Government needs to beware the easy promise of Covid certification

The prime minister’s roadmap has put vaccine passports – or Covid status certification, as the government calls them ^[1] – in play as a possible way to accelerate the country’s return to some form of pre-pandemic normality. This could allow people who have had a vaccination (or tested negative for Covid-19) greater rights and freedoms – such as going to restaurants or traveling internationally – and the government to relax restrictions in particular cases.

Cabinet Office minister Michael Gove will lead a review into the possible use of certification, including the ethical, legal, equalities, economic, social and practical implications. The government is working with the WHO and other institutions on the international aspects. ^[2]

After a year of pandemic restrictions, everyone is looking for a straightforward solution and as rapid a return to normal life as possible: vaccine passports or Covid certificates are an appealing prospect.

But the government should beware the lure of a tech-solutionist silver bullet. It has done exactly the right thing in holding a review before allowing their use, but it needs to know what problem it is trying to solve.

Vaccine success has revived interest in Covid certificates

At the start of the pandemic, some countries considered ‘immunity certificates’ granting greater rights and freedoms to those who had already had Covid-19. ^[3] The World Health Organisation (WHO) warned against this given the lack of evidence that having the virus led to lasting immunity and the risk that people thinking they were immune would spread the disease.

The recent development of vaccines offering some protection against Covid-19 has revived interest in certification, with the WHO, a number of countries and private companies investigating schemes. Israel has introduced a ‘green pass’ allowing people to attend cultural events. ^[4] Many schemes focus on vaccination as a basis for certification, but could allow test results (negative for Covid or positive for antibodies from a previous infection) to be used too.

The UK’s stance has fluctuated. ^[5] Vaccine minister Nadhim Zahawi ruled out passports in early February, saying they would be discriminatory with an unclear impact on the spread of the virus. This echoed earlier comments from Michael Gove. ^[6] At the same time, however, Innovate UK (the UK government’s innovation agency) funded some feasibility studies and pilots. The review announced in the government’s roadmap out of lockdown puts passports back on the agenda. Reports suggest the existing NHS app – not to be confused with the contact tracing app – could be used. ^[7] But it looks like the government is still agnostic about the value of certification, with recent comments from the prime minister acknowledging political divisions in his party (and government). ^[8] Reports from the Ada Lovelace Institute (whom this author is working with) and the Royal Society have urged caution and highlighted the challenges (not least the lack scientific evidence), while the Tony Blair Institute for Global Change has urged the government to take the lead on the issue. ^[9]

What problems does government think certification would solve?

Before answering big questions around ethics, discrimination and privacy that inevitably flow from a scheme using personal data to allow some citizens greater freedom than others, the government needs to answer the basic questions about its objective in allowing Covid certification to be rolled out: what are the problems to which ‘Covid certification’ is the answer? 

The roadmap suggests that the government thinks certification could help reopen the economy, ease social distancing and improve safety. But which is the priority? Certification might suggest a focus on individuals and opening up the economy over collective public health. Vaccine passports can promise an easy binary distinction (I’ve had a vaccine, I’m safe) which is reality a false one – vaccines are not 100% effective, and the efficacy of each differs. I might be granted entry to a pub or restaurant on the basis I will not transmit the disease to others, but this can never be conclusive. (Who would be liable for a Covid outbreak in this instance – me, the venue, the app manufacturer, the manufacturer of the vaccine or test, the authorities approving all the above?) As previous IfG work has shown, government needs to be clearer in communicating risk and uncertainty.  

The government also needs to know where this tool might work, and where it will struggle. Certification may have some uses in some settings: international travel is one example, frontline workers (for example, in care homes) may be another. Even here, the government should consider whether rolling out shiny new systems is the best solution, or whether there are existing models and mechanisms that could be adapted instead. For example, there are already Yellow Fever certificates for international travel; there may be elements of existing health and safety law that could be adapted. And as we have already seen with the contact tracing app and the exam algorithm, that excessive enthusiasm for seemingly straightforward technical solutions to complex societal problