My Late and Ineligible Submission to the Policy Framework for Ontario’s Digital ID Program Consultation — Phase 3

Bianca Wylie
17 min readOct 13, 2021

The deadline for this recent round of public consultation has closed. I missed it, but I will send this post to the provincial government regardless. I will do so by emailing a link to this post along with its full text to: digital.government (at) . I’ll also post this on my site shortly so it’s not just on medium. I’m going to give it a day or two because sometimes you find mistakes and let me know, or I find them myself. Or I want to make edits. Update: submitted to the govt of the province of Ontario on Oct 19, 2021 via email.

Included is a short story about mail, automation, the so-called Canada/US border, and Canada Post. It’s relevant to the worlds that lie ahead, both in government and outside of it.

Here’s my feedback on this consultation in a bit more of a narrative format, which would primarily live in a question box for “other feedback”. I’m open as always to corrections, additional information that may help me understand the issue more, etc. This is not a topic I’ve followed super closely but let’s be honest, how many of us in Ontario have? So let’s cut through the fear/hesitation that keeps us quiet sometimes, particularly with tech, because we don’t think we know enough to have opinions. Let’s also take this moment to pause and wish people with big tech opinions find more humility and interest in history. Why not?

My feedback:

  1. This is not the time for digital identity to be implemented in Ontario. The second-order impacts have not been properly assessed or planned for. If they have been, they’re not easily accessible to the public

I am against the idea of implementing digital identity in the province of Ontario at this time. I don’t believe the government has the people’s consent for this action. There are very few Ontarians with even meagre knowledge about this subject. The government is forging ahead with a program without anywhere near significant informed consent of the population. I think the government knows this and believes it is making an important step in the direction of being more “modern”. They are far from alone in this position.

Regardless, it is important to be clear that the decades ahead will be impacted by this decision to implement digital identity right now. There are significant legacy system technology issues, legislation, and cultural norms both evolving and in trouble. This should weigh on both those in political charge but also those in bureaucratic charge. At the heart of the problem with timing for this implementation is inequity, despite the fact that the government says this is not a mandatory service and that traditional ID can continue to be used.

Both types of leaders (political and civil service) should most certainly be aware of the potential dominoes that fall from instituting a system change such as this one — who it serves and who it does not serve. In this case, while nothing about provincial political leadership supporting this move surprises me, those within the civil service have a deep understanding of the need for government services to serve all equally, regardless of how badly this idea of equity in services is supported now. Leadership within the civil service should be watching the world around them in the last decade and understanding the service stratification these decisions create.

From a historical perspective, this decision, and its driving force (industry pressure, efficiency of government) has been brewing for a long time — see this paper from 2005 by Stuart G.M. Bailey and Nadia Caidi (open access, yay) — about the time in 2002 when Ontario was thinking about smart cards. An idea that was stopped before it went formally to public consultation because of the backlash. Efficiency is not a dirty word. Efficiency in services is important. Efficiency for whom and why, however, continues to be an important question in the frame of state modernization efforts. More on that further down.

2. The technical specifications are (probably) not a problem, or at least they aren’t the part I have a problem with

My concern is not with the technical specifications being proposed. I know a lot has changed since 2002, I know there are earnest and smart people working on this topic and have been for a long time. Being solely concerned about the technical specifications of any technology policy is a persistent trap to avoid. Once you fall into that frame it’s hard to get back to one of the most important starting frames which is always “should we do this or not?” (aka abolition world.) Beyond the technical specifications, we should also all be aware of the significant corporate push there has been to “own” identity — to become the owner of the corporate entity where you login to your life. There are companies that are well known that are pushing for this from several sectors — tech, banking, etc. Some of the people working on digital identity projects are doing so out of a defensive posture, which is important and vital work, knowing that if there is a not a state or community led response, the space will be defined and captured by corporate and commercial intent.

This is important mitigation work and I’m appreciative of this effort, particularly in this moment, and even moreso in a country like Canada where civil society’s capacity to show up to this consultation in any kind of a powerful way was never possible. A place where public information and education efforts on this and so many other topics have been so low there is no true public oversight possible. I’m not going to get into media coverage but I have an instinct/guess that tech policy is now so overly dominated by technical specifications and jargon that even curious journalists might not be able to wade through it to make sense of it. And if they did, they’d be invited in through the narrow frames being offered by the government: privacy, security, etc.

