some of the most important recent examples are described below: Different approaches to adoption of children In cases of clean break adoptions, or where there can be a risk to the child or to the adoptive parents from the natural parents, the new identity and location of an adopted child must be protected and all links back to the old identity broken. In at least two major Government systems, this is handled by simply over-writing the old name and address with the new name and address but crucially keeping the same identifier. This works where the systems are closed, but when data from those systems are shared with people or systems that have memory (for example DfES ContactPoint remembers past names and addresses for matching purposes) then the old and the new identities become linked. In addition, the identifiers used by both systems alluded to above are under consideration as General Purpose Identifiers (as defined by the Data Protection Act 1998), so they could become widely used identifiers that are retained between the old and new identities. In order for data sharing to work seamlessly across departments, a common policy for handling adoptions would be valuable. Such common policies will need a cross-government governance arrangement. Shielding records Most major databases have a means to protect records about individuals who are at special risk. Common categories for shielding include individuals under witness protection, transsexuals etc. Discussions between departments have revealed that each department and system operates different policies as to which records should be shielded and what shielding means in terms of viewing such records. Information Sharing and Identity Management 7
8 For most of us, our address is at the same time our residence, the place where we want letters sent to and the secure location where we want valuable items delivered. However for some there can, legitimately, be different addresses for each of the above purposes. While in isolation these differences in policy and processes may be appropriate, sharing information exposes the problem that a record shielded by one system may not be shielded in another, so the protection policy of one system can be bypassed by the policies of another. Furthermore, systems like ContactPoint will operate a safety-first policy and protect a record if any system supplying data to it indicates that the record should be protected. ContactPoint will therefore end up shielding an increased number of records and this will erode the benefits of the system. Again, for the security of individuals and for efficient operations, a common policy on shielding will be needed. Personal risk management Demographic information is currently protected at anywhere between Level 1 and Level 3 on the government Impact scale, taken from the Registration and Authentication document egovernment Strategy framework Policy and Guidelines (September 2002 Office of eenvoy). Systems that have adopted a level 3 protection will not share data with systems operating at a lower level of protection. But if demographic data cannot be shared, then data identities cannot be matched and no data can be shared! A single definitive guidance and policy on the sensitivity and protection of basic information such as demographic data is urgently needed. Data value is context-dependent All information needs to be considered in the context for which it has been entered. Take a simple example of an address. For most of us, our address is our residence, the place where we want letters sent to and the secure location where we want valuable items delivered. However for some there can, legitimately, be different addresses for each of the above purposes. And in the case of Higher Education students, there is usually one address for term time and another for vacation time. For some systems, like Government Gateway, posting letters to an address is part of identity verification, for others address is simply where non-sensitive notifications are delivered. The simple idea of exchanging change of address notifications becomes less simple when all of the above contexts have to be taken into account. Government Gateway security could be compromised if address changes were accepted from a source where address information is not strongly verified. On the other hand, no-one would want to send in two recent utility bills just to change the address for receiving their tax return. 8 Information Sharing and Identity Management
9 Technology variety There are fundamental differences in the technology and communications patterns across government systems. For example, the following departments each have distinct approaches to data sharing: ONS operates by periodically publishing datasets to a server and allowing approved systems to pull the data from the server during a defined time window. This relies on the user of the data to ensure the data they are using is current but the supporting infrastructure is relatively simple. DWP operate a batch extract of data and publish this to external systems. This ensures users are provided with current data whilst still needing relatively simple infrastructure. NHS the systems within the Connecting for Health spine operate by transactional query/response using their own Messaging Interface Manual. This ensures current data but requires the most complex infrastructure. There are fundamental differences in the technology and communications patterns across government systems. Where the sharing of data is between a very limited number of systems this diversity has been mitigated by agreeing which approach to take on a case by case basis. However complex and widespread sharing schemes such as ContactPoint and those proposed by CIP need to exchange data between thousands of data sources and diversity of that magnitude significantly adds to the complexity of these projects The use of technology alone cannot resolve these problems. There will also be communication style and cultural differences that will also need to be resolved. A centralised architectural design is needed to define a minimal set of styles that meet the current and projected range of data exchange needs across government. Such a design must include guidance in the form of approved patterns and rules for data exchange. Information Sharing and Identity Management 9
