Work in progress - ratings and comments are still to be finalised
Vulnerability Registration Service
1.1 Stated purpose
People can register with VRS and declare various "vulnerabilities" (the term is not defined). It will then be shared with "various organisations so that they are aware of your vulnerability if they are dealing with you."
1.2 Episodic or relational
2.1 Statutory notification
2.2 Info validated by
Sector
4.1 Personal identifier used
Online portal
Offline alternative
1.3 Data included
Relational
No
Financial services, Utilities
Name, address, address history, DoB
Yes
No
Communication preferences
Reasonable adjustments
Benefits entitlement
Benefits claimed
Debt
Risk of eviction
Loneliness or isolation
Unpaid care responsibilities
Lifecycle events
Any other factors or circumstances
Diagnoses (confirmed and provisional)
Physical disabilities
Sensory impairment
Cognitive impairment
Mental health
Mental capacity
Dyslexia, literacy and numeracy
Strengths
A detailed and comprehensive list of actionable support needs (other than those given under mental health needs), although the list itself is relatively difficult to access.
Weaknesses
VRS is the lowest scoring platform we have reviewed against all five groups of functional criteria. Of greatest concern is the complete lack of transparency, choice and control over who receives the information and how they use it. Information is passed to all subscribing organisations, whether or not they have (or are likely to have) a business relationship with the person; and neither VRS nor the subscribing organisations offer clarity or reassurance in their privacy statements about how it will be used.
Other significant weaknesses include:
• VRS appears to be a platform for sharing actionable support needs, but in practice behaves more like a tool for assessing financial risk.
• There is no provision to provide specific detail, e.g. nominating someone as your proxy.
• There is no acknowledgement of receipt of your information by subscribing organisations.
• Although VRS claims to operate across sectors, at best it offers little confidence that information will be shared with the right recipients, and at worst it’s misleading, and implies that your information will reach recipients who will never see it.
• A poorly designed online interface, loaded and judgmental language, and no provision to share your information offline.
• Inbuilt obstacles to the (otherwise good) list of actionable support needs, which involves selecting the right "vulnerability flag" (sic).
Overall, VRS is more likely to engender anxiety than trust among the people expected to use it.
Further information
Overall functional rating
3. Transparency, choice and control
3.1 Transparency
Generic statements about which organisations will have access to the data, with very limited/open-ended information about how it will be used. Unlikely to offer any real confidence to someone who may be anxious about sharing their information - more likely to increase their anxiety.
3.2 Choice and control
One element of choice included: whether future credit applications should be pre-declined. Unclear whether the alternative is for them to be automatically or manually processed – this is much clearer on the Experian Support Hub. No choice or control over who receives the information.
4. Functionality
4.2 Structured data
4.3 Free text
Structured data is uneven, and focuses on the condition rather than the needs which arise from it.
4.4 Carer role
There are options to say "I may want someone to speak on my behalf", but no way to say who that will be or to give them authority in advance to do certain things for you. This would need to be done on a case by case basis, defeating the object of "telling us once".
4.5 Acknowledgement of receipt
No evidence of an acknowledgement from data recipients
4.6 Updates
System allows for updates
4.7 Access to records
This is one platform where it would really help to see the context in which organisations might use the information
5. Reach
5.1 Multi-sector acceptance
Multi-sectoral but relies on the organisation subscribing. Some local authorities subscribe, but it's unclear who in the authority would receive the information.
5.2 Recipients within orgs/services
Unclear how far recipients share (e.g.) reasonable adjustment/communication needs within the organisation. For example: Hampshire County Council subscribes; the contact point given is for the Client Affairs team, who look after the financial affairs of people who lack mental capacity. Does HCC communicate ASNs to other teams across social care, TEC etc? Do they share comms needs with district/borough partners in respect of Council Tax, benefits, housing etc? (Almost certainly not, per the HCC Client Affairs team privacy notice.) Would someone sharing needs through the VRS understand which bit of HCC will receive and act on information? (I had to go digging)
5.3 Proactive sharing
No provision
6. Language and user experience
6.1 Language
'Vulnerable' is a loaded word and will act as a barrier for many potential users of the platform. The language in general could easily come across as judgmental.
Words to watch
6.2 Conditions vs actionable support
A fairly wide-ranging list of ASNs, but these can only be accessed by selecting the right "vulnerability flag" (sic). There may not be a direct correlation between these flags and the needs listed, so you may not be presented with the "circumstances outcomes" options that relfect your ASNs.
Focus on "vulnerability flags" as a gateway to ASNs suggests undue emphasis on a condition rather than on the impact that condition has on your day-to-day life. Equality Act statutory guidance states ("There is no need for a person to establish a medically diagnosed cause for their impairment. What it is important to consider is the effect of the impairment, not the cause."
6.3 Online UX
Cumbersome and poorly designed. The site throws up error messages at step 1, but doesn't say what you need to do to correct them. Access to relevant ASNs is dependent on ticking the right box at step 2.
6.4 Offline UX
No offline alternative to the online platform
7. Outcomes
7.1 Actionable support needs
Positive score for options available, reduced due to the barriers to accessing those options. However, choices available under mental health needs are extremely poor and do not reflect the actual ASNs of people experiencing mental health difficulties.
7.2 Trustworthiness
'- Breadth of subscribers may be offputting to some users.
- Privacy notice is fairly generic in respect of who receives data and what they use it for.
- Little or no transparency
Think Local Act Personal: Data for People
Ratings against the 15 Principles
Overall
TLAP 2
TLAP 3
TLAP 4
TLAP 5
TLAP 6
TLAP 7
TLAP 8
TLAP 9
TLAP 10
TLAP 11
TLAP 12
TLAP 14
Money Advice Trust
Ratings against the 10 principles for designing vulnerable consumer data-sharing programmes
Overall
MAT 1
MAT 2
MAT 3
MAT 4
MAT 5
MAT 6
MAT 7
MAT 8
MAT 10-