Response to the consultation on the data sharing for identity verification services

(27 February 2023)


I write, as a member of the public and as a small businessman, to provide my response to the consultation on draft legislation to support digital identity verification services.

Before I answer the consultation questionnaire, I will make some general remarks about the subject of this consultation, about government consultations in general, and about government today as a whole. The survey front page exhorts: “Please be as open and frank as you wish.” I have chosen to take that exhortation at face value! Some of my friends may think I am putting my head above the parapet by saying these things. But so be it.

I will begin by saying that over the last 40 years or so, the way in which the UK government has treated the people it is supposed to serve has gone from bad to absolutely atrocious. If there are any half way decent people still left in government, they need to make themselves aware, quickly, of how dire the political situation now is for the people of this country. And of the need for radical change for the better, both immediately and in the longer term.

The subject of this consultation

Mr Burghart talks in his Foreword about government driving “inclusive digital transformation.” I retch when I see words like transformation used by government to describe their policies. I am a human being. I am what I am; I do not either need or want to be transformed in any way. And any attempt to transform me into something I don’t want to be will be resisted with everything I’ve got.

My own experience of “digital transformation”

As to “digital transformation” in government, my experience, as a small businessman, of communicating digitally with government has been extremely negative. For example, when HMRC withdrew its acceptance of cheques as a means of paying corporation tax, and demanded a digital form of payment, I picked what appeared to be the least onerous option, and paid by cheque through the Post Office. The result was that someone in the Post Office got visibility of the cheque, and attempted to forge five cheques on my business account. The effect of “digital transformation” in this case was to increase the likelihood of fraud.

After that experience, I got a company debit card, which I used only to make company tax payments. But now that is no longer viable, since HMRC has imposed a charge on payments by company debit card, which it did not previously. To force people to pay digitally, then to make them pay for the privilege, seems to me an act of bad faith. My work-around is to pay by personal debit card, then to re-imburse myself from the company; but this is a considerable administrative overhead.

As a third example, now that all VAT returns have to be done via Making Tax Digital, I am no longer able to submit VAT returns myself. I have to do it through my accountant, who charges for the service. That is a cost to me, which would not have been necessary if government had not imposed its insane idea of “digital transformation.” Personally, I’d go back to sending forms and cheques through the post, if I could; it’s less costly, and far less hassle than trying to do things digitally.

My view of technology

I am no anti-technology freak; I am a technologist myself! I am willing to use any technology if it brings a benefit to me, and is both usable and affordable. But I will never willingly use a technology that, overall, is a negative to me. And I very strongly resent having tried and trusted technologies discontinued, in favour of things that don’t work for me.

I find myself becoming increasingly reluctant to use the Internet for financial transactions, mainly because of the hassles of logging in to one or another service. And the problems when your computer fails, and you need to set up all your accounts from scratch on its replacement.

The system, whereby you have to field a phone call from the bank before you can complete the transaction, has made things worse. Moreover, since I choose not to have a mobile phone, I am now unable to do any transactions over the Internet from anywhere except my home.

I should also note that, on the two occasions when I have been asked to do on-line identity verification through one of the providers of such services, they have not been able to complete the verification. One of these was when I tried to activate my state pension on-line. The verification failed, and I had to send the application by post instead!


As to government consultations in general, I do hope that I am not wasting my time here. For I have noticed a very strong tendency for government in recent years just to “go through the motions” of consulting the people they are supposed to be serving. They do not take any account of, or even acknowledge, the points made by those whose views are not in line with the government agenda of the day.

An example was the 2021 “consultation” on “de-carbonizing the economy,” to which I submitted a 56-page response debunking the case for any kind of de-carbonizing action, and highlighting the huge negative impacts of such action on the quality of life for ordinary people. My views, and the views of those like me, were completely ignored, and the upshot of the “consultation” was that the date for banning the sale of new petrol and diesel cars was brought forward from 2040 to 2030.

Two more examples just as egregious have been: The implementation of the London Ultra Low Emissions Zone, despite (as we only found out some years later!) two-thirds of the people who responded to the “consultation” having been against the scheme. And the recent case of the Oxford “15-minute city” and traffic restrictions, still going ahead despite 90 per cent of those who responded to the “consultation” being opposed to the schemes.

