Challenges faced in undertaking digital transformation
This chapter details evidence regarding critical challenges to digital
- Cyber security, risk and resilience.
- The diversity of users and their needs:
Critical challenges to digital transformation
Systems architecture issues
Many submissions focussed on practical and technological challenges
facing infrastructure and platform design, including hardware legacy issues, as
well as complexity arising from the digitalisation of a diverse range of
government activities and services in compliance with the applicable
Submissions on infrastructure and platform design covered a variety of
- the need for a consultative approach to platform design;
a whole-of-government approach to standards;
- that systems must comply with administrative law principles; and
- privacy imperatives.
Several submissions emphasised that understanding the user's needs is
paramount when designing digital systems, and recommended the co-design and
user‑testing of proposed government digital services. Mr Chris Hamill noted the
need for digital services to be designed to resemble traditional services that
consumers are used to, both in terms of style and format, and in terms of
procedure, 'familiarity' being the key to engaging the less computer literate
or less confident consumer.
Ms Louise MacLeod, Senior Assistant Ombudsman, Operations Branch, Office
of the Commonwealth Ombudsman, agreed, stating the need for designers to
understand their users, and to build into the design of a system explanations
of what information is sought, and why:
so that people along the way understand what they have to
complete, why they have to complete it and the consequences for not providing
The Royal Australian College of General Practitioners (RACGP) commented
on the need for co-design, reporting that:
A previous lack of
general practice clinical engagement has resulted in the delivery of some
products which are not fit for purpose...
SCOA Australia identified a further ongoing, and potentially
intransigent design issue that needs to be accommodated in digital
transformation, being that government systems must be designed and built so
that they can actually be used by their intended users who may be relying on
old and outmoded devices:
Firstly, users may be
using a wide range of devices to access the system – Apple computer, Windows
computer...MacOS, Windows 7 – 10 Linux... iPhone...Android,...All these devices will be
expected to work with the government system.
The CPSU contended that co-design in the development of public services be
extended to include staff as well as the wider community, noting that employees
are uniquely placed to provide input into how public services can be improved:
and utilising the capacity and experience of the APS workforce will result in
better designed services.
DHS has advised that it has established a position of Chief Citizen
Experience Officer to focus systemic improvement of the user's experience with
the department's digital services:
[DHS] is also
actively applying behavioural insights to understand how and why people make
the decisions they do and using this knowledge to test and design more
effective digital services.
Furthermore, in relation to the Welfare Payment Infrastructure
Transformation program, Mr John Murphy, Deputy Secretary, Payments Reform, DHS,
, acknowledged 'it is not exclusively about digital':
We fully recognise that for many people digital is a real,
appropriate response but that a number of people, particularly those who are
vulnerable, need to continue to have access to the services that the department
provides day in and day out. Essentially, what we're also looking to do as part
of this program is ensure that the people who need access to our experts, of
whom we have many, are able to access those people in a very timely way.
The DTA promotes its Digital Service Standard (DSS), which articulates criteria
that agencies should adopt to establish a 'sustainable multidisciplinary team'
to undertake the development process, and recommends a user-centred approach to
Two submissions noted the need for independent reviews of systems
design. The Commonwealth Ombudsman described the need for an 'external
perspectives in the design, testing and implementation of new digital systems'. Mr Ian
Brightwell, who appeared in his private capacity, observed that agencies
currently undergo a limited number of structured reviews such as 'Gateway' or
the Implementation Readiness Assessments (IRAP). He recommended that review
data should be shared more widely, including being published on the DTA's new
program status dashboard.
The Office of the Cyber Security Special Adviser (OCSSA) [now the
National Cyber Security Adviser] and the Office of the Australian Information
Commissioner (OAIC) are concerned about design that supports trust on line. The
OCSSA recommended that cyber security be considered a core part of systems
design to strengthen trust on line, noting:
Security needs to be
embedded in all levels of systems architecture, in software and apps, as well
as applied to the end-points that public the use to access these systems.
The OAIC similarly recommended the adoption of a 'privacy by design'
approach to build privacy into systems and projects from the design stage
With respect to the design of automated decision making systems such as
the DHS' Online Compliance Intervention automatically generated debt letters,
the Commonwealth Ombudsman noted that the system must be consistent with
administrative law values of lawfulness, fairness, rationality, transparency
and efficiency. The Commonwealth Ombudsman noted that in 2004, the Australian Research Council
'recommended the establishment of an interdisciplinary advisory panel to
oversee automated systems'. The Commonwealth Ombudsman suggested:
One solution to this
problem may be for agencies rolling out automated decision making systems to
consider establishing advisory panels or delivery units to oversee major
digitalisation projects, which include external stakeholders, in particular,
the DTA, the Commonwealth Ombudsman, the Office of the Australian Information
Commissioner and the Australian National Audit Office in the earliest stages of
design and planning.