While I’m here, small side note/pattern: one thing possibly worse than tech media that reprints corporate press releases or product reviews as news is tech media that will do the same for the state. We’re not always there yet, but the state is getting ever more aware of how to frame its technological desires as social goods. When government sets the frame for a policy through comms and public consultation, they define the stakes and shape of the way public conversations are had. I cannot say this enough: this frame has to be challenged every single time because it always presents things as both inevitable, and as issues of privacy and security (and most recently accessibility). Reading the government congratulating the public for saying that privacy and security and accessibility are important considerations are the motherhood and apple pie of inane outputs. Did the government really need the public to share these “insights” with them?

Look at the last five or ten years. We are not having the kinds of conversations that are shifting government investment to good civic and public tech, nor are we moving social norms away from the harms that technology is creating. If the government had a good track record on these bits to date, that would be one thing. The reality, however, is quite otherwise. And the data to have this conversation is a nightmare to try to piece together. We’re at a point where I don’t even know if the government has good track of our public systems but that’s a post for another day.

3. Lipstick on a pig, state-side

There is no quick-fix for legacy technology systems. And one can be assured that swapping out the traditional modes of identification for digital identification as it relates to access to government services is lipstick on a pig. Whenever I use this term I feel bad because I like pigs and I like lipstick so it’s not ideal. But it’s stuck with me since a colleague in Maine used it, and she was using it in a tech context, so here we are. It’s probably remembering her laugh that makes me like it. Anyway — part of why it’s so good a saying is because lipstick can be so pretty and shiny, imagine a gloss here, not a matte heavy one. That light gloss, that sheen — that’s the digital identity part. Then look at that little pot of gloss beside the size of the beautiful pig’s face and body. That’s the legacy technology this digital identity is being “applied” to, state-side. It’s making the removal of a small part of the system “prettier” but the underlying system is, in a word, not great. I’m messing with this analogy to make it more kind, I know it’s not the most coherent but whatever.

Here’s where this gets a bit more confusing so hold with me for a few. Yep, worse than the mess I just made with the lipstick pig. The legacy systems that exist in the private sector are a total mixed bag. There are large companies with messy old systems, some on par with the mess of the state, but there are also newer companies with messy new systems. Then there are also companies that are providing ways to create clean systems between systems. Mess connectors. Spaghetti cutters and joiners. These are some of the companies that are seeking to benefit from digital identity as a project. The middle place.

I am not going to slide into credit card policy world but there are some parts of that world relevant to this world. In some cases its less about transactions and more about opening up the door to lots of new intermediaries. Let’s go back and look at the framing from the province’s website: “Digital ID is the foundation that will enable easier access to online services and make Ontario one of the world’s most digitally advanced jurisdictions, with a value for Ontarians, businesses and the government that is estimated at $20 billion.” — This is a rough-order-of-magnitude estimate calculated from about 35 value drivers and hundreds of data points from various sources, including DIACC (Digital ID & Authentication Council of Canada), McKinsey Global Institute and World Economic Forum.”

Ok, so how much of this move is about increasing economic growth and how much of this is about savings, on the government services provision side? Nothing further on that $20 billion number. No links. No math. Lots of subtext. The recent concern from tech companies about the unbanked also comes to mind here. That, again, is another post.

Back to efficiency not being a dirty word. Who does this modernization benefit? If we know about the unresolved technology and service problems laying beneath the ID, we know that on the government side, those that are already well-served will be better served. Consider this from Annie Lowrey’s latest piece, necessary reading on efficiency : “as shown by the Cornell political scientist Suzanne Mettler, many high-income people, unlike poor folks, never even realize they are benefiting from government programs.” Granted, this is US context, but there is enough similarity not to ignore it.

The point is not that we shouldn’t be making systems more efficient. But the priority should be investments in this for all. If you can show me how this will be one of those, and that equitable investments will be made to support and improve process for the poor, ok great. I don’t see that explicit intent. The idea of equity seems to be that you don’t have to use this policy. Ok. But what of that experience then, and investments in it? This brings us to the place where technology and disenfranchisement and democracy collide. This also brings us to the need to stop pretending that while access and efficiency is indeed a problem, the amount of support we provide each other through the state is the core issue at the heart of our trouble.

The government has clearly stated that this new digital ID will not be mandatory. But that is not the same thing as considering equity in experience, if and where feasible. We have seen historically that one of our weak spots with technology in our democracy is not having alternatives to those that become dominant. To that end, a story from inside a drug store. I’ve lost my notes on this for now, so I may return to this and expand it with exact quotes and my folded up flyer. This may seem like it’s an aside but I think the example is a good tangible one. I sometimes get blasted for being too abstract in my writing without enough examples so here we go.