These are, in my view, all instances of extremely bad faith by government towards the people. Government should never, ever be dishonest towards the people it is supposed to serve. In my view, dishonesty by any government official towards the people – for example, such as Boris Johnson showed over the Partygate scandal – should be a dismissal offence. And should lead to a lifetime ban from all further employment by government.

Moreover, the timeframes for these “consultations” are repeatedly being telescoped. This consultation had the period in which comments could be submitted restricted to just eight weeks. The road user pricing “consultation” in London allows even less time; just 30 days.

Government as a whole

Which brings me to some more general thoughts on government. I feel anger, contempt and hatred for government today. For its politicians, officials and hangers-on, and for just about everything it does. My level of trust in government is now well below zero. Indeed, my position is that by default, I expect the great majority of what government tells me to be lies, distortions or misinformation.

I also feel that government does not trust me, and does not have any concern for me, for what I think or for what I want. I am coming more and more to think of government as my enemy. And I know that I am not alone in these feelings.

Government is supposed to be for the benefit of the governed – of all the governed. As John Locke put it, it is for “the good of every particular member of that society, as far as by common rules it can be provided for.” And it only has any valid authority when it has the consent of the governed.

I have now reached the point where government has lost, not only my trust and my respect, but my consent too. Further, I have not voted in a general election since 1987. Because, simply put, there is no-one worth voting for. All the political parties that have ever had power are the same-old-same-old pro-establishment, anti-human criminal gangs. This, and the consultation examples above, show that any pretence of “democracy” from government today is a mockery.

Further, I find most of the things that government wants to do to the people it is supposed to serve to be abhorrent. To give just four examples: First, they want to force on us destructive green policies that are not justified by any evidence, or by any objective cost-benefit analysis. Second, they have sought to force on us COVID vaccination passports, so making pariahs out of those of us who are conscientious objectors to unnecessary medical treatment. Third, they violate our human rights and civil liberties. Such as impinging on our freedom of movement, freedom to protest, and one of our most fundamental freedoms of all, freedom of speech.

Fourth, they seek to destroy our right to privacy altogether, by a combination of: Data sharing (on which, I suspect, they plan to go far beyond what is stated in the consultation document). A central bank digital currency (which, I expect, will enable recording on a central database of every financial transaction we make, down to the level of individual supermarket items, and is likely to imply the abolition of cash). And, not quite on the horizon yet but surely in the works, a “Lifestyle Police” seeking to force everyone to conform to the latest policy fad, in “health” or whatever else is the cause du jour. “You ate too much chocolate (or bacon) last week,” for example, “so we’re fining you £100.”

Most of these policies, it seems, are being forced on us because of commitments made by government, on our behalves but without our agreement, to third parties; particularly the United Nations, and (prior to Brexit) the European Union. Indeed, UNESCO is actively aiming towards schemes similar to the UK’s “on-line safety bill,” which is sure to become a “Censor’s Charter” and enable faceless bureaucrats to order material, to which they object, to be taken down as “disinformation,” even if it is simply the truth.

UNCTAD has said: “the creation of a digital identity system is critical to enable every person to fully participate in their society and economy. Without proof of identity, people may be denied access to rights and services.” This is rather odd from a UN organization, considering that their very own Declaration of Human Rights states: “Everyone is entitled to all the rights and freedoms set forth in this Declaration, without distinction of any kind.” Meaning, if you’re human, then you have human rights, regardless of what you can or can’t prove.

Moreover, it is common knowledge that the UN has been the driver of the green agenda for more than 50 years. But the commitments John Major made on our behalves at Rio were made without us, the people, having any chance to say “no” to them! Such commitments should never have been made without a full, honest and public debate, and at least a referendum. This, again, is extremely bad faith by government against the people.

I shall now respond specifically to the questions in your consultation.

Question 1

The first condition for new objectives under section 35 of the Digital Economy Act 2017 is that the data sharing should either;

a) improve or target a public service provided to individuals or households; or

b) provide a benefit (whether financial or otherwise) to individuals or households.

To what extent do you agree that the proposed new objective meets at least one of those parts of the first condition?


From my perspective, data sharing, even if forever restricted to ID verification data, will not provide any improvement or benefit of any kind. If extended beyond this, it will open up as a serious possibility the Orwellian nightmare I sketched in my opening section above.