10 Examples include Health, which uses HL7 data standards, and Education, which has a significant investment in the Common Base Data Set standard. Both of these are significant industry sectors in their own right. Information diversity Information diversity has long been recognised as a barrier and the need for standards has been recognised and addressed, for example by the egif standards. What we are observing, however, is that there are large communities that have entrenched sector standards and where the investment in systems supporting these standards is very significant. Examples include Health, which uses HL7 data standards, and Education, which has a significant investment in the Common Base Data Set standard. Both of these are significant industry sectors in their own right. Migration of these large tectonic plates of standardisation will take considerable time and effort, simply publishing a standard is not enough. Funding for migration, or acknowledging the existence of interim standards and architecting for a small number of converters will be needed in order to smooth the path of data sharing. Government urgently needs to address the issue of information variety to at least ensure the issue stops growing and becoming more entrenched; again this should be address at a high level within xgea. 10. Information Sharing and Identity Management
11 But there are areas where Government can assist and provide a suitable environment for Information Sharing to flourish... SUMMARY AND CONCLUSIONS Government action is needed to address: Government Architecture - to coordinate point solutions, eg for citizen/government controls and for a number of common processes Directing migrations towards common information standards (more than establishing common infrastructures) Creating data exchange standards and standard translators, and funding migrations towards common data standards Policy recommendations Atkins recommends that the issue of policy harmonisation in relation to the basics of data sharing are recognised and a means to form and manage cross-government policy is instituted. What form might this take, what work is involved, and how long would it take needs to be resolved but it would include the following common policies; a common policy for handling adoptions would be valuable in allowing data sharing to work seamlessly across departments,. a common policy on shielding will be needed for the security of vulnerable individuals and for efficient operations, Such common policies will need a cross-government governance arrangement. We also see the need in many cases to create government-wide solutions architectures and for solutions architecture and policy to be better integrated within the public sector. In the case of a subject as complicated as this, a government-wide activity to architect the full solution to address change is needed, within which individual systems can use the parts relevant to their needs. Atkins advocates the enterprise architecture approach, as defined by TOGAF and Zachman, where a complete solution covering governance, people, processes, business and technical dimensions are developed as an integrated whole. The current Cross Government Enterprise Architecture (xgea) initiative seeks to develop this, but it needs to be developed hand in hand with policy. Policy sets goals but policy statement needs to be informed by the art of the possible in terms of workable process and technology. Sometimes legislation, primary and secondary, needs to be informed by and interwoven into the solution. Information Sharing and Identity Management 11
12 About Atkins Management Consultants Atkins Management Consultants (Atkins MC) is one of the leading management consultancy companies in the UK. Atkins MC is a part of the Atkins Group and our vision is to help clients to deliver value from their programmes of investment and change. We plan, design and enable the delivery of complex programmes for clients in the public and private sectors across the globe. Atkins is the largest multidisciplinary consultancy in Europe. The combination of Atkins position as a leading multi-disciplinary consultancy, its heritage of successfully delivering on some of the world s most complex projects and our capability in programme delivery, position us uniquely to ensure that your IT-enabled change really delivers. At Atkins MC, we enable our clients to make change happen. Clients value us because we speak their language. Atkins Euston Tower 286 Euston Road London NW1 3AT Telephone mcsolutions@atkinsglobal.com Atkins Ltd except where stated otherwise. The Atkins logo, the open A device, Carbon Critical Design and the strapline Plan Design Enable are trademarks of Atkins Ltd. Our Organisation is proud to be a supplier to the Office of Government Commerce (OGC) External Resources framework (ERF). design by designation.com
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