Ms Ward considered that the digital delivery of government services
requires recognition of the value of embedding information management
functionality into digital platforms and services. She considered that this
functionality needs to be considered at the outset of technical development,
rather than being retrofitted, to enable information to be properly managed. Ms
...that digital delivery of government services should include
information governance requirements and relevant whole-of-government and
whole-of-agency digital government services delivery project, noting that the
crucial role of information and data play in the delivery of trusted government
services and reinforcing requirements under the Digital Continuity 2020 Policy
that information management functionality be included in the design of digital
platforms and services.
A number of department and agency submissions demonstrated the complexity
of transforming to digital technology. Though the issues raised in the
submissions have a whole-of-government application, the committee were advised
that agencies each have their own particular challenges.
DHS advised that it made over $174 billion dollars in payments to
citizens in financial year 2016–2017. It dealt with over 700 million digital
and self-service transactions, with digital services being available 99.3 per
cent of the time. It has 349 service centres across Australia, with 239 Access
Points and 347 agents. It had 19 million visits to service centres, an average
of 77 000 per day, and over 52 million phone calls.
DHS explained the complexities it presently faces in seeking to
implement welfare benefits:
delivered as prescribed by numerous Acts of legislation that describe how
benefits and payments must be calculated and delivered.
As the Government
introduces new services and changes or ceases existing services, [DHS] needs to
amend its systems, procedures and resources to maintain their integrity. [DHS]
faces several challenges when implementing new or changed government policies.
- Policy initiatives that involve
legislative uncertainty and/or rapid implementation
- Ageing legacy systems that provide
day-to-day critical services yet are costly to maintain, are at end-of-life and
prevent rapid and/or agile policy implementation, and
- High demand on technical,
programme and project management capabilities, skills and resources.
Mr John Murphy spoke about joining DHS after a banking career of some 36
years. He reflected on the complexity of the digital task for the department:
I would like to reiterate what I said earlier: the environment
and the complexity in the government sector are far more pronounced than what
you would see in the private sector...
...Our challenges are, in no particular order: the redesign of
the business processes; the ability to implement the changes that we need to
make, and by that I mean the culture, the reskilling, the retraining of our
people, and the right-sizing of the department, by which I mean having the
right people in the right place; and then the technology. Certainly, as I say,
it's probably unfair to draw a direct comparison between government and the
private sector. My point would be that the expectations of customers have gone
up significantly. That includes being able to do things digitally, being able
to stay in the digital channel, and equally—I think we would all agree we would
expect—to be able to access services anytime, anywhere. You've only got to look
in the private sector. You have, generally speaking, more access and greater
access to various services outside of the normal business hours. The idea of
normal business hours fell away many years ago.
The ATO advised that its computing environment holds data securely for
25 million clients and partners. The ATO observed that it operates in a 'necessarily complex' environment,
referring to its systems' 'co-dependencies'. The ATO stated that the taxation
regime collects data from banks, states and territories, stock exchange
companies, employers, private health insurance providers, Centrelink and other
government agencies, and employee share schemes. It also interacts with the
superannuation industry including self-managed superannuation funds, tax
professionals, other government agencies, a variety of digital services
providers, and intermediaries including financial advisers, insolvency practitioners
and legal practitioners:
While our IT
infrastructure is extensive to support the vast array of systems, millions of
transactions and interactions needed to administer the tax system and
superannuation systems each year, we don't and can't do it in isolation. We are
integrated; our systems, our data, our technology, or legislative framework and
our infrastructure all have co-dependencies across the economic and digital
The circumstances of Home Affairs' are directly opposite to those of the
ATO in that it is aggregating its business systems, but is equally complex.
Home Affairs technologies represent critical infrastructure that allow the
department to protect and manage the Australia's territorial border. The
breadth of technologies is underpinned by a complex technology foundation of
networks spanning unclassified to top secret material, and storage data
infrastructure which is delivered by a range of models from in-house support to
fully managed commercial services.
Home Affairs' functions are undertaken 24 hours per day, seven days a week in
84 locations across Australia and 50 locations world-wide. It operates 250
SmartGates and kiosks, more than 3 000 CCTV cameras, patrol boats, surveillance
aircraft, 2 000 terrestrial and satellite capabilities, 660 detection and
inspection technology units and more than 11 000 personal defence equipment and
wearables located within 48 armouries.
