Do a tax check when renewing or applying for a licence
The report for the Do a tax check when renewing or applying for a licence alpha assessment on 04 August 2021
Service Standard assessment report
Do a tax check when renewing or applying for a licence
Confirm an applicant has done a tax check
| From: | Central Digital & Data Office (CDDO) |
| Assessment date: | 04/08/2021 |
| Stage: | Alpha |
| Result: | Met |
| Service provider: | HMRC |
Service description
The hidden economy consists of individuals and businesses with sources of taxable income that are entirely hidden from HMRC. The hidden economy tax gap is estimated to be £2.6 billion for 2018 to 2019.
New legislation introduces the concept of ‘conditionality’. This makes tax registration a condition licensees need to meet to renew a licence to provide services, like taxi driving or collecting scrap metal.
The purpose of the tax check is to enable HMRC to be satisfied that the applicant has complied with their obligation to be registered for tax.
The new rules will come into effect from 4 April 2022.
For the purpose of our service, the following actions are constituted as a transaction:
- when an applicant confirms their information and submits a record for a tax check code
- when a licencing body validates a tax check code
Service users
This service is for
-
Licence applicants will need to use our service if they are renewing or applying for a subsequent licence for one of these licence types:
- Taxi
- Private Hire Vehicle
- Scrap Metal Collector
-
Scrap Metal Dealer
- Licensing Bodies - Licensing officers who process applications will use our unauthenticated service to check an applicant’s tax check code
- Customer Services Group Operators at HMRC will use our internal service to serve customers who need to use the offline journey
1. Understand users and their needs
Decision
The service met point 1 of the Standard.
What the team has done well
The panel was impressed that:
- the team seemed really on top of the user research and using it to drive everyone’s understanding of users and their needs. They are doing regular research which is informing design, and testing the team’s riskiest assumptions
- overall the team seemed very aware of where their own gaps in understanding about their users were. They had clearly reflected on a number of ways to fill these gaps and had plans to do so (for example how they might find scrap metal users, or work around the challenges of not being able to use non-compliant users)
What the team needs to explore
Before their next assessment, the team needs to:
- ensure that they are building up a clear understanding about the needs of users with a range of access needs, and the needs of users on mobile devices, and doing regular research with both. The team has had a complex landscape to learn about at Alpha, and have had a bit of a focus on assisted digital needs so far, however these also need to be a priority at Beta
- continue to research the unhappy paths of three connected services’ journeys to ensure these stress cases are well understood
- ensure they are testing the end to end journey, particularly around communication and awareness in the build up to renewal, to ensure that the team’s assumptions around user’s needs in this area are validated
- explore whether there are other related user groups who might be able to help the team build their understanding of the scrap metal dealer user group
2. Solve a whole problem for users
Decision
The service met point 2 of the Standard.
What the team has done well
The panel was impressed that:
- the team is informed of the end-to-end journey of the service
- the team has considered various happy or unhappy paths within the end to end journey
- the team have considered the various user groups involved in the service
- the team acknowledged biases in user research and have addressed strategies to mitigate them
- the team has mapped out various user groups and their user needs. The team also tested some of the earlier hypotheses around involving agents during the process and have demonstrated plans to continue to do so
- the team applied data minimisation practices and has considered the privacy of users by not revealing personal information with the licensing agency
What the team needs to explore
Before their next assessment, the team needs to:
- as recommended in the internal HMRC assessment, continue to fully explore and rigorously test the support channels to ensure that the user needs are taken into account
- the team demonstrated the scalability of the service in the existing design. Suggest this is in check with the policy team and other stakeholders on a regular basis to make sure any dependencies are considered
3. Provide a joined-up experience across all channels
Decision
The service met point 3 of the Standard.
What the team has done well
The panel was impressed that:
- the team raised sharing data for strategic solutions and offline solutions for identity verification with the policy team
- the team tested the riskiest assumptions around integrating API for licensing bodies and had extensive discussions with principal licencing officers and service lead
- the team has created micro-services to create a joined-up experience
- the team has considered providing education and communicating needs for people who cannot complete the online journey through guidance pages in the various exit routes
- the team explored whether a user need to connect individuals HMRC tax assessment portal with the tax check code, there are no instances of this need based on user research so far
What the team needs to explore
Before their next assessment, the team needs to:
- the team is aware of email notification as a user needs. Suggest exploring already available government platforms such as Notify to deliver at pace
- the team should do research on back of stage integrations to provide a clear understanding of what is relevant and possible, such as could a single authentication process reduce data entry during renewal?