The Post Office Story

Part One

A few months ago I went to a postal kiosk in a Shoppers Drug Mart. I was going to send a parcel to a friend in the United States. When I went to share the information, the woman working there told me I had to use an app. She tore off a small paper with instructions and graphics and handed it to me. I asked her how it worked. She said the app something something (it wasn’t a coherent answer, she was basically saying use the app). I told her I didn’t have the app, and also that I didn’t really understand. Then she told me that my parcel would have a better time with customs if I used the app. Then she told me I basically had to use the app, that it was mandatory. Then I asked what people were supposed to do if they didn’t have a mobile phone or internet access. To which she pointed at my phone and said, but you do have a phone. The tone of the conversation got increasingly hostile.

This hit me pretty hard because my asking questions about this thing instead of just downloading the app was making her angry. And her anger was making me feel like I was being belligerent, which I wasn’t. I was thrown off. And I was surprised to have my body doing its anger reaction, so maybe I wasn’t being perfect but I definitely wasn’t being fighty. This anger reaction is an important part of the story because when my body tells me something is maybe off, I am so grateful because it breaks through the habits of the moment I’m in. I’m hopeful this feeling in all of our bodies is something we can use to slow down and redirect the ways we’re using technology.

She asked me when the last time I had sent a package was. I told her it was probably before the pandemic started. She then said there would be a deadline when using the app/online form would be the only way to send a package to the US. Near the end of our conversation she went back on her first comment and said she *could* do it manually. Then she said she had always said that (which she hadn’t), but by that point I told her I’d take the flyer home with the instructions and try to understand what was happening and how this all worked. She could sense I was having a bit of a moment. And I could too. I try to slow down and talk slow when my body does the thing. While I was having a physiological reaction, in my head I was thinking “there is no possible way people without cell phones or access to a computer in Canada now can’t send a parcel to the US”. I was also trying to understand if this was a thing to dig in on. Sometimes my body isn’t right to have its moment, it’s more of a signal than a certainty.

On my way home from the post office I thought about the kinds of small exchanges that get lost, shaved away, worn off, when we automate parts of the ways our systems work. Or when we change the person who does the “data entry” so to speak. The change here is from me telling the postal worker what is going in the package and writing it down to me doing that online or using an app, and then printing the label, or create a code, or.… I didn’t get to the end of what this new process is because I lost patience with it for that day. also pandemic.

This isn’t to romanticize repetitive labour if it’s the wrong kind of thing to protect (more on this in part two). The way I understood the app or online form kind of reminded me of the way those of us that have done air travel fill in the customs card. Is there anything inherently wrong with that? Mmmm, is there really any other way? Are they alike enough to be useful to think about together? How do Canada Post employees feel about this app? Did they help design it? Was this coming from US customs? I still haven’t tracked down the origin story on this app yet, again, pandemic. The flyer she gave me made it sound like this app was both required and a positive thing, so maybe it was a customer service improvement idea. I don’t know.

Part Two

I went back to the post office to send the package a few weeks later. I felt compelled to test out the path for someone without internet access. There was a different younger woman working there, and when I sought to send the package without using the app, she called for someone else. Then the woman from part one returned. Her annoyance level was pretty high from the beginning. It grew as the line behind me grew. It wasn’t a brutal line and it wasn’t that long a thing to do, but it was all palpable. Then the first woman was explaining how to ship the parcel to the younger woman, explaining how they had to enter all this information themselves because I didn’t want to use the app. Out loud. Start to finish, this all probably took four minutes, but it felt really long. And that feeling of not being allowed to take time for things, that feeling and what it means is bad for all of us.

The Point

I have other versions of this story. I’m sure you do too. And I’m well aware of how who I am, demographically, allowed me to have this whole experience. It’s partially why I feel some more of us should do this. The point of this story, mostly, is that the idea that something is not mandatory rests upon the investment and maintenance of systems that work without the thing. And the people you encounter along the way that are in charge of allowing you access to systems, the incentives that drive their behaviour, and more. This postal situation is a whole story unto itself, I may pick it up, I may not. I’m not doing it justice but I’m trying to share the feelings part of it as they relate to time, our use of time, our use of time and systems, and our consideration of each other. I’m also trying to share it because this is such a simple little act of jamming and resistance that some of us can do every time we are faced with a path that is trying to make something binary when maybe it shouldn’t be. I hope you’ll note that I’m aware I might be wrong here. I might have been creating friction where more assessment will change my understanding or my future actions. But the point is also that this was low-stakes enough, and with enough room for me to move through it with adequate consideration and kindness to everyone involved in it.