Home Affairs submitted that it is managing complexity by:
dependencies between applications by developing independent business systems,
or decoupled domains, enables the ability to more effectively make changes to
business functionality and reduces the time to implement new functionality or
change business processes. Using this approach, changes to business policy,
process or functionality can occur without the need to impact or involve other
business systems. By aggregating critical business information into a single
service and providing this service to all business systems, each decoupled
business system gains by:
- Having access to a deeper set of
- Allowing effective decision making
- Simplifying and reducing
maintenance requirements over time.
Ms Ward identified a very different but equally significant complexity facing
Commonwealth agencies' digital transformation is the capacity to retain and
preserve Commonwealth records. She observed that Commonwealth records are being
created in a range of digitalised formats. The obligation on departments and
agencies in transferring material to the National Archives is to ensure the data,
including metadata, is transferred in a readable format. Ms Ward stated that the National Archives is aware:
That around 87 per cent of agencies have moved from paper
processes to digital processes, and we are also aware that data is being lost
every day—either not well-managed, can't be found or kept in locations that
aren't appropriate—and that access is rendered impossible both for now and the
A number of department and agencies' submissions demonstrated the
difficulties arising from 'legacy' systems, such as new systems being overlaid
on outdated hardware which in turn have been subject to ad hoc iterations of
updates and upgrades, as well as outmoded business processes, and security
vulnerabilities arising from old technologies.
Mr Ian Brightwell, who appeared in his private capacity, noted that ICT
program failure in the APS is due in part 'to poor backend infrastructure and
systems upon which to build online systems'.
DHS drew attention to challenges it faces in delivering digital
services, in particular that core ICT systems were not designed for modern
digital services, such that changes to these services brings risk of unforeseen
impacts. The DHS stated:
[DHS's] legacy ICT
systems supporting delivery operations are now over 30 years old and were
originally built to operate on a different scale...
[DHS] faces several key challenges in this area:
- The core ICT systems were not
designed for modern digital services;
- Any changes to these systems
brings the risk of unforeseen impacts, and
- Rules and processes are not
standardised across payments, and complex rules cannot be easily changed.
Mr Murphy summarised the legacy issue facing DHS:
But, essentially, the environment that we're working in is
one that was largely designed back in the seventies, eighties and nineties,
which was largely constructed around paper and telephones and largely based on
face-to-face interactions. I think it's fair to say that that mode of operating
has largely continued. I think we would all recognise that, in this day and
age—particularly around customer expectations of digital, simple, clear,
easy-to-use, safe and available anytime, anywhere—that is a very, very
difficult proposition for the delivery of welfare without a fundamental change.
Home Affairs stated that it will continue to sustain legacy technology
capabilities as they are progressively decommissioned and replaced over the
next 5–10 years. Home Affairs will actively manage the costs associated with
making changes and enhancements of legacy technology capabilities to minimise
the costs involved.
Mr Osmond Chiu, Policy and Research Officer, CPSU, reported the
difficulties facing APS staff who use the technology:
many of the ICT systems that APS staff are using are quite
old and outdated. The 2015-16 ICT trends report found that 44 per cent of the
government's major applications are over a decade old and that 53 per cent of
the government's desktops and laptops are past the end of their planned useful
life. So when you have very old ICT software and systems, it can often mean
that it takes a long time to log in and there can be massive delays.
Mr Alastair MacGibbon, NCSA, and head of the ACSC observed that legacy
systems are hard to protect against threats:
...an issue we have– and government is very much not immune to
[threats]—is the conflict of legacy systems. You have an application of a piece
of software that only runs on a particular type of computer. You can't upgrade
the computer system, because the software won't run on it. This happens not
just in government...as a consequence, you end up with a series of legacy systems
that are hard to protect. We know that newer systems generally have a lot of
the bugs ironed out of them. The latest versions of the software have patched
security vulnerabilities that previous versions haven't patched. If you're
running old systems that you can't update the software on, then it could be
that there are an increasing number of methods of attack, whether they're for
state actors or criminal groups. Government is not immune from that.
Cyber security, risk and resilience
Submissions from government specialists dealt with the need to embed cyber
security protections and protocols in the design stage of infrastructure and
software, being cognisant of the inherent vulnerability of internet based government
infrastructure and systems to malicious threats to their integrity. The
submissions also address risk mitigation and systems resilience.
The NCSA identified issues of cyber risk, stating that 'with the vast
opportunity of the internet comes risk'. The NCSA noted that the Cyber Security Centre's Threat Report of 2016
revealed the nature and extent of the threat against Australian Government
networks. The NCSA stated:
services move online there is a new imperative to embrace cyber security as a
core objective of digital transformation.
