One of the most commonly quoted concerns about publishing public data on the web is the potential for fraud – and certainly the internet has opened up all sorts of new routes to fraud, from Nigerian email scams, to phishing for bank accounts logins, to key-loggers to indentity theft.
Many of these work using two factors – the acceptance of things at face value (if it looks like an email from your bank, it is an email from them), and flawed processes designed to stop fraud but which inconvenience real users while making life easy from criminals.
I mention this because of some pending advice from the Local Government Association to councils regarding the publication of spending data, which strikes me as not just flawed, but highly dangerous and an invitation to fraudsters.
The issue surrounds something that may seem almost trivial, but bear with me – it’s important, and it’s off such trivialities that fraudsters profit.
In the original guidance for councils on publishing spending data we said that councils should publish both their internal supplier IDs and the supplier VAT numbers, as it would greatly aid the matching of supplier names to real-world companies, charities and other organisations, which is crucial in understanding where a local council’s money goes.
When the Local Government Association published its Guidance For Practitioners it removed those recommendations in order to prevent fraud. It has also suggested using the internal supplier ID as a unique key to confirm supplier identity. This betrays a startling lack of understanding, and worse opens up a serious vector to allow criminals to defraud councils of large sums of money.
Let’s take the VAT numbers first. The main issue here appears to be so-called missing trader fraud, whereby VAT is fraudulently claimed back from governments. Now it’s not clear to me that by publishing VAT numbers for supplier names that this fraud is made easier, and you would think the Treasury who recommend publishing the VAT numbers for suppliers in their guidance (PDF) would be alert to this (I’m told they did check with HMRC before issuing their guidance).
However, that’s not the point. If it’s about matching VAT numbers to supplier names there’s already several routes for doing this, with the ability to retrieve tens of thousands of them in the space of an hour or so, including this one:
Click on that link and you’ll get something like this:
Whether you’re a programmer or not, you should be able to see that it’s a trivial matter to go through those thousands of results and extract the company name and VAT number, and bingo, you’ve got that which the LGA is so keen for you not to have. So those who are wanting to match council suppliers don’t get the help a VAT number would give, and fraudsters aren’t disadvantaged at all.
Now, let’s turn to the rather more serious issue of internal Supplier IDs. Let me make it clear here, when matching council or central government suppliers, internal Supplier IDs are useful, make the job easier, and the matching more accurate, and also help with understanding how much in total redacted payees are receiving (you’d be concerned if a redacted person/company received £100,000 over the course of a year, and without some form of supplier ID you won’t know that). However, it’s not some life-or-death battle over principle for me.
The reason the LGA, however, is advising councils not to publish them is much more serious, and dangerous. In short, they are proposing to use the internal Supplier ID as a key to confirm the suppliers identity, and so allow the supplier to change details, including the supplier bank account (the case brought up here to justify this was the recent one of South Lanarkshire, which didn’t involve any information published as open data, just plain old fraudster ingenuity).
Just think about that for a moment, and then imagine that it’s the internal ID number they use for you in connection with paying your housing benefits. If you want to change your details, say you wanted to pay the money into a different bank account, you’d have to quote it – and just how many of us would have somewhere both safe to keep it and easy to find (and what about when you separated from your partner).
Similarly, where and how do we really think suppliers are going to keep this ID (stuck on a post-it note to the accounts receivable’s computer screen?), and what happens when they lose it? How do they identify themselves to find out what it is, and how will a council go about issuing a new one should the old one be compromised – is there any way of doing this except by setting up a new supplier record, with all the problems that brings.
And how easy would it be to do a day or two’s temping in a council’s accounts department and do a dump/printout of all the Supplier IDs, and then pass them onto fraudsters. The possibilities – for criminals – are almost limitless, and the Information Commissioner’s Office should put a stop to this at once if it is not to lose a serious amount of credibility.
But there’s an bigger underlying issue here, and it’s not that organisations such as the LGA don’t get data (although that is a problem), it’s that such bodies think that by introducing processes they can engineer out all risk, and that leads to bad decisions. Tell someone that suppliers changing bank accounts is very rare and should always be treated with suspicion and fraud becomes more difficult; tell someone that they should accept internal supplier IDs as proof of identity and it becomes easy.
Government/big-company bureaucrats not only think like government/big-company bureaucrats, they build processes that assumes everyone else does. The problem is that that both makes more difficult for ordinary citizens (as most encounters with bureaucracy make clear), and also makes it easy for criminals (who by definition don’t follow the rules).
Since OpenlyLocal started pulling in council spending data, it’s niggled at me that it’s only half the story. Yes, as more and more data is published you’re beginning to get a much clearer idea of who’s paid what. And if councils publish it at a sufficient level of detail and consistently categorised, we’ll have a pretty good idea of what it’s spent on too.
However, useful though that is, that’s like taking a peak at a company’s bank statement and thinking it tells the whole story. Many of the payments relate to goods or services delivered some time in the past, some for things that have not yet been delivered, and there are all sorts of things (depreciation, movements between accounts, accruals for invoices not yet received) that won’t appear on there.
That’s what the council’s accounts are for — you know, those impenetrable things locked up in PDFs in some dusty corner of the council’s website, all sufficiently different from each other to make comparison difficult:
For some time, the holy grail for projects like OpenlyLocal and Where Does My Money Go has been to get the accounts in a standardized form to make comparison easy not just for accountants but for regular people too.
The thing is, such a thing does exist, and it’s sent by councils to central Government (the Department for Communities and Local Government to be precise) for them to use in their own figures. It’s a fairly hellishly complex spreadsheet called the Revenue Outturn form that must be filled in by the council (to get an idea have a look at the template here).
They’re not published anywhere by the DCLG, but they contain no state secrets or sensitive information; it’s just that the procedure being followed is the same one as they’ve always followed, and so they are not published, even after the statistics have been calculated from the data (the Statistics Act apparently prohibit publication until the stats have been published).
So I had an idea: wouldn’t it be great if we could pull the data that’s sitting in all these spreadsheets into a database and so allow comparison between councils’ accounts, thus freeing it from those forgotten corners of government computers.
This would seem to be a project that would be just about simple enough to be doable (though it’s trickier than it seems) and could allow ordinary people to understand their council’s spending in all sorts of ways (particularly if we add some of those sexy Where Does My Money Go visualisations). It could also be useful in ways that we can barely imagine – some of the participatory budget experiments going in on in Redbridge and other councils would be even more useful if the context of similar councils spending was added to the mix.
So how would this be funded. Well, the usual route would be for DCLG or perhaps the one of the Local Government Association bodies such as IDeA to scope out a proposal, involving many hours of meetings, reams of paper, and running up thousands of pounds in costs, even before it’s started.
They’d then put the process out to tender, involving many more thousands in admin, and designed to attract those companies who specialise in tendering for public sector work. Each of those would want to ensure they make a profit, and so would work out how they’re going to do it before quoting, running up their own costs, and inflating the final price.
So here’s part two of my plan, instead going down that route, I’d come up with a proposal that would:
- be a fraction of that cost
- be specified on a single sheet of paper
- paid for only if I delivered
Obviously there’s a clear potential conflict of interest here – I sit on the government’s Local Public Data Panel and am pushing strongly for open data, and also stand to benefit (depending on how good I am at getting the information out of those hundreds of spreadsheets, each with multiple worksheets, and matching the classification systems). The solution to that – I think – is to do the whole thing transparently, hence this blog post.
In a sense, what I’m proposing is that I scope out the project, solving those difficult problems of how to do it, with the bonus of instead of delivering a report, I deliver the project.
Is it a good thing to have all this data imported into a database, and shown not just on a website in a way non-accountants can understand, but also available to be combined with other data in mashups and visualisations? Definitely.
Is it a good deal for the taxpayer, and is this open procurement a useful way of doing things? Well you can read the proposal for yourself here, and I’d be really interested in comments both on the proposal and the novel procurement model.