Last week members of the BC government engaged in a media blitz to promote the proposed BC Services Card. As part of the blitz, BC’s Health Minister gave an interview to CBC’s All Points West to explain some of the proposed Services Card’s features. As a key Minister involved in the Services Card she understandably has been an outspoken advocate for the new initiative. Previously, BC’s Health Ministers have stridently argued that the Services Card would defray fraud, though this rhetoric has since been toned down: now the cards will remedy unknown levels of fraud, save unknown amounts of money, and facilitate undetermined kinds of data migration across government.

In what follows, I analyze the Minister’s interview with CBC to identify the confused and problematic nature of the Services Card, as it is being presented to the public. I start by noting an area where I think most residents likely support the government – some basic updates to the present CareCards – and then proceed to deficiencies in how the Minister is introducing the new Cards. I conclude by focusing on the frankly bizarre methods that the provincial government is using to ‘sell’ the card to the public and ask whether these cards could be a significant election issue later this year.

Areas of Agreement (?)

The key takeaway from Minister MacDiarmid’s interview with the CBC was that BC needs a new card for health issuance. Few would argue with the Minister’s claims that the health card is ready for a basic upgrade. I think that most BC residents would support increased protections, which can include things like actually giving health cards an expiry date, anti-fraud protections on the card itself, and a picture to hinder multiple people from using the same health card. These are all reasonable protections and in line with many other provinces’ cards. I think most people, myself included, can get behind these elements of the proposed Cards.

This said, without knowing whether there are significant levels of fraud, it is unclear whether all the proposed new protections are economically rational. Residents need this information so they can tell whether such basic security features exceed the costs of existing fraud. If the costs of the cards are higher than fraud-related saving then, with the new cards, BC residents would be paying more in protections than they would save in fraud deferral. Consequently, we should expect the government to make public how they accounted for the ‘full’ services card (integrated data management infrastructures, costs to third-party vendors to enable identity confirmation, physical card costs, etc) versus a ‘light but updated’ CareCard (with basic card protections, expiry dates, photo).

Again, I think that everyone can agree that having this basic costing information is incredibly important for the public to conduct an informed and rational debate over the fiscal merits of the Cards. Given that the provincial legislature will barely sit this calendar year it is more important than ever that the public be given the information so they can debate the issue themselves. The fiscal data is required information for debate. Without it, we sacrifice a fully honest and transparent discussion surrounding the appropriateness of a BC identity card.

Questions Abound

There are problems in stating that the proposed Services card will actually reduce fraud, or will protect the province of BC’s pocketbook. From the interview, the Minister readily admits that her Ministry doesn’t know how much fraud associated with CareCards exists today. For instance, Minister MacDiarmid notes that people who have moved away may still be using their CareCards, presumably in the provinces where they’ve taken up residence. If ex-BC residents are using their CareCards out of province then the host province delivering medical services will bill BC. The same applies if you have an Ontario health card and use it in BC, the Ontario government gets a bill, and vice versa for using a BC card in Ontario. It ought to be fairly apparent if non-residents are regularly using their CareCards in other Canadian jurisdictions over prolonged periods. Defraying costs associated with this type of misuse should be as simple as managing records that should already be in place. Adding expiry dates to issued cards, a relatively simple and effective improvement, would help to remedy these kinds of problems.

From the Minister’s interview we also learn that her department has (seemingly) either failed to conduct a costing analysis or, even more bizarrely, failed to provide the relevant memo to the Minster herself. Specifically, when asked how much the proposed Card would save the province she couldn’t provide a figure. Any figure. The Services Card didn’t materialize in the government’s mind overnight: the Card initiative represents  a core facet of an elongated, detailed, and technocratic government policy item. There have literally been years to evaluate the proposed Card and associated policies but it seems that the government has, to date, failed to conduct basic costing analyses.

So, while the Minister can tell the public that the Services Card and associated infrastructure(s) will cost $150 million or more, she can’t simultaneously explain how this infrastructure will lead to savings in excess of the Cards’ investment costs. This isn’t how most BC residents make major purchase decisions when it comes to upgrading their homes or investing capital in long-term projects: shouldn’t the BC government be engaged in basic economic competency already adopted by almost all economically-responsible BC residents?

Minister MacDiarmid also notes that the new BC Services Card will facilitate Internet-based engagements between government and citizens. The Minister does not, however, clearly outline the specific and detailed kinds of engagements envisioned by the government. This is odd: you’d imagine that an expensive technological infrastructure would be accompanied by public discussions of how that infrastructure will subsequently be used. Private documents, interviews, and government presentations revealed to policy insiders have shown just a few ways that the Services Card will be used: before you receive social benefits the Ministry of Education’s records might be queried by your social worker and, though rebuffed to date, the provincial authorities want access to data aggregated through the card. In essence, the card is to become a focus around which provincial data sharing will occur, letting the government build new and expanded databases, though the ultimate aims or goals of these databases aren’t being disclosed to residents at the moment.

While developing the initiative, the BC government was sharing residents’ information across Ministries while quietly changing laws to facilitate deeper data integration. The sharing was conducted under ‘research’ clauses in BC privacy law, though internal documents show that some BC privacy managers were worried that the sharing stood in violation of how those clauses are actually meant to be interpreted. The email records show how the same managers were prevented by Ministers from communicating their concerns to the Office of the Information and Privacy Commissioner; to my mind, it’s worrisome when individuals are forbidden to communicate with the governmental bodies established to deal with questions of privacy law.

Given that members of the government hold very definite positions about how this card will unify government services then why aren’t governmental representatives willing to talk about that degree of citizen surveillance when ‘explaining’ the card? Why have Ministries been so tardy in providing documents and assistance to the provincial privacy commissioner or civil rights groups?

The government’s outreach approach seems odd. If the government has run focus groups that saw members of the public respond positively to the Services Card then shouldn’t the government’s representatives be quick to trumpet all the benefits of massive e-government integration that their focus groups favoured? In essence, the Minister is leaving an open-ended ‘the card will be used to help you communicate with government’ statement instead of offering definitive ways that the card will be used. Her ambiguity isn’t necessarily the result of government not planning future uses, though it might be driven by the government’s fears that fully disclosing proposed uses could strike a negative chord amongst the electorate.

While I’ll be touching on this in more depth, it’s also important to note that the Minister stated that the cards would be more ‘secure’ than existing cards. This is partly true, insofar as anti-fraud and anti-reproduction techniques will reduce the ability to third-parties of falsely issue health documents. Importantly, a reduced capability isn’t remotely similar to stopping fake issuance or preventing medical fraud; security imposes resource and temporal delays on attackers, rather than protecting ‘the system’ definitively from attack. Further, the full identity infrastructure the BC government is deploying has not received a robust technical analysis. Indeed, in the interviews that were conducted by Adam Molnar, he discovered that security audits of a private vendor associated with the initiative (which had been paid for by the vendor itself) hadn’t been read by government officials who are driving this project. It also seemed as though the same officials failed to read a report prepared for the federal Treasury Board Secretariat about the vendor’s systems. In short: the Minister is telling the public that the new card is ‘secure’ but the implementors of the technical infrastructure seem not to have engaged in basic levels of due diligence.

A Bizarre Public Relations Move

Most government offerings rely on statements to the citizenry that ‘X is going to save Y or bring Z incredible benefit to the public.’ From the Minister’s interview I don’t see this kind of logic. The cards will be expensive. The government has no idea if they’ll save money. A core driver (anti-fraud) appears phantasmic at best, insofar as the government has no clue how much fraud there is, or might be. Finally, the proposed ‘integration benefits’ remain partitioned from the public domain, preventing BC residents from fully appreciating the government’s intention to massively share data about its citizens across Ministries. Quite frankly, this is a bizarre way of pushing out a major initiative; in an era of ‘evidence based policy’ the government’s proposed policy initiative has more in common with faith-based policy.

I suspect that the lack of forethought and strategic planning is based on the government’s presumption that the public just won’t care and, if they do, there simply won’t be enough time to act. Other core actors inside government who are advancing the Services Card hold an almost reverential attitude towards the cards: these individuals, seemingly, can’t appreciate why BC residents wouldn’t be in favor of the new systems if they just knew enough about the identity documents and surveillance benefits. So, we have strident advocates partnered with politicians that don’t think that the public will mind enough to stand against the new cards. This isn’t a combination of actors that engenders high levels of trust or confidence.

Importantly, even if the new cards are deployed they can be repealed. Identity cards were an important topic in the last major British election and were a determining factor in the change to a new governing party. If the provincial Liberals decide to forge ahead with their new identity schema and just keep issuing misleading public claims, instead of genuinely engaging in outreach or efforts to democratically legitimize their surveillance scheme, then we could reasonably ask: will their identity card boondoggle cost them the next election?