2021 Digital Identity Services Trust Framework Bill

PSGR's submssion to the 2021 December 2 - Digital Identity Services Trust Framework Bill discussed the problem of an absence of consultation with the public, while a large private consultation with 'targeted stakeholders' occurred. (Link to submission)

The submission discussed the challenge of stewarding increasingly complex technologies. Policy has not produced a values-based framework (which might have arisen from consultation with the public) to appropriately govern digital identity in such a way that is protective of human rights, and appropriately anticipatory (such as of the challenges thrown up by AI). This is important as challenges thrown up by new technologies - if not framed by values-based ethics - often tend to be governed instrumentally in such a way that is not protective of public or environmental health.

Also discussed were issues of power imbalance, potential conflicts of interest in the business activities of prospective multinational providers, and a requirement, in the public interest to establish adequate resourcing in order to research, and potentially counter the claims of the regulated entities - the trusted framework providers. The policy did not discuss, or downplayed the requirement to resource an appropriate New Zealand-based independent science, technology and ethics network, outside of large vested interests - in order to appropriately understand current and prospective risks presented by digital identity technologies.

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