As a veteran of the NO2ID wars, I fought against the database state pushed by New Labour, that they wanted to be a “single source of truth.” We won the battle back then; but this is merely the same idea, writ large and with the big tech companies onside. And it’s being promoted by the Tories! So much for the idea that “democracy” gives people a choice.

In the words of a TV series from the 1960s: “I am not a number. I am a free man.” I am not a kilobyte, a megabyte, a gigabyte, or even a terabyte of information. I am a human being. And I deserve to be treated as a human being.

Question 2

The second condition is that data sharing should improve the well-being of individuals or households.

To what extent do you agree that the proposed new objective meets this second condition?


Same answer as to question 1.

Question 3

The third condition is that the data sharing should support the delivery, administration, monitoring or enforcement of a service provided by a particular public authority (or authorities).

To what extent do you agree that the proposed new objective meets this third condition?


The condition as stated makes no sense. You might be able to enforce a court order or a law against a particular crime, but you cannot enforce a service! Similarly, if “monitoring” means monitoring the quality of the service, that should be explicitly stated.

But the mealy-mouthed nature of these words leaves open the possibility that this proposed legislation could be used to “justify” routinely tracking people electronically everywhere they go. Like a criminal tracking tag, on everyone, all the time. That would be an Orwellian dystopia.

Beyond this, same answer as to question 1.

Question 4

To what extent do you agree that the following government departments should become a public body eligible to share data for public service delivery objectives (these public authorities are listed in Schedule 4)?

  • Cabinet Office
  • Department for Transport
  • Department for Food, Environment and Rural Affairs
  • Disclosure and Barring Service

No government department should ever hold any personal data beyond the absolute minimum it needs in order to perform its functions.

All personal data accessible to any government department should be covered by the right of access, as per existing subject access requests. And there must be safeguards in place to ensure that no-one is refused access to the data held on them by government or a private company simply because they are unable to provide proof of ID digitally.

Question 5

To what extent do you agree that the following government departments should be able to share data for the identity verification objective?

  • Cabinet Office
  • Department for Transport
  • Department for Food, Environment and Rural Affairs
  • Disclosure and Barring Service

Same answer as to question 4.

Question 6

Are there any other public authorities not proposed in this consultation which you think should be able to share data for the identity verification objective?

  • NO

Question 7

To what extent do you agree that the data items, known as data attributes, as described under this proposed objective are consistent with, and appropriate for, the delivery of the objective?


I assume that the data items referred to are those listed under the “What data will be processed” heading in the consultation detail document.

“Photographic images” covers a very wide spectrum, and such data could very easily be misused.

“Transactional data, for example income” seems to cover a very wide spectrum indeed. I can understand that historical transaction records may be useful if a department wishes to use the person’s knowledge of a particular past transaction with that department in confirming their identity. For example, the Department for Work and Pensions (already covered by this legislation) might keep pension payment records against a personal record for such a purpose. But otherwise, I cannot conceive of how any such data could help with identification.

“Other data items may be processed as identity verification services develop.” This is open-ended, and looks as if it could easily be extended without supervision by parliament or anyone else.

Any such extra data would, of course, need to be available via a subject access request.

Question 8

To what extent do you consider the proposed sharing of data for the identity verification objective will lead to any individual and/or household losing any benefit?


I found this question very hard to answer. Partly because the effect on individuals will be very dependent on how it is done. But it seems probable that data from one department, when used by another, is more likely to produce false rejections (as well as false acceptances), perhaps leading to an inability to complete the identification process, and thus an inability to access services. If that merits an AGREE response, please change my response to that.

Question 9

To what extent do you consider the proposed sharing of data for the identity verification objective will lead to an individual and/or household losing access to a service?


It is very concerning that someone who can supply ID such as a passport, but cannot for whatever reason pass a digital ID check, should be in danger of being locked out of any service.

Otherwise, same as answer to question 8.

Question 10

Do you think the proposed sharing of data for the identity verification objective will negatively impact on people who share any of the protected characteristics under the Equality Act 2010 (i.e. age, disability, gender reassignment, marriage and civil partnership, pregnancy and maternity, race, religion or belief, sex and sexual orientation)?

  • YES

It will hit very badly those older people, who are unused to technology and may well find it difficult and frustrating, or even impossible, to get their identity verified digitally.

Depending on how it is implemented, it may impact badly on people who are not dexterous enough to use, or have chosen not to have, a mobile phone.