The NCSA also referred to the need for a culture of security, noting
that 'there is a prevailing tick box compliance culture'; that agencies
consider themselves secure if there is compliance with prescribed security
procedures, whereas 'compliance does not equal security'. The NCSA further stated
that 'security must be "baked in" to design and delivery' of digital
Mr MacGibbon observed:
There is no such thing as a totally secure connected system,
nor is there a totally stable connected system. Rather than looking at a binary
secure or insecure state, I think we really need to enter into a world of
asking about resilience and risk management.
On the issue of the management of risk, Mr Mike Burgess, Director, Australian
Signals Directorate (ASD), observed that the issue of risk-management of cyber
intrusions is a reasonably new circumstance:
I'm not familiar with the SFIA framework [Skills Framework
for the Information Age] from a management-of-your-cybersecurity-risk point of
view, and it's fair to say there is no decent framework internationally
recognised on how to manage cybersecurity risk effectively, because this risk
is really a young thing, insofar as the internet is really only 10 years old in
the benefit we're seeing in society, even though it's been around longer, and
there isn't yet a decent body of practice.
The NCSA offered this warning to governments and the public at large:
Security of personal
and financial information is not solely the government's responsibility. The
government can only protect what it possesses... Everyone must take
responsibility for their online security.
The ASD advised that one of its functions prescribed by legislation is
to provide material, advice and other assistance to Commonwealth and state
authorities on matters relating to the security and integrity of information
managed digitally. Under the Attorney-General's Protective Security Policy Framework ASD sponsors
the Information Security Manual (ISM), which assists government agencies to
apply a risk-based approach to protecting their information and systems:
The controls in the
ISM are designed to mitigate the most likely and highest severity security
threats to Australian government agencies.
The ASD's Strategies to Mitigate Cyber Security Incidents and the Essential Eight provide a prioritised list of practical actions
government agencies can take to make their information systems and online
services more secure. The ASD stated:
...the advice that ASD
provides to Australian Government agencies, when applied by an agency head as
the system owner, should result in digital services that have been designed
with due regard to security.
Dr Nick Tate, Vice-President, Membership Boards, Australian Computer
Society (ACS), considered cyber security to be a significant concern in light
of attacks now being conducted by nation-states as well as organised crime. He
stated that there is a need for dedicated cyber security task forces for all
major departments and a national focus on the issue. In this regard, Mr Mike Burgess, Director, ASD, stated:
There is, however, good advice out there coming from my
agency [about risk management], but what's missing is: how do senior executives
know the value of their data and ensure they understand who's got access to it,
where it is, who's protecting it and how well it's protected from a data
security point of view?
In response to a question from Senator McAllister, Mr Burgess advised
that the management of risk is not the issue of having skilled people, but
rather it is an issue of the skill of the chief executive and his or her
management team, in identifying and managing the risk effectively.
Mr Ian Brightwell, who appeared in his private capacity, recommended
that agencies separate the roles of CIO [Chief Information Officer] and CISO [Chief
Information Security Officer], with each having separate reporting line to the
Chief Executive Officer to ensure difficult security decisions are elevated
outside the ICT area of an organisation. As to the CIO role, Mr Brightwell said that CIO should not be lower than one
level down from the CEO or agency head level because the responsibility rests
at the CEO level:
Because the role of the CISO, I would argue, is largely
around audit control and ensuring all the controls for security are in place.
Largely, it's the CIO who has the job of implementing those cyber controls and
the CISO is going to look at those and look at other controls managed by other
levels. You've got to have them as far away from the people doing the job so
they can effectively be responsible for reporting their efficacy in
implementation. If they're one and the same person, no-one is ever going to
find out failure.
The ATO advised that it maintains an expert in-house capability to
conduct cyber-security resilience testing against ATO assets. The ATO testing
team are industry certified and have knowledge of ATO systems. Mr Ramez Katf, Second Commissioner and Chief Information Officer, ATO, further
advised that the ATO has established a security operations centre to
specifically address cyber-security threats.
DHS advised that it has established a Cyber Security Operation Centre
and has significantly enhanced its cyber security monitoring, security threat
intelligence, rapid detection and security incident response capability. Mr
Charles McHardie, Acting Chief Information Officer, DHS, reported that in March
2017 the ANAO had assessed DHS as being cyber-resilient across all its
Submissions identified privacy as a significant issue for the successful
transformation of government services. Submissions from government privacy
specialists dealt with the need to embed privacy principles and protections at
the design stage of infrastructure and software, recognising and accepting that
protecting citizens' privacy is a critical enabler to the government's
transition to the digital delivery of government services. A number of
submissions representing citizens' interest have raised the critical issue of
the need for a more sophisticated approach to digital identity in light of data
The CPSU noted that there is a real risk that the transformation of
digital delivery could be derailed because of community concerns about privacy
and digital rights. The CPSU highlighted widespread community concern about the
ABS' collection and storage of names in the 2016 census.
