‘Digital by Default’ Consultation Paper Submission to the Australian Taxation Office (ATO)

CPSA welcomes the opportunity to comment on the ‘Digital by Default’ Consultation Paper but has serious reservations about much which is raised within it.

CPSA can understand the rationale behind offering more online services: it is cheaper to administer, produces a more standardised approach and in many cases is what the end user prefers. CPSA is not adverse to online being a primary way of interacting with Government and the ATO: what we are strongly against is it being the only, or default way to interact.

While internet usage across Australia sits at 83%, it is markedly lower among older people at just 46% for those over 65[1]. Implementing a digital by default system will discriminate against older members of the community, as well as those who are not tech savvy for other reasons, including people with disabilities, people with limited literacy in English and people who cannot afford to run a computer. CPSA fears that people who are not computer-literate will be forced to seek assistance from relatives, friends or library staff and this will not only impinge on their right to privacy but will open themselves up to potential abuse as it provides other individuals with important and sensitive information about one’s self.

Pensioners and other low income households continue to be disadvantaged and penalised by companies for being unable to conduct their business online. They are increasingly charged for the privilege of receiving a bill in paper format and charged extra to pay bills in person, for example, at the post office.

It is most concerning when Government agencies follow the same path, and hinder people from being able to access information in a format that is easily available to them. In 2013 Centrelink ceased sending out Payment Summaries automatically to pensioners, instead offering online options. CPSA heard from numerous people in their 80s who had tried phoning up only to be told it wasn’t possible to have it sent out. Until CPSA intervened, there was simply no way of having your statement posted to you. Similarly, CPSA heard from people who looked for a paper tax pack at their newsagency, only to be told that they were no longer supplied with them. In the same way the closure of Medicare branches as services move online leaves the most vulnerable people in the lurch.

Implementing an opt-out system will disadvantage those who are not online and are never likely to be. A person without access to a computer or the skills required will be forced to pay a tax agent to submit their returns. Being required to demonstrate that you cannot move to a digital service, rather than showing that you can by doing so (i.e. opting-in), will disadvantage the most vulnerable. The Discussion Paper (page 12) states that exemptions will rely on a person contacting the ATO to advise that they cannot use digital services and the reasons why. Not only is this degrading and may require people to delve into personal information they do not wish to discuss with the tax office, such a strategy will also miss those who simply won’t realise that this needs to be done. Requiring people who are frail, those with disabilities, have cognitive decline, low levels of literacy and numeracy and other stressors in their life to know that they need to get in touch with the ATO to ask for an exemption and go through the process of obtaining it and outlining the reasons why is too much for some people and it simply won’t happen and they will face penalties.

CPSA is also concerned that temporary exemptions are being flagged as an option. This may be relevant in the case of, say a natural disaster, but for someone who has a disability which is not immediately apparent, or for someone who has no intention of going online, it makes no sense that they should have to go through this process more than once, let alone at all.

CPSA also has reservations about the extent to which dealing with the ATO purely online will provide the level of service and tailored details people need. For example, Centrelink has online services which they push on to clients, yet much of the communication is very limited to basic, general information with privacy cited as a reason. People receive emails for example, rather than letter correspondence, but the emails simply ask the person to look up the website, not even a link is provided. This is not helpful to those who are not particularly competent with computers and does not provide information that applies to their personal circumstances, which clients find incredibly confusing frustrating. CPSA does not want to see this become the norm with the ATO as well. CPSA also questions whether the ATO’s online systems would be able to cope with every tax paying Australian dealing with it online. myGov and myTax have been plagued with negative publicity over the last 12 months regarding inability to deal with demand and privacy glitches [2].


[1] ABS (2014), ‘Household Use of Information Technology, Australia, 2012-13’, catalogue number 8146.0, available at: http://www.abs.gov.au/ausstats/abs@.nsf/Lookup/8146.0Chapter32012-13

[2] Examples include www.news.com.au/finance/money/tax/ato-apologises-for-online-tax-glitches/news-story/2b70c5b1a9c570c5be7342ed4a987a33  and  www.smh.com.au/digital-life/consumer-security/taxpayer-records-exposed-by-serious-ato-mygov-security-flaw-20151117-gl1kex.html