Service Victoria Bill 2017

The Bill aims to provide a legislative framework for a single online point of contact with Victorian instrumentalities and departments. Liberty Victoria remains deeply concerned at creating a ‘honeypot’ of identifying and tracking information that lies at the heart of any such information system – however well-constructed.
Liberty Victoria

The portal that has been created does meet many privacy standards. The entry point stores minimal information – once the identity (ID) has been established only a token certifying that level of ID is kept on the website. The department or instrumentality being accessed is told that the ID is correct and doesn't require re proof for later access, nor do they store ID information. Only those departments or instrumentalities that the consumer wishes to access are linked to their account. The government is keen to encourage all departments to destroy all ID records (copies of drivers licences/passports etc) used for past proof of ID, which are now not required if the consumer has moved to the new website. This meets a key privacy requirement to minimise record storage and destroy any identifiers which are no longer needed.

The Government is very keen to promote this as a one size fits all access. Yet non tech-savvy individuals will be making all their data available in one place. Without a VPN (virtual private network) attached to their personal device (mobile phone/laptop/desktop), access via WiFi will potentially open the whole of that person’s private records to third parties. The use of public access WiFi (coffee shops, airports etc) allows interception of account names and passwords. Banks and similar institutions of trust are moving to app-based rolling PINs and other similar security methods for transactions of this level of privacy in an attempt to overcome the problems of insecure access routes.

The ‘honeypot’ is made bigger, and more attractive to potential hackers, because it will constitute the online point of access for the two or three Departments which most require casual contact (VicRoads, Consumer Affairs, Agriculture), and further it  ultimately aims to have all details of all contact between the State and the individual.

The question should be raised as to why smaller departments with diverse ranges of interaction need to conform to the Service Victoria template, when nearly all savings and efficiency reside with the high-volume transactions in a few departments.

Liberty Victoria acknowledges and is thankful for the extensive consultation provided by Service Victoria, in an era where often there is very little time for stakeholders to engage and respond to proposed legislation.

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