COTA Australia (COTA) noted that older people have a strong belief in
the importance of the privacy of their personal information. In order to engage
this cohort, governments must actively engender confidence that the systems are
safe and that information is protected. COTA Australia recommended regular risk
assessments and periodic audits of privacy protection procedures, with all
breaches being reported to Parliament.
The Federation of Ethnic Communities' Councils of Australia (FECCA) and
COTA also highlighted that confidentiality is an issue with older Australians, people
with disability, and culturally and linguistically diverse (CALD) communities
where they may be reliant on third parties to whom they must disclose sensitive
personal information if they are to engage with government agencies on line,
through which process their privacy is breached, and the third party may be
placed in the position of a conflict of interest.
The NCSA has acknowledged that trust and confidence in operating online
are the salient factors to successful digital transformation:
...the potential for digital transformation and digital
delivery of government services depends upon the extent to which the Australian
people can trust and feel secure online.
The OAIC recommended the use of privacy impact assessments (PIAs) to
provide a systematic assessment of a project that identifies the impact the
project might have on the privacy of individuals. The OAIC also advised the
development of the Australian Public Service Privacy Governance Code (Code) which is to come into effect on 1 July 2018. The Code will set out
specific requirements and practical steps an agency must take to comply with
Australian Privacy Principles 1.1 (APP) (those include reasonable practices,
procedures and systems in place to comply with APPs). The Code requires an
agency to undertake a PIA on 'high privacy risk' projects.
DHS has advised that its operational framework is guided by its
significant digital services.
A number of submissions considered the security of a digital identity to
be a significant enabler in the transition to digital government.
SCOA Australia said that a major issue contributing to the way data is
used is the ability to positively and uniquely identify individuals. SCOA
Australia advocated the introduction of a unique individual identifier on the
basis that current identifiers are no longer sufficient. SCOA Australia contended
that the lack of a strong identifier has a significant cost, often unheralded:
attempt to data match and data mine large data sources irrespective, with the
matching attempt on name, address, birthdate and other descriptive data. The
twins, Mary and Margo Smith, therefore spend their lives being mistaken for
each other, especially if they share a house and an occupation.
On this point, Ms Ward referred to a Productivity Commission report that
considered data and datasets as a value to the economy and the community. In that context, Dr Tate, ACS, drew attention to the potential dangers of the
government's open data initiatives to privacy using apparently de-identified
data. Dr Tate observed that data linking tools are such that it is difficult to
keep data anonymous. Furthermore, Dr Tate considered there is a need for a
framework for de-identification of government data, especially medical data:
...it is possible to take data from a whole range of different
sources, not just medical ones, but often sources you wouldn't expect, and put
them together and say, 'Hang on, now we can possibly work out who these are'. I
don't know how extensive it is. But the initial work on that has certainly shown
that it's possible...
The ATO noted that taxpayers can now choose voice biometric
authentication and cloud authentication and authorisation to establish proof of
The ATO also stated that it will continue to invest heavily in securing taxpayer
information through robust identity authentication and authorisation platforms:
Increasingly the risk
of identity theft in online and digital interactions needs to be anticipated,
monitored and mitigated as fraudsters become more sophisticated in their
The ATO advised that it is continuing to invest heavily in securing
taxpayer information through robust identity, authentication and authorisation
platforms. It flagged the Tax File Number as a main identifier. It has also
introduced the option of voice biometric authentication; and the use of cloud
authentication and authorisation; and the linking of an Australian Business
Number with myGov accounts.
The DTA stated that it is working with agencies, other jurisdictions and
the private sector to develop the GovPass program, to produce a common model
for verifying data that can be used across government:
To complement the GovPass program, the DTA has developed the
Trusted Digital Identity Framework, a comprehensive set of rules, policies and
standards that will set a nationally consistent approach to accredit, govern
and operate identity across the digital economy...The framework will be extended
to address non-digital identity for individuals to allow alternate pathways for
those unable to complete identity verification digitally.
Mr Peter Alexander, Chief Digital Officer, DTA, advised that myGov has
now has 12.5 million active accounts. He further advised that the DTA is looking
to change the authentication process for myGov to build in the 'Tell Us Once'
service, and payment and notification utilities. He also advised that the
Trusted Digital Identity Framework is nearing completion; it will be a common
framework across government which covers use of identity for digital services;
the use of non-digital identities in a digital world for those without a
digital identity to interact with government, and also an 'acting on behalf of
On 7 May 2018, Mr Gavin Slater, Chief Executive Officer, DTA advised
the committee that the DTA had received $60M in the recent budget to work with
agencies for the next phase on the development of a digital identity.