4. Make the service simple to use
Decision
The service met point 4 of the Standard.
What the team has done well
The panel was impressed that:
- the team has used known design patterns provided by gov.uk design system
- the team is practising agile ways of testing and iterating design
- the team is actively feeding back research to the design system community
- the team has acknowledged the riskiest assumptions around Government Gateway for users, format of tax check codes and has explored these with users to overcome any barriers
What the team needs to explore
Before their next assessment, the team needs to:
- the team has plans to add the service to GOV.UK start pages before launch. This is a key part of the service and any changes might have an impact on the whole journey, so this must be added as part of the end to end journey testing and iterated as necessary
- the service pages have in some instances used variable form components. The team should ensure consistency is maintained, here’s a blog on being consistent not uniform
- usage of long form should be backed up by evidence of user need, else known components and patterns such as question pagesshould be considered
- the services pages have plain content laid out, this might be difficult for users to navigate and increase cognitive load. The team should explore breaking down the content into readable parts with proper content hierarchy wherever necessary. And explore design systems components such as warning Text to break down content, and this must be tested with users
- the team should explore alternative ways to understand non-compliant users such as speaking to the accountants or lawyers who might’ve had experience with such cases
5. Make sure everyone can use the service
Decision
The service met point 5 of the Standard.
What the team has done well
The panel was impressed that:
- the team is aware of the need to test and iterate with all the different user groups across channels, screen-size and end-to-end. And has demonstrated them in their roadmap as priorities before beta launch
- the team has developed a specific telephone service to help ensure there is a clear path for users with limited or lower digital skills
- the team has considered a broad range of users such as users whose first language is not english, first time users and Scrap metal trade users
- the service team has plans in place on implementing the DAC audit recommendations before the public beta launch
What the team needs to explore
Before their next assessment, the team needs to:
- the team must test and iterate the journeys with assisted digital users and users with low digital confidence before launch. Suggest to speak to other government departments for knowledge sharing around users with accessibility needs.
- the team must use meaningful and contextual alternative texts for images and must test this with users
- the team built an internal system for internal support staff. The team should continue with their research and iterate the system with the internal scripts for natural flow and avoid any human typing errors
- the service is still in its initial stages and needs thorough testing with all user groups (especially users with access needs, and on mobile devices), the team must continue testing and iterating the design
- As recommended in the internal HMRC assessment, the team should continue to do extensive testing with mobile as has been pointed out as a preference for the majority of users.
6. Have a multidisciplinary team
Decision
The service met point 6 of the Standard.
What the team has done well
The panel was impressed that:
- all key roles are covered in the team
- an HMRC scrum master has been brought into the team
- despite being almost entirely made up of suppliers, the team is empowered to deliver the service
- the team is collaborating closely with HMRC colleagues in the HCD project team
What the team needs to explore
Before their next assessment, the team needs to:
- consider bringing more civil servants into the team, particularly whilst there is the opportunity to learn from the supplier team
- mitigate for the team team being almost entirely made up of contractors by having a plan in place for handing over knowledge to HMRC colleagues and ensuring there is no single point of failure
- ensure that the Service Manager is included as part of the team
- continue to collaborate closely with the Hidden Economy Conditionality project team
7. Use agile ways of working
Decision
The service met point 7 of the Standard.
What the team has done well
The panel was impressed that:
- the team are working in two week sprints with sessions to review goals and weekly summaries to a wide group of stakeholders
- there is a governance process and a point of contact for escalation to the Project Board through the Service Manager
- the team are feeding into the comms team to inform guidance for the service
- the team ensure that they have a definition of ready and a definition of done for each sprint item
What the team needs to explore
Before their next assessment, the team needs to:
- continue to ensure that the Project Team and wider policy stakeholders are included in agile ceremonies where appropriate so that they can learn about and become more familiar with the benefits of agile ways of working
- as recommended in the internal HMRC assessment, the team should ensure that good practices like Sprint reviews and team retrospectives are effectively used to monitor progress against the roadmap and understand how and when a need for additional resources, or change of approach can be identified and escalated.
- as recommended in the internal HMRC assessment, continue to work closely with Policy and stakeholders to influence how the service and approach needs to change as knowledge from real users is gained
8. Iterate and improve frequently
Decision
The service met point 8 of the Standard.
