Impact assessment

Customer Engagement Platform - Secure Messaging Service (SMS) Deflections (January to March 2023) - screening equality impact assessment

Published 22 June 2023

Project objectives

As an optimisation opportunity to improve customer experience and reduce resource demand, HMRC is encouraging customers to self-serve where possible The Secure Messaging Service (SMS) Trial is using deflective messaging to encourage customers to self-serve on the digital channel

Six specific queries have been considered and the customer will either be:

1. offered an SMS.  If the customer accepts, they are disconnected.  If they refuse, an SMS they continue to route
2. issued with an SMS and disconnected
3. issued with an SMS and can continue to route

This screening equality impact assessment covers the deflection activity between January 2023 and March 2023 and similar activity going forward. Any alternative deflection approaches used will be impacted separately.

Customer groups affected

All customers who contact HMRC via the self-assessment helpline, PAYE helpline or National Insurance helpline,

What customers will need to do

What customers need to do as a result of the change

If a customer calls the self-assessment helpline, PAYE helpline or National Insurance helpline from a mobile number, they will be offered 3 separate options as below:

1. offered an SMS, if they accept, the customer is disconnected. If they refuse an SMS, they continue to route
2. issued with an SMS and disconnected
3. issued with an SMS and can continue to route

How customers will access this service.

The customer will access the service by calling the existing HMRC telephone number and if calling from a mobile number, the Interactive Voice Response (IVR) process will determine which route the customer is put through to. In some cases, the customer will get the option to answer yes/no questions, this will determine the direction their call will go.

When customers need to do this

Customers may contact HMRC when they have query. The customer will need to follow the instructions by the IVR messages or SMS as directed.

Assessing the impact

We assessed the impact on those in protected characteristic groups in line with the Equality Act and Public Sector Equality Duty and section 75 of the Northern Ireland Act:

• racial groups
• sex
• gender reassignment
• sexual orientation
• religion or belief
• pregnancy and maternity
• marriage and civil partnership
• people with dependants and those without (carers)
• political opinion (in Northern Ireland only)

There is no evidence to suggest any specific impacts on those customers within any of these protected characteristic groups.

The following potential impacts were identified for customers from the following protected characteristic groups.

Disabled

Impact on customers

Customers with visual impairments may be impacted as they may not be able see and/or read the SMS messages sent.

Customers with hearing impairments may be impacted as they may not be able to hear any IVR messages and potential contact numbers/information.

Neurodivergent customers, such as those with dyslexia may find it difficult to understand the SMS messages and instructions.

Customers with voice projection and/or speech disabilities may not be able to project their voice when using IVR.

Customers with mental health issues may experience increased anxiety if they are cut off.

Customers with learning and/or physical disabilities may not be able to fully understand or follow the instructions noted in the text. Additionally, they may not have the physical ability to make a note of the extra support team phone number given in the voice message.

Customers with extra support needs may find it difficult to access Extra Support Team services due to an increase in demand.

The deflection service is compatible with Relay UK services.

Proposed mitigation

The journeys selected for hard disconnects are for customers who are trying to engage with an online process i.e., to recover SA credentials and enrolment. These customers have been selected as they are already engaging with our online services and platforms.

Customers who are unable to project their voice for the IVR when calling HMRC are routed to an option menu for that line of business where they can use the keypad to select options.

To ensure they are easy to understand and follow, all SMS messages have been reviewed by HMRC Communications and Security teams prior to being published.  Moreover, as part of the review process, more data will be obtained from relevant teams in July.

Where the deflections signpost to GOV.UK pages, these have been reviewed to ensure GDS accessibility checks had been completed.

Customers will be able to ask friends and family to support them in accessing GOV.UK self assessment information. However, this does not extend to registering for online service outside without the Trusted Helper Scheme as this will require access via government gateway.

Voluntary and Community Sector (VCS) organisations can support customers.

Customers on the automatic deflection line, are issued with a text message before disconnection and will also hear the IVR message which plays the extra support telephone number to the customer over the phone.

To mitigate against customers being concerned about fraud the text message advises of the following: ‘Please do not reply to this text. Do not give out private information (such as bank details or passwords), download attachments or click on any links in emails or texts if you’re not sure they’re genuine.’

IVR message has been reviewed by HMRC Communications where applicable.

The deflection service is compatible with Relay UK services.

Age

Impact on customers

Evidence shows that customers aged over 65 years are more likely to be impacted due to being less digitally able. Moreover, customers aged over 65 are more likely to have hearing and visual impairments as well as neurological conditions such as Parkinson’s Disease, dementia and Alzheimer’s Disease.

Similarly, those aged over 65 are much more likely to have physical impairments and impaired motor functions. The impact of these could include limited dexterity and difficulty in using SMS functions and smart phone keyboards.

Although evidence suggests a high proportion of over 65-year-olds have a smartphone, it is not assumed that they will be fully capable in accessing the online guidance signposted within the text messages.

The over-65 age group, have fewer sources of support in accessing in digital services.

The 16 to 24 age group could be impacted if they do not have a National Insurance number or other identifier. This could result in our online credit search agency not being able to verify them to self-serve through Personal Tax Account/Business Tax Account because of limited information.

Proposed mitigation

The journeys selected for permanent hard disconnects are for customers who are trying to engage with an online process i.e., to recover SA credentials and enrolment. These customers have been selected as they are already engaging with our online services and platforms.

Customers who are unable to project their voice for the IVR when calling HMRC are routed to an option menu for that line of business where they can use the keypad to select options.

To ensure they are easy to understand and follow, all SMS messages have been reviewed by HMRC Communications and Security teams prior to being published.  Moreover, as part of the review process, more data will be obtained from C relevant teams in July.

GOV.UK pages have been reviewed to ensure GDS accessibility checks had been completed.

Customers will be able to ask friends and family to support them in accessing GOV.UK SA information. However, this does not extend to registering for online service outside without the Trusted Helper Scheme as this will require access via government gateway.

Voluntary and Community Sector (VCS) organisations can support customers.

Customers on the automatic disconnection line, are issued with a  text message before disconnection and will also hear the IVR message which plays the extra support telephone number to the customer over the phone.

To mitigate against customers being concerned about fraud the text message advises of the following: ‘Please do not reply to this text. Do not give out private information (such as bank details or passwords), download attachments or click on any links in emails or texts if you’re not sure they’re genuine.’

IVR message has been reviewed by HMRC Communications where applicable.

Customers identified as not having a National Insurance number through IVR questioning will not receive an SMS option and will continue to route through to an advisor.

People who use different languages (Including Welsh Language and British Sign Language)

Impact on customers

There may be an impact on customers who are unable to understand the IVR messages or read English SMS messages.

Proposed mitigation

It is expected that friends and family will be able to support customers with language barriers. In addition, those who do route to an adviser will be supported by the ‘BIG WORD’ interpretation services, if needed.

There is a dedicated Welsh phoneline for Welsh speaking customers where the SMS deflection has not been deployed.

Opportunities to promote equalities

We have considered opportunities to promote equalities and good relations between people in each of the protected characteristic groups and those outside of that group.

None have been identified within the scope of this activity.

A full equality impact assessment is not recommended.