By October a system will be up and running that will allow
people to apply for and receive their tax file number. Over the following 12
months the capability will be rolled out to a number of other high-volume
government services, giving more than 400 000 people the opportunity to test
The diversity of users and their needs
Submissions emphasised the diversity of needs and circumstances of the
Australian community which must be accommodated in the design, delivery, and
ultimately, the acceptance by the public of government delivering services
online. A number of submissions expressed dissatisfaction with the government's
performance in the delivery of online services.
A number of submissions focussed on the need for inclusiveness, and
particularly the need for the government to maintain traditional methods of
dealing with citizens to accommodate sectors of society who are not digitally
literate. Submissions concerning website design focussed on the user perspective and the
need for user-friendly websites through consistency in screen presentation and
language across the whole-of-government sector.
Public expectations of government
in digital transformation
A number of submissions have expressed dissatisfaction in the
government's delivery of digital services. Mr Chris Hamill, private citizen,
...I think it's fair to say the government does not have a
great track record when it comes to 'going digital'...
It makes no sense to build a digital service for the nation,
if that digital service can't handle the nation.
COTA Australia has made a similar point, expressing concern over the
quality and reliability of systems used to deliver government services:
COTA views customer experience as a key quality domain in
online services. In turn, this is comprised of response time, user
friendliness, ease of access and availability and responsiveness of customer
support. Feedback that COTA has received indicates that current online
government services have far to go in this area of performance'.
Many submissions stated that the success of digital delivery of
government services is critically dependent upon the government's capacity to
provide a secure and user-friendly service, accessible by all sections of the
community, and especially the most vulnerable who are the most likely
recipients of government services.
Submissions identified categories of vulnerable Australians, and the
barriers each group faces in interacting with the government on line. The
categories identified as vulnerable are older Australians; CALD communities;
people with disability; people on low incomes; rural and remote communities; remote and Indigenous communities; homeless people; and small business.
COTA contended that digital inclusion is just as important as privacy
It is just as important (and challenging) to understand and
address inclusion as it is to ensure privacy and security when building
government digital platforms, service delivery models and business practices.
Given that many government programs are specifically targeted to disadvantaged
and vulnerable, it is essential that delivery to be fit-for-purpose.
The barriers all categories face are a lack of computer literacy, and
affordability issues. Homeless people and those in rural and remote Australia face the additional
barrier of availability of internet access, and network availability and coverage
is an issue for those in remote Australia. A lack of services have led to poor literacy and access for CALD and Indigenous
Older people are reluctant to engage in the online world, having
significant concerns with security and privacy. COTA observed:
COTA hears from many older Australians that they hold strong
belief in the importance of their personal, financial and medical information.
Recent research reinforces this with the finding that older people are more
likely than younger people to take steps to protect their personal information.
Issue related to privacy and security can create anxiety for
many older Australians...To engage this cohort in the transition to digital
systems government must actively engender confidence that the systems are safe
and information is protected.
COTA Australia noted that Australians over age 65 are increasingly
vulnerable to scams, particularly those involving the loss of money, as well as
an emerging trend of threat-based and impersonation scams representing to be
from government agencies.
The retention of traditional
methods of engagement with citizens
SCOA Australia and COTA noted that government processes must recognise
that there will always be Australians who cannot or will not use an automated
process to interact with government. Mr Hamill advocated the need to maintain traditional methods of service
delivery concurrently with digital delivery, on the basis that there are many
Australians who cannot or will not engage in digital government for a range of
COTA referred to the importance of inclusiveness. It supported the
DTA's Digital Service Standard's recognition of the importance of digital
The Australian Government has acknowledged the importance of
digital inclusion in its Digital Service Standard, stating that the services
'need to ensure they are accessible to all users regardless of their ability
and environment'. This high-level principle acknowledges government
responsibility to all citizens and recognises it is increasingly evident that
digital exclusion can further exacerbate the social and economic exclusion
experienced by vulnerable Australians.
ACCAN expressed a similar view that:
As traditional points of contact such as shopfronts and call
centres give way to the Government's new digital channels, millions of
digitally disconnected consumers will need to spend more time engaging with the
government – exacerbating their social exclusion and the impacts of Australia's
digital divide. Without taking positive action to eliminate barriers to
universal digital access, the Australian Government risks alienating millions
of vulnerable consumers who are effectively denied the opportunity to engage
with crucial services such as healthcare, welfare and social housing – all of
which are increasingly mediated by the internet.