What the team has done well
The panel was impressed that:
- in response to feedback from user research, he team have done at least 3 iteration of each part of the end to end service during the last 3 months
- the team have worked with Policy to remove the declaration from the service
- the service will be built so that it can be scaled for other types of licence should that be needed
- the team were able to give examples of how they had changed the content in response to user research
- there is a user research plan for beta that includes offline, accessibility and additional licences
What the team needs to explore
Before their next assessment, the team needs to:
- continue to test and iterate, particularly with those who are not able to use the service and with Scrap Metal licence holders
9. Create a secure service which protects users’ privacy
Decision
The service met point 9 of the Standard.
What the team has done well
The panel was impressed that:
- the team has a strong understanding of the security risk of the service, in particular regarding the nature of the data that this service will require and will consume via other services, and are minimising the PII data required to use the service. They believe opportunities for fraud are low. A Data Privacy Impact Assessment will inform a Security Risk Assessment
- the team are using the Government Gateway service to provide user identification functionality, but also have a process established for those users who may be currently unable to use Government Gateway. The team has also provided input to the Identity Verification team with a view to enabling DVLA data to be used as an additional identification source, although that work strand is unlikely to complete before this service needs to launch
- the team have identified measures to limit requests in the event of an attempted misuse of the ‘Licensing Body’ service front-end
- HMRC have a broader team that monitors and provides security guidance
- the team will be implementing continuous ZAP testing and will undertake a formal penetration testing exercise before going live
What the team needs to explore
Before their next assessment, the team needs to:
- ensure that any recommendations from continuous testing, or from one-off penetration testing are implemented
10. Define what success looks like and publish performance data
Decision
The service met point 10 of the Standard.
What the team has done well
The panel was impressed that:
- the team have run workshops to discuss how to measure success for both the service and the business
- a performance framework has been created, mapping users, user needs, metrics and what is needed to obtain the metrics to measure the critical success factors
- dashboard wireframes with dummy data are being created to show how the data can be presented to stakeholders
What the team needs to explore
Before their next assessment, the team needs to:
- the team should ensure that targets are discussed during private beta as planned
- continue to work on the plan to show how success will be measured
- speak to data.gov.uk
11. Choose the right tools and technology
Decision
The service met point 11 of the Standard.
What the team has done well
The panel was impressed that:
- HMRC have a common technology stack for new services that are expected to be adhered to, meaning the service teams’ choices are relatively limited; however, the service team is able to challenge this if they do find a need that cannot be met by this existing stack. In this case there was no need to challenge as it was felt that the existing technologies would suitably meet the needs of the service
- the team have a good sense of the technology considerations of adjacent service teams, and are aware of how changing approaches elsewhere may impact upon this emergent service, for example, a proposed shift away from the current CDN provision
What the team needs to explore
Before their next assessment, the team needs to:
- the change to the Content Delivery Network service provision is not without risk, although it is largely outside of this team’s control. The team should seek to keep informed of these wider changes so they are well-placed to react to, or otherwise mitigate any additional risks that may emerge from that work
12. Make new source code open
Decision
The service met point 12 of the Standard.
What the team has done well
The panel was impressed that:
- HMRC have a well established and positive approach to coding in the open, that this service will adhere to
- although there was no code written for Alpha, the team has already prepared three repositories in advance of the Beta work commencing
What the team needs to explore
Before their next assessment, the team needs to:
- ensure that the coding-in-the-open policy is adhered to, and that any exceptions are carefully considered
13. Use and contribute to open standards, common components and patterns
Decision
The service met point 13 of the Standard.
What the team has done well
The panel was impressed that:
- for Alpha the team made very good use of existing tools and components, such as the GOV.UK Prototyping Kit
- the team identified a gap in the Prototyping Kit and submitted that back to the maintainers of the kit for future inclusion
- the team is reusing patterns from the Making Tax Digital Programme (MDTP) programme and integrating with/sharing other services within the programme
What the team needs to explore
Before their next assessment, the team needs to:
- continue to look for opportunities to contribute to open standards, components and patterns
14. Operate a reliable service
Decision
The service met point 14 of the Standard.
What the team has done well
The panel was impressed that:
- the team has a good sense of their expected use patterns, and are planning for capacity testing accordingly
- HMRC have a well-established Platform Operations function that ensures that individual service teams aren’t burdened with additionally managing the day-to-day resilience and scaling of the service
- the team have established a process/approach in the event of the service being unavailable for an extended period