#notmydebt Inquiry- what should we be asking for?

Rosie has a degree in Sociology with a major project in public policy which analysed submissions to the Insurance Crisis Inquiry (circa 2002) and govt response to them and set this within a theoretical framework. Rosie also researched, documented & made submission to following recent Inquiries: Open Government Partnership Consultation, the CensusFail Inquiry,  PC Data Access & Use Inquiry, Privacy Act Re-Identification Amendment Inquiry and Data Retention departmental Inquiry.

Today the government released impressively thorough terms of reference to the Senate Inquiry into the Design, Scope, Cost-Benefit Analysis, Contracts Awarded & Implementation Associated with the Better Management of the Social Welfare System Initiative. And what a mouthful that is!

Submissions are due on March 22 with a reporting date for the Committee of May 10.

Terms of Reference

-the impact of Government automated debt collection processes upon the aged, families with young children, students, people with disability and jobseekers and any others affected by the process; -the administration and management of customers’ records by Centrelink, including provision of information by Centrelink to customers receiving multiple payments; -the capacity of the Department of Human Services and Centrelink services, including online, IT, telephone services and service centres to cope with levels of demand related to the implementation of the program; -the adequacy of Centrelink complaint and review processes, including advice or direction given to Centrelink staff regarding the management of customer queries or complaints; -data-matching between Centrelink and the Australian Taxation Office and the selection of data, including reliance upon Pay As You Go income tax data; -the process of awarding any contracts related to the debt collection system; the error rates in issuing of debt notices, when these started being identified and steps taken to remedy errors; -the Government’s response to concerns raised by affected individuals, Centrelink and departmental staff, community groups and parliamentarians; -Centrelink’s Online Compliance Intervention (OCI) and its compliance with debt collection guidelines and Australian privacy and consumer laws; -the adequacy of departmental management of the OCI, including: the adequacy of staff numbers to manage the workload associated with the OCI, including customer complaints, -what impact the roll-out of the OCI has had on other areas of work and whether resources have been diverted from other areas, -training and development provided to staff who are working on this program or in related areas (for example, telephony and complaints), -how the Department of Human Services and Centrelink are tracking the impact of the OCI rollout on staff, including stress and incidents of customer aggression, -any advice and related information available to the Department of Human Services in relation to potential risks associated with the OCI and what action was taken as a result, including feedback arising from system testing and staff, and -decisions taken in relation to IT systems and service design that may have contributed to problems experienced by Centrelink clients; and  any other related matters.

An Inquiry is where we need to not only document the scope of the problem but also put forward recommendations for how such problems can be avoided in future.

Submissions will be expected from the organisations lobbying on this issue including ACOSS, AUWU, CPSU, Welfare Rights, Legal Services, probably also the major religious charities that deal with the poor and unemployed such as Mission Australia, The Salvation Army etc. Political parties Labor, Greens, Pirate Party and  Independents may also provide submissions to this Inquiry given their public stance and there will be many submissions provided by individuals. There should also be submissions from experts in the area of data ethics and related fields to provide some direction and detail for policy making that can put an end to the kind of unethical, incompetent and under-resourced program now described as robodebt. Government agencies will also have been invited to make submissions.

An Inquiry is where we need to not only document the scope of the problem but also put forward recommendations for how such problems can be avoided in future. Much of the talk about #notmydebt to date has been around the scope of the problem with the media becoming more aware of the veritable impossibility of actually carrying out business with Centrelink even in response to their own demands and the question of whether the creation of false debts is a deliberate attempt to extort money from Australia’s most vulnerable or whether it is just a bad implementation of a worthy goal.

While researching and documenting the scope of the problem is a necessary step, at least some submissions also need to go further and consider ways of preventing the kinds of decisions that created the robodebt situation so similar calamities will be avoided in future.

Right now there is no process in place to ensure programs like the robodebt fiasco do not happen (obviously enough). This massive failure of ethics and information management follows immediately on the heels of the Productivity Commission’s planned overhaul of the data integration and sharing framework. The Productivity Commission needs to heed recommendations coming out of this Senate Inquiry with advice on how to insert appropriate tests into policy decisions that involve the use of public data.

The framework being planned by the Productivity Commission needs to include within it a process for testing that decisions taken by agencies and data integrating authorities (mooted by the PC as taking over from agencies in taking responsibility for data integration projects) are justifiable in a legal, ethical and practical sense. Without such input and recommendations, the Inquiry will be limited in its ability to stop or prevent future policy failures.

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