COTA also recommended the Australian government ensure appropriate,
sustainable and adequately resourced legacy systems, including face-to-face,
phone and paper based communications at no extra cost to the consumer are in
place for people who are unable to access digital services. SCOA Australia noted that 86 year old Mrs Smith who has never used a computer
must be catered for. ACCAN similarly supported the retention of non-digital points of contact until
there is universal access to digital technology in Australia, as does Mr Hamill, who observed that the non-digital alternatives should not
...unreasonably inefficient, slow or unreliable, compared to
their digital versions.
The CPSU argued that the community choice of service delivery must be
mandatory noting that government and agencies maintenance of the option of
face-to-face and other delivery methods is 'vital' on the basis that not all
members of the community want to, or are equipped to access government services
digitally. In an answer to a question on notice, Mr Tull, Assistant National Secretary of
the CPSU expressed concern that government business processes have been
designed to push citizens onto online services:
The role of DHS staff has been changing from helping the most
vulnerable and disadvantaged Australians, to implementing business processes
that many in the community perceive are designed to make access to financial
support from the government as difficult as possible.
In its submission, the Tangentyere Council Aboriginal Corporation stated
that the transfer from the existing Centrelink portal to myGov needs to be
Future service delivery should not oblige individuals with
poor literacy and numeracy; limited English; poor computer literacy; limited
access to information technology; and limited internet to access Centrelink
services via the internet. Individuals should not be obliged to create email
addresses or purchase mobile phones unless they have the capacity to use and
maintain these devices and services in a sustainable manner that is not open to
exploitation. Centrelink in particular needs to continue to operate Centrelink
agencies in remote areas and for language speaking Aboriginal in a manner that
is appropriate and accessible...
Mr Murphy of DHS advised that the Welfare Payments Infrastructure
Transformation program is not exclusively about digital:
We fully recognise that for many people digital is a real,
appropriate response but that a number of people, particularly those who are
vulnerable, need to continue to have access to the services that the department
provides day in and day out. Essentially, what we're also looking to do as part
of this program is ensure that the people who need access to our experts, of
whom we have many, are able to access those people in a very timely way.
The issue of website design is closely inter-related with the public's
expectations of government; that the user as the ultimate arbiter of the
success of the new technology must be at the forefront of website design. Many
submissions focussed on the confusion and frustration citizens face when they
are required to provide the same information to different departments and
agencies, all of which have different web designs, some of which are better
than others. Submissions focussed on the need for a whole-of-government
approach to website design and data collection.
SCOA Australia observed that, as data is the basis of policy, there must
be a consistent approach to its collection, as well as the application of
The data that Government uses should be defined,
standardised, retained and maintained of a whole of Government basis by a
central agency, most probably the ABS.
FECCA advocated the use of consistent icons and layouts across all
government websites to enable easier navigation of different agencies' websites
by users. Mr Hamill recommended that the layout of digital services be designed to
resemble the traditional versions consumers are used to, both in terms of style
and formats, noting that the less computer literate can become confused if the
format deviates from what they are used to.
The Commonwealth Ombudsman commented that:
A key lesson from the [DHS Online Compliance Incident – robot-debt]
experience is that the design of the online platform may have a significant
bearing on the launch of a new process.
Seemingly micro-level issues of design may have significant
consequences...What icon should be used? Should the phone number appear
prominently on each web page? This may determine whether people access help at
the critical points or instead give up in frustration...
The RACGP noted that standard terminology, including the use of
structured data and national interoperable standards are vital to the safe
sharing of digital information.
In relation to DHS's 'Cuba' child care payments operating system
replacement project, Ms Bridger, General Manager, Child Support and Redress, DHS, advised that a key
lesson learnt by DHS during the project was that users must be very tightly
intertwined with not only the program or design, but also the testing,
trialling and iteration of any initiative. She further advised that recent
experience of having the users involved allowed requirements to be acquitted
Mr Charles McHardie, Acting Chief Information Officer, DHS advised that
DHS had recently established a new position of Chief Citizen Experience Officer
to look after design change from the public perspective.
The DTA stated that it is developing a whole-of-government design system
in collaboration with a community from across the government
The design system works like a catalogue of reusable design
components, including code, that can be used freely by agencies.
This brings consistency to the design of government websites
and services...This empowers agencies to transform their services efficiently,
bringing usability, accessibility and consistency to the forefront.
Data storage security
Submissions indicated that data collection and data storage are a very
sensitive issue for users, the concerns being demographically based.