What this leads me to, as a point for those inside and outside government, is that these non-binary situations are places to agitate. You can use the digital Id, you can not. You can have one and still support those that don’t have one or want one. You can support those that don’t have to get one, technically, but will be forced to practically. We all know this is a thing. Forcing support for every case, and using your energy for multiple paths. When a project is presented as a certainty, as a done deal, there is another place to open up and grow — how to keep alternatives alive and how to keep changing the way the tech works.

This is not a simplistic rejection of technology. This is buying time to think and build and be careful. This may be something for those that adopt any kind of tech to do alongside that adoption. It’s about using our power to pressure those in charge of our systems to invest and maintain in equitable services, in as much as that is possible. This is not only about keeping our labour involved in the work of defining how automation changes our systems. It’s also about knowledge retention.

When processes change, are automated, reduce exchanges between humans, cross-cut old workarounds to make systems work, there can be new trouble. Some of that relates to the single most important piece of technological and social failure that we’re terrible at understanding across the board: context. When we automate, we often lose context. Context is so vital. Some of what we know we don’t even know we know or how to explain it (visceral knowledge) and we may forget how to safeguard that knowledge in these processes of automation. For example, there are insights we may lose from getting rid of fax machines (not because of the tech, but because of the people that have been operating them). There are also many thoughtful cases about automating the right part of a process to better support people. This is never binary, but of course it’s not. The point is that in rushing to add more complexity to systems that already don’t serve everyone well and aren’t built by the people that will have to use them, generally only those well-served benefit unless we demand otherwise.

I have only ever felt the sense that a tighter net of automation has been closing in around us since I started to pay attention. There are so many branches to this evolution, and a good number of them have to do with the kinds of interactions that we are letting go of, and what that means to the future versions of how we co-exist. Our postal system is important. It’s important to me that there are a lot of us that know and understand deeply how it works.

In addition to abolition and rejection of technologies — which sometimes are the only argument to make, there is significant work to do in creating two or more concurrent paths for technologies. The problem here is often more about investing in them, and non-commercial tech, than getting them to exist. If you need some inspiration, read, follow and support Compost Magazine. Learn about how they’re doing things, on levels, operationally. It’s a bright light.


I was struck recently by the use of the term “disenfranchisment” from our decision-making regarding technology in democracies. This goes all the way to the way our money is spent, and the way our money props up industry in ways that never comes back to us. This idea of tech disenfranchisement is discussed by Ursula Franklin in her 1989 Massey Lecture “The Real World of Technology.”

The social and political and legal tendency we are being urged to create is to look very narrowly at every technology or product and then seek to mitigate specific individual harms related to privacy or security or something else. The muscle we need to develop is the one that zooms out and looks at the patterns, recent history, or future effects. Second-order impacts on the collective. The big long future. The one that everyone that has the luck to exist in Canada needs to consider. How we build and secure a society that will be welcoming to the climate refugees we will need to support. It’s always the edges where things that are said to be optional are less so. How do we continue to work to protect the space for the kind of country so many of us morally know we are going to need to be?

There is a significant need for the government to invest in unionized public sector technology capacity and non-technology capacity, to bring public service employees together better across ministries and divisions in how government work gets done. This is, at heart, an organizational and human resources challenge for the state in terms of aligning the great force of public good that is the public service with the many varied ways it can be supported to fulfill its mandate. There are cultural issues here. There are senior management issues here. There are perverse incentives issues here.

One thing we have to figure out is how to agitate for this kind of change from outside. How to demand wrap-around supports for all service delivery so that there is equity regardless of the path one takes to access any public service. And also so there is a simple and accessible path for access to justice when these systems don’t serve and support us well, as happens already too often today and is only certain to increase as a problem in future given the approach being used to digital adoption.

If you live in Toronto, there is another public consultation that you can participate in (on time) for the City’s Digital Infrastructure Plan. Many of these themes are replicated there — feedback closes on Tuesday October 19th. Here you go.

Related recommended reading/listening:

“National Digital Identity Programmes: What’s Next?” (2019) by Access Now

“The Cult of Efficiency” 2001 Massey Lectures, (2001) Janice Stein

Additional resources, added Oct 19, 2021:

eIDAS Regulation (current EU) (thank you + h/t Pierre-Antoine Ferron)

Joinup (current EU) (thank you + h/t Pierre-Antoine Ferron)

The Economic Impact of Digital Identity in Canada (undated) DIACC Member Consult Hyperion (thank you + h/t Joni Brennan)

Digital Identification: A key to inclusive growth (2019) McKinsey Global Institute (thank you + h/t Joni Brennan)

“horizon no. 1” by Jayson Edward Carter is licensed under CC BY-NC-ND 2.0