People who have suffered what they perceive as gender changes may also be harmed by these proposals, as they may end up with duplicate and conflicting records.

Question 11

Do you have further comments on this proposed objective?

In putting together these replies, I have found myself coming towards the view that the “digital transformation” may well be, even given the best intentions, a wild goose chase. The need for on-line identity verification arises because of the nature of the on-line medium. The need to communicate with government on-line, in turn, arises from the idea of a “digital transformation.” I think it would be appropriate to re-consider the wisdom of that entire “transformation” process. Particularly also, given that the people of the UK have never before been given any chance to assess this “transformation,” and to accept or reject it. And even more so, if it is being driven by forces outside the UK, and has therefore bypassed all the checks and balances that any democracy ought to have in place.

I am not sanguine that these proposals will do anything at all to protect people against government expansion and over-reach, either today or in the future. The Orwellian nature of the consequences of any such expansion or over-reach is clear.

Moreover, why is government offering identity checking services at all? Something which, particularly given that government is the monopolist of formal identities such as passports, seems inappropriate. But are the private identity checking services, like Verizon, fit for purpose? From what I see, the answer is no. That doesn’t mean that government should take over the task. But rather, it suggests that digital identity checks are not a good way to go forward.

In any case, it MUST be possible for individuals to choose not to use digital ID tools whether provided by government or not). And alternative mechanisms must be in place which allow people who so wish to continue to use, indefinitely, tried and trusted methods of identification at no extra cost. That includes signed letters, and cheques by post.

Question 12

Please indicate whether you are happy for the relevant points and comments you have made to be published in the consultation summary report:



  1. I am not a UK citizen, but I share the concerns and contempt for government involvement in forcing, and thereby reducing people to little if nothing more than data. How anyone can support such actions is beyond reason and should be exposed as fascism leading to a classic Orwellian dystopia.

  2. I too share your view that I do not wish to be ‘transformed’. Infact, I want to be free and left alone.
    I find most new technological advances have created me far more work than I had before. I’m already sick of a thousand passwords and being locked out of sites and having to go through convoluted processes, talking to robots, in order to get back in. Either things work smoothly and are open to fraud or they become so complicated they break down. Workload and frustrations go through the roof. I am presently locked out of my hotmail account (with no way back) and my doctors – with another lengthy form and much nuisance to get back. What used to be simpole is now time-consuming and complex. What starts as a convenience ends as a real problem.
    I too do not have a mobile phone and don’t want one. I’m much too grumpy for anyone to want to talk to me and I have my computer.
    As for consultations – they are a sham. The government goes through the process to tick a box and takes no notice. They already know what they’re going to do.
    As for this profiteering, lying, greedy, self-serving bunch of hypocrits that call themselves a Tory Government when they are really just a bunch of robbers who have spent twelve years robbing the needy and public servants to give huge sums to their rich chums, I would see them more as robber barons than politicians. I hope they all rot.
    However, when it comes to green policies and covid we differ. As a biologist I see the immense harm we are doing. We need to change. I also see the need for vaccination. We dodged a bullet with covid. The next virus could be the one that wipes out 99%. Vaccination is an imperative.

  3. Opher, thanks for the comment. Despite our differences on many political matters, we are on the same hymn sheet on these issues. And we’re even singing the same verse of the same hymn when it comes to “transformation,” poor technology causing people problems, mobile phones and sham consultations. The real divide is not “left” versus “right,” but “up” versus “down.” “Down” supporters want, in Orwell speak, “a boot stamping on a human face forever.” “Up” supporters like me want a free market economy, and minimal government which delivers objective justice, upholds human rights and freedoms, provides a capability for military defence when necessary, and does no more. I’m pleased that you have moved much closer to my views in the more than 5 years I have known you.

    As to green policies, if you read the UN’s “sustainable development goals,” you will see that they like to “transform,” too. In fact, the title of their document is: “Transforming our world: the 2030 Agenda for Sustainable Development.” And “transforming” a world implies transforming the people on it. Neither you nor I like the idea of that.

    As to COVID, the jury is still out on the efficacy, and cost-benefit in the long term, of COVID vaccines. But it’s starting to look as if the human immune system is more effective at dealing with a virus like COVID than are any of the artificial vaccines. I should know: I caught the damned thing before it was officially in the country, and haven’t had it, or anything like it, since!

Leave a Reply