COTA noted that older Australians are concerned about data security
where data is held at third party data 'cloud' centres). 'Cloud' is a term used
to describe a global network of servers, each with a unique function. The cloud
is not a physical entity. It is a vast network of remote servers around the
globe which are hooked together and meant to operate as a single ecosystem.
These servers are designed to either store and manage data, run applications,
or deliver content or a service... Instead of accessing files and data from a
local or personal computer, it is accessed online from any internet-capable
device—the information will be available anywhere ...and anytime it is needed.
COTA recommended regular audits to ensure centres meet performance
levels relating to security, with all breaches of security being reported to
the Australian Parliament and the Australian National Audit Office.
FECCA accepted the need to collect data for digital delivery of
government services, and encouraged data collectors to use secure storage
methods, noting that transparency and accountability will garner further trust.
SCOA Australia stated that data should be retained and maintained on a
whole-of-government basis by a central agency, but also makes the additional
point about the location of cloud storage:
concerned about whether their tax data is stored in Canberra or in Dallas?
AusAccess advocated that proper protection of data held by the
Australian government means cloud computing centres that are for government
data only; are within Australian borders; are Australian owned, and staffed by
Australians who have a security clearance. AusAccess recommended
that the decision to grant 'protected status' to a multinational cloud service
provider should be elevated to a cabinet or parliamentary level, taking the
The data of
Australians held by government should never be subject [emphasis in the
original] to the actions of any foreign government.
The AIIA noted the complexity and lack of transparency of the
Information Security Registered Assessor Program (IRAP) arrangements
administered by the ASD. Under the IRAP arrangement, ASD will certify an
assessor who, once certified, is qualified to assess the implementation,
appropriateness and effectiveness of an organisation's systems and security
controls. The AIIA stated:
are complex, time consuming and costly and most critically not transparent or
responsive to industry attempts to be more actively engaged in the process.
While this has obvious impacts on industry, more importantly, it is inhibiting
the operation of an effective and competitive cloud market across government
and undermining the government's broader procurement agenda.
The DTA explained that it is developing a secure cloud strategy to
increase government understanding and adoption of cloud services:
The strategy will
address a number of areas to encourage government adoption of cloud, such as
promoting cloud in a government context, building confidence in compliance and
streamlining assurance processes, creating shared capabilities, guiding
agencies to transition to the cloud, and working with industry to make cloud
offerings more comparable and easier to adopt.
In an answer to a question, the ATO has advised that it uses cloud
storage, however, the ATO was adamant that it would never put its cloud
services in an overseas data centre. The ATO stated that it maintains absolute
control over the data centres the cloud services are offered from. The ATO
confirmed that its contracting arrangements are that data be physically stored
somewhere in Australia.
The ATO advised that three of its eight applications are available by
cloud and are benefitting from improved availability. The ATO stated that it
continues to leverage cloud to improve availability of key applications, and
will continue to work with the DTA on future cloud policies of strategies.
DHS similarly confirmed that its cloud services are located onshore in
We as a department are a very small consumer of cloud based
services. We have a very large on-premise [storage] in both of our large data
centres here in Canberra. All of our customer data is kept on shore in both of
those data centres. They are what are known as ASIO T4 accredited data centres,
so they can handle data up to the secret national security classification. The
only cloud services we are using are some add-ons to assist things such as
website representations et cetera. We are not moving any customer data
Mr McHardie further advised that it has embarked on a program to be able
to access cloud based services, known as the 'elastic private information
cloud' program (EPIC). The program has been established so that DHS can shift
load across its low, mid and mainframe platforms in a more dynamic fashion, but
also allows DHS to start the work which will enable DHS to access more cloud
based services where appropriate:
It may be to use some cloud based storage, because it's very
cost effective. But you should only consume it if you've done a proper risk
based assessment and you know exactly where that data is going to be stored.
The DTA may want to say a bit more about that approach.
Mr Peter Alexander, Chief Digital Officer, Digital Division, DTA
referred to the security and privacy regime currently in place through both the
ASD's Information Security Manual, concerning how data is stored, the
Australian privacy principles concerning the storage of people's private and
personal data. The obligation imposed by that guidance is that agencies must
'control' the data:
...Control then has implications on knowing where it's stored,
not putting it in the cloud, when we're talking about people's individual data.
But we also have a set of security requirements.
Mr Alexander further advised that the DTA has built a cloud strategy set
of principles and policies for what agencies can use cloud, and how they do it.
The DTA is also examining whole-of-government hosting. DTA intends to collect
data on what departments and agencies are currently doing to obtain an overall
picture of Australian government hosting arrangements. The DTA sees great
advantages in obtaining cloud technology and public cloud services, but notes
those things come with risks around privacy and security.
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