Last month, I renewed my car tax disc. I am certain that Francis Maude and the Cabinet Office will be thrilled beyond measure to learn that I did it online. During the process there were some tick boxes, one which stated the following:
The email address and/or mobile number supplied by you, may also be used by DVLA and other Government Motoring Agencies to inform you of other services which may be of interest.
Needless to say, I opted out, but I found this intriguing, as I couldn’t imagine what else the Government might want to tell me about motoring issues. So I made an FOI request to the DVLA to ask what the other services that might be of interest were and which other government agencies and departments get access to the data.
I received a prompt response.
DVLA does not hold details of the other services. The statement relates to the fact that DVLA may contact you via the e-mail address you have used to ask about your experience of using that service, or to gain further insight around motoring services. Whilst this insight is normally used internally (within DVLA) for us to improve our services, findings may be shared within Government beyond DVLA. However, no other government departments have access to the mobile phone numbers and email addresses when a customer renews their car tax online.
I think the two quotes above are impossible to reconcile. The text on the site is not vague or ambiguous – it describes information sharing to promote other services. If the DVLA were going to share people’s details with other parts of government, effectively for marketing purposes, as stated by the statement on the website, this wouldn’t be unreasonable. I think the text should be clearer about the ‘who’ and ‘what for’ and it should be opt-in not opt-out, but that’s not the point. The DVLA’s FOI response describes a different activity altogether.
The use of email and mobile phone numbers to ask further questions about the service, and sharing the results with their colleagues is obviously acceptable. The Information Commissioner (I think rightly) considers research or ‘customer insight’ to be separate from marketing, and probably wouldn’t even expect an opt-out if it was going to be carried out. I certainly wouldn’t have bothered to opt out, if only for the opportunity to tell them how dull and clunky the registration process was.
The requirement placed on the DVLA to provide drivers’ details to the broadest conceivable spectrum of parking companies (including many that stray close to illegality) has not given them the best reputation amongst the public. The abolition of the paper tax disc in October, based apparently on DVLA’s conviction that the prevalence of Automatic Number Plate Recognition cameras make the paper discs unnecessary, has already given rise to some hysterical reaction in the media. In particular, Guy Walters’ almost parodic attempt to tick as many paranoid boxes as possible (Big Brother! Cameras! Minority Report Style Adverts! Immigrants!) shows how far suspicion of the DVLA can go.
In this context, it’s remarkable that the DVLA seem to want to give the impression of greater data sharing than is actually the case. The only alternative is that their FOI response is untrue – I’m not leaping to that conclusion, although I am asking for an internal review to clear up the apparent confusion. Perhaps they haven’t changed the website since such data sharing happened; perhaps they wrote it anticipating data sharing which hasn’t come off, or hasn’t started yet. Whatever happens, it underlines the importance of clarity and fairness. If the website had clearly stated what they were doing (whatever that turns out to be), I would never have made the FOI request in the first place. If there wasn’t a disparity between the website and the response, I wouldn’t be asking for an internal review. If you have any spare time soon, it might be worth looking at whether your organisation’s website is a fair reflection of what you actually do.