There has been a quiet revolution occurring which will have profound impacts on community-based social services organisations. This revolution was brought to my attention recently when the Request for Proposals (RFP) for the new style budgeting programme, Building Financial Capability, was released. Buried in the RFP supplementary information is the requirement to provide Individual Client Level Data, or as it is colloquially known in government circles, ICLD. This individual data includes the requirement to provide “Client Name, address, gender, date of birth, primary ethnicity, Iwi. Dependents Name, date of birth, relationship to client”.
The latest update to the Community Investment Strategy further spells out; “Starting from July 2016, we will begin collecting individual client level data (client level data) from providers. We will do this progressively over the year, so that we are collecting client level data from all providers by July 2017.” This means that all Community Investment funded service providers will be required to collect and provide to government Individual Client Level Data. NZCCSS members have been signalling their concern as their contracts begin to require the collection and reporting of “Individual Client Level Data”.
Acting as an arm of government:
Currently social services providers work in communities as independent agencies. As such they are accessible, trusted and able to engage across their communities and are seen as independent providers of necessary support services. Once service provision is contingent on the collection of individualised data, which is supplied to government, this independence is compromised and the agency becomes a defacto arm of government.
Many of the most vulnerable families in our members’ communities trust our Christian service providers as they are independent, honest and committed to their well-being. This means they are willing to work with these members in such situations as; – being impacted by family violence, having drug and alcohol addictions, living in situations where benefit eligibility is uncertain, having outstanding warrants for arrest and/or outstanding fines. The children living in these families are extremely vulnerable.
The support and direction provided by our independent members to these families is often the critical factor in keeping their children safe. For many of the most vulnerable families in these situations data sharing by government agencies does not have positive connotations. In the past they may have had Work and Income seeking recovery of benefit payments after Inland Revenue has shared data showing that a person received a benefit after being in employment. Or they may have had their address revealed to the Courts after the Probation Service had shared their current address, resulting in debt companies chasing them for unpaid fines.
The thought that their individual data would be shared with government if they engaged with the services of the no-longer independent social support agency could result in vulnerable families not seeking support. This is very likely to result in negative impacts on the wellbeing of these families and their highly vulnerable children.
Free and informed consent:
While the individualised data sharing and the processes to do this have been cleared by the Privacy Commission our members still see many instances where their clients may feel compelled to give consent rather than freely giving consent in an informed manner.
An example is a family in receipt of benefit payments who are desperate for food and have made an application for a special needs grant for food with Work and Income. They have been directed to undertake a programme of building financial capability. In order to receive the special needs grant they must give permission to their community social services organisation to share their individualised data with government. This is not freely given consent, it is given under duress. It may further affect the ongoing relationship with the service provider.
Demographic and geographic data sharing is acceptable
The sharing of such details as general geographic location, primary ethnicities, gender, month and year of birth and family size and structure are all acceptable if provided anonymously. This will allow for the analysis of the service effectiveness contracted by government and provided by the service provider across in a range of socio-economic settings.
Service rationing in a social investment environment
High level users of community social services may take many years and huge resources to achieve long-term sustainable positive outcomes. Our members are concerned that the collection of individualised data may lead to the rationing of services to these highly vulnerable and resource intensive individuals and families.
In a social investment environment government may decide that a certain level of support, of investment, is the limit for any individual or family – as the return on investment beyond that point is not sufficient to warrant further cost. Our members know we are all created in the image of God (Genesis 1:27) and do not measure the person’s or family’s worth in dollars rather see the potential of hope and transformation in all. The collection of individualised data is a first step in the potential journey to this type of rationing.