Newfoundland and Labrador will run a digital identification pilot in 2023 – what will this mean for community organizations and the people they serve?

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For somebody experiencing homelessness and moving from shelter to shelter, there is a high chance that possessions and important documentation could get lost or misplaced while they are on the move. “You see ID clinics around Canada, which store people’s personal IDs when they are in a state of homelessness,” says Doug Pawson, executive director of End Homelessness St John’s. 

However, without that form of identification, a person’s ability to access critical services and government support is also hindered. Without identification, a person could lose access to housing benefits and health services too – putting them at risk of staying in a cycle of homelessness. 

In these situations, a digital form of ID could reduce barriers and help “expedite [necessary] support without people having to wait,” Pawson adds. Pawson, based in the capital of Newfoundland and Labrador — which is now on the traditional and unceded territory of the Beothuk and the Mi’kmaq — is a supporter of the provincial government’s recent announcement to pilot a digital form of identification in 2023. 

The government is still in the early stages of developing these credentials, said Digital Government Minister Sarah Stoodley’s office. The program is also optional for residents. So far, the only form of digital identification planned is a service that allows people to show and verify their age, adds Information and Privacy Commissioner Michael Harvey. It’s not yet clear the exact format that this digital form of identification will take. 

For Pawson, and in the work he does to connect those experiencing homelessness with housing support services, digital ID could help reduce stigma.

That is because, usually, not having an address or proof of residency poses multiple barriers – not only to accessing a physical form of identification in the first place, but also to then being able to apply for the adequate support services. In theory, if the form of digital identification proposed is an age verification service, then there is no need for a person to also have a registered address to be able to have and keep a form of digital identification. 

Digital identification is also useful for women fleeing domestic violence, who might be living in transition homes, Pawson adds. “Women may have had their identification stolen by a partner. Digital identification could help them maintain access to a bank account, support or income, without having to share more information than is required. The promise of digital identification technology should enhance that autonomy.” 

How could digital identification affect communities?

Despite Pawson’s optimism about the program, he does also note that the devil will ultimately be in the details. 

For example, if the digital ID is tied to a smartphone or an app, what will that mean for people who can’t access or use devices, or those who can’t afford to pay for data plans? There is also the risk of data breaches – in October 2022, the Newfoundland and Labrador healthcare system was subject to a cyberattack, which led to more than 200,000 files being leaked, including patient and employee information. 

Charlie Murphy, the Executive Director at Quadrangle, a Newfoundland and Labrador organization working with 2SLGBTQIA+ communities, adds that consultation with communities and the organizations working with them is going to be crucial to the success of digital identification. “This will impact the trans community, and I’d like to see more conversation about how it will impact us,” he says. “It’ll be better to be proactive, rather than fixing issues on the backend once it has launched.” 

“If someone has not changed their gender marker on the analog version [of identification], can they change it online? What are the steps to changing gender markers, and what sorts of systems are going to be in place for those changing over to a digital ID?”

“In the 2SLGBTQIA+ community, there is a lot of employment insecurity. When you don’t have work, you don’t have access to privileged items like phones,” he adds. “In the senior population of the 2SLGBTQIA+ community, people often don’t use their phones for anything else other than a phone.” 

Murphy adds that despite the announcement of the digital identification pilot, little has been done by the Newfoundland and Labrador government to engage communities and community organizations thus far, meaning that many don’t know the timeline in which it will launch and become available to the public. It’s also unclear at the moment if community organizations will be able to use the digital form of identification themselves in their work, and if so, how they would go about doing it. Future of Good reached out to Minister Stoodley’s office for comment, but she was unavailable for an interview. 

What is the importance of designing digital identification from a privacy-first standpoint?

While it’s not mandatory, the government may turn to Information and Privacy Commissioner Michael Harvey for consultation on building these digital credentials in a way that upholds citizens’ privacy rights.

“Our position is that privacy is a human right,” Harvey says. “Rights are subject to being able to operate in a fair and democratic society. They have to bring equitable benefits for all.”

Harvey also believes that a digital form of identification could bring more security than a physical one. He gives the example of the form of identification that a person uses to buy alcohol, which is usually a passport or a driver’s license. “Both of them contain much more information than is required,” Harvey says. “All a person in a bar or liquor store needs to know is that I am older than 19. They don’t need to know exactly how old, nor do they need to know my name and address. There is all sorts of information in the physical form [of identification] that is not necessary.” He says this also opens the doors to exacerbating existing equity issues, particularly around race-based information. 

He calls this ‘function creep’ – in other words, when a piece of data or information is used for a different purpose than the one it was originally intended for. In the context of digital identification, Harvey and his team advocate for gathering as little information as possible, but that, he adds, “is not intuitive to designers. [They] try to collect as much information as possible because it can make a tool more powerful, and allow you to do more evaluation of the tool. I understand that is a logical imperative for designers, but that is inconsistent with the privacy laws that Canadians are entitled to under the law.”

Harvey suggests that the government take a “privacy-by-design” approach in building digital credentials. Alongside collecting as little personal identifiable information as possible, a joint, cross-provincial statement on digital identity recommends the following: systems that do not create central databases; the availability of anonymous and pseudonymous identifiers where appropriate; and no tracking of users’ usage of these digital credentials. 

And this privacy-by-design approach shouldn’t be too difficult to implement, especially given that the Newfoundland and Labrador government has already deployed a form of digital credential at scale before: NLVaxPass, an app which allowed residents to disclose their vaccination status on a need-to-know basis. Not only did provincial governments repeatedly consult privacy consultants through the design and development stages, but users remained in control of how and how often their information needed to be disclosed, Harvey says. 

“Five years ago, before the pandemic, it would have been unthinkable that you had to show your vaccine status or disclose health information at every store you went into. The notion of it would have been appalling to us. But we now had a true, demonstrable need. When we did, we put our conditions into place for minimum [data] use, and decommissioned it when it was all over. Decommissioning was part of our recommendations from the beginning.” 

Ultimately, Harvey adds, the physical form of identification will always have to play a part. “For example, our local pharmacy – which is in an area adjacent to low-income housing – has replaced its numerous checkout counters with self checkouts. It’s a pharmacy frequented by many new Canadians and older people, and for a whole variety of reasons, people primarily pay in cash over electronic forms of payment. There always ends up being a huge line for the single human checkout counter.” 

“This is an equity issue, and we can’t create an equity problem.”

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