provide for student allowance and social housing will increase that amount again. The magnitude of these opposing forces and the resulting impact is not known. The aim of sharing of information for social housing purposes is to assist the proper allocation of social housing and to assist in calculating the correct rate of income-related rent the household may be required to pay for the property. This may result in a fiscal benefit or revenue savings. OBJECTIVES The main objective is to deliver better outcomes for customers by enabling a more accurate and timely provision of benefits and subsidies. All the options are assessed against the status quo in relation to the main objective and the following criteria: Efficiency of compliance and administration – gain efficiencies through a more collaborative, cross-agency work in regards to common customers and the joint administration of social policy, and provide better services to customers, reducing their compliance costs and delivering a better customer experience; Fairness and integrity – maintain the integrity of the tax and benefit systems, and ensure sufficient protection of people’s privacy and a proper level of security and transparency; Sustainability of the public sector – provide a framework that is flexible enough to respond to Government’s priorities, and facilitate changes going forward. Criterion (a) can potentially conflict with (b) if information is shared too widely or if robust security systems and processes are not established to protect people’s privacy. A balance must be reached between providing better public services and ensuring people’s information is adequately protected, so all objectives can be achieved without conflicting. REGULATORY IMPACT ANALYSIS Four options have been considered in this RIS: Option 1: Retain the status quo Option 2: Create an Approved Information Sharing Agreement (AISA) under Part 9A of the Privacy Act to amalgamate existing agreements and extend the information shared to social housing and verification of students and their parent’s income for student allowance purposes. (preferred option) Option 3: Use the information sharing framework in section 81BA of the Tax Administration Act to share information for housing assistance and verification of students and their parent’s income for student allowance purposes. Option 4: Retain the current information sharing provisions and create a specific legislative amendment in the Tax Administration Act to allow information
sharing for social housing and verification of students and their parent’s income for student allowance purposes. Option 1 Option 1 is to retain the status quo. Assessment against objective and criteria – option 1 Main objective Inland Revenue and the Ministry of Social Development must work together closely to deliver the service improvements expected by government and customers and that requires information to be available more fluidly across organisational boundaries. This doesn’t currently happen under the status quo. Efficiency of compliance and administration There are efficiency gains that cannot be achieved under this option due to the limitations of the current information sharing agreements, which are very prescriptive. Fairness and integrity This option ensures sufficient protection of people’s privacy and a proper of security and transparency. However, the benefits are limited and do not result in improvements in the integrity of the tax and benefit systems. Although Inland Revenue shares information with the Ministry of Social Development to ensure integrity of benefits, information is not shared in relation to student allowance or social housing. Sustainability of the public sector This option is not future proof as it is not flexible enough to respond to the upcoming organisational changes, Government’s and customer’s expectations. Option 2 This option would create an AISA, which is a legal mechanism enabled under the Privacy Act 1993 authorising the sharing of information between or within agencies (either from one agency to another or sharing by both agencies) for the purpose of delivering efficient and effective public services. With this option the current legislation would be amalgamated into one AISA and would operate under its authority. Also, the information shared would be extended to include information for assessing eligibility for social housing and student allowance. set out how information is to be shared according to the requirements of the Privacy Act. They also provide the necessary flexibility to enable efficient information sharing, and provide appropriate systems and processes to protect people’s privacy. While AISAs do not apply for the sharing of information between non-individuals, that does not cause any concerns as the information sharing considered in this RIS is entirely relating to individuals.
Assessment against objective and criteria – option 2 Main objective The AISA framework was created for the purpose of delivering efficient and effective public services, so this approach to information sharing provide easier and faster access to government services and reduced compliance costs for customers. From a customer perspective, greater sharing of customer information facilitated by the proposed AISA would, over time: reduce the need for individuals to interact with agencies on multiple occasions or to provide duplicate information to government agencies; make it easier for individuals to meet their obligations, thereby reducing adverse outcomes such as accumulating debt; and meet evolving expectations of the public to provide joined-up social services across government agencies. This option the main objective. Efficiency of compliance and administration The AISA would continue the existing information sharing and provide a wider purpose for using the information. This would enable agencies to provide services more efficiently and effectively, by improving the timeliness and accuracy of benefits and subsidies, and assisting the assessment of tax obligations. It would reduce the administration costs associated with agencies sharing information, and create public confidence through the perception of agencies’ efficiency in managing customer information – sharing the right information, in the right way, at the right time. It would also reduce compliance costs for customers as they would not be required to provide the same information multiple times. This is a significant improvement on the status quo. Fairness and integrity The AISA clarifies and improves the rules around how agencies share personal information, while ensuring safeguards are in place to protect an individual’s privacy. It would provide certainty around the purpose of information sharing, use of information, and management of privacy risks; it can also modify privacy principles when justified. AISAs provide a transparent approach to sharing, as all agreements are made public and consultation is required for any agreement. This is an improvement on the status quo. Sustainability of the public sector An AISA is easier and faster to amend to include sharing of additional information and other agencies in comparison to the status quo process for changing legislation, providing a more future-proof framework for sharing information. From a government and agency perspective, the wider scope of the agreement and having all information sharing under one agreement would, over time, contribute to the Government’s Better Public Service objectives of better service to New Zealanders, and provide a foundation on which to base future sharing of information among the two agencies. This is an improvement on the status quo.