On 13 July 2021, the Trust Alliance provided a submission to the Australian Government’s Position Paper on its proposed Digital Identity legislation. 

We welcome the Government’s continued consultation in developing the Digital Identity Bill, which aims to expand the Digital Identity system in Australia. While we support the aim of the scheme, which is to improve access to government services, our submission highlights a range of issues that need to be addressed to ensure the Bill results in a more inclusive, safer, trustworthy and dignified experience for all Australians engaging with the proposed system. 

The submission specifically highlights that the Bill would benefit from:

• incorporating digital inclusion and ability strategies to ensure all Australians could access and benefit from the Digital Identity scheme
• improved interoperability of identity systems across governments, industry and the not-for-profit sector to reduce confusion and access barriers for citizens
• integrating support infrastructure for  groups at risk of digital exclusion through targeted onboarding support
• clarity on how children would be protected from harm, and
• adopting best practice around the creation and management of digital identity systems as outlined in  the Principles for Digital Development and the ID2020 manifesto. 

We also provided 38 actions or recommendations on specific issues raised in the Position Paper. These included:

• integrating a customer service standard to set out expectations to the citizen
• banning automated decision-making
• ensuring governance mechanisms includes a broad representation of society
• enhanced privacy safeguards
• strong data protection and storage guidelines
• review and appeal mechanisms available to citizens
• limiting biometric use to one-to-one matching, and
• using cryptographically secure, decentralised identity system in the design of the system to maximise portability and ensure citizens’ retained custodianship of their identity data.

A federated digital identity system for Australian citizens has the potential to improve access to government services. However, a poorly designed or executed system could harm citizens through misuse or malfunction. Addressing the issues raised in our submission would strengthen the bill’s public value. 

We look forward to the Government considering these recommendations as it refines the Digital Identity Bill.