In the first of a series of blogs discussing key issues and challenges that arise from our project, Dr Sarah Gorin discusses the problems encountered by our team as we try to find out which local authorities in the UK are using data linkage and predictive analytics to help them make decisions about whether to intervene in the lives of families.
As background context to our project, it seemed important to establish how many local authorities are using data linkage and predictive analytics with personal data about families and in what ways. To us this seemed a straightforward question, and yet it has been surprisingly hard to gain an accurate picture. Six months into our project and we are still struggling to find out.
In order to get some answers, we have been reaching out to other interested parties and have had numerous people get in touch with us too: from academic research centres, local authorities, independent foundation research bodies, to government-initiated research and evaluation centres. Even government linked initiatives are finding this difficult, not just us academic outsiders!
So what are the issues that have been making this so difficult for us and others?
No centralised system of recording
One of the biggest problems is finding information. There is currently no centralised way that local authorities routinely record their use of personal data about families for data linkage or predictive analytics. In 2018, the Guardian highlighted the development of the use of predictive analytics in child safeguarding and the associated concerns about ethics and data privacy. They wrote:
“There is no national oversight of predictive analytics systems by central government, resulting in vastly different approaches to transparency by different authorities.”
This means that it is very difficult for anyone to find out relevant information about what is being done in their own or other local authorities. Not only does this have ethical implications in terms of the transparency, openness and accountability of local authorities but also more importantly, means that families who experience interventions by services are unlikely to know how their data has been handled and what criteria has been used to identify them.
In several European cities they are trialling the use of a public register for mandatory reporting of the use of algorithmic decision-making systems. The best way to take this forward is being discussed here and in other countries.
Pace of change
Another issue is the pace of change. Searching the internet for information about which local authorities are linking families’ personal data and using it for predictive analytics is complicated by the lack of one common language to describe the issues. A myriad of terms are being used and they change over time…‘data linkage’; ‘data warehousing’; ‘risk or predictive analytics’; ‘artificial intelligence’ (AI); ‘machine learning’; ‘predictive algorithms’; ‘algorithmic or automated decision-making’ to name but a few.
The speed of change also means that whilst some local authorities who were developing systems several years ago, may have cancelled or paused their use of predictive analytics, others may have started to develop it.
The Cardiff University Data Justice Lab in partnership with the Carnegie UK Trust are undertaking a project to map where and why government departments and agencies in Europe, Australia, Canada, New Zealand and the United States have decided to pause or cancel their use of algorithmic and automated decision support systems.
General Data Protection Regulation (GDPR)
GDPR and the variation in the way in which it is being interpreted may be another significant problem that is preventing us getting to grips with what is going on. Under GDPR, individuals have the right to be informed about:
- the collection and use of their personal data
- information including the purposes for processing personal data
- retention periods for data held
- and with whom personal data will be shared
As part of their responsibilities under GDPR, local authorities should publish a privacy notice which includes the lawful basis for processing data as well as the purposes of the processing. However, the way that local authorities interpret this seems to vary, as does the quality, amount of detail given and level of transparency of information on privacy notices. Local authorities may only provide general statements about the deployment of predictive analytics and can lack transparency about exactly what data is being used and for what purpose.
Lack of transparency
This lack of transparency has been identified in a Review by the Committee on Standards in Public Life who published a report in February 2020 on Artificial Intelligence and Public Standards. In this report it highlighted that Government and public sector organisations are failing to be sufficiently open. It stated:
“Evidence submitted to this review suggests that at present the government and public bodies are not sufficiently transparent about their use of AI. Many contributors, including a number of academics, civil society groups and public officials said that it was too difficult to find out where the government is currently using AI. Even those working closely with the UK government on the development of AI policy, including staff at the Alan Turing Institute and the Centre for Data Ethics and Innovation, expressed frustration at their inability to find out which government departments were using these systems and how.” (p.18)
Whilst some local authorities seem less than forthcoming in divulging information, this is not the case for all. For example, in Essex, a Centre for Data Analytics has been formed as a partnership between Essex County Council, Essex Police and the University of Essex. They have developed a website and associated media that provides information about the predictive analytics projects they are undertaking using families’ data from a range of partners including the police and health services.
So what are we doing?
As part of our project on parental social licence for data linkage and analytics, our team are undertaking a process of gathering information through internet searching and snowballing to put together as much information as we can find and will continue to do so throughout the course of the project. So far, the most useful sources of information have included:
- the Cardiff University Data Justice Lab report that examines the uses of data analytics in public services in the UK, through both Freedom of Information requests to all local authorities and interviews/workshops with stakeholders
- the WhatDoTheyKnow website which allows you to search previous FOI requests
- internet searches for relevant local authority documents, such as commissioning plans, community safety strategies and Local Government Association Digital Transformation Strategy reports
- media reports
- individual local authority and project websites
It would seem we have some way to go yet, but it is a work in progress!
If you are interested in this area we’d be pleased to know of others’ experiences or if you’d like to contribute a blog on this or a related topic, do get in touch via our email firstname.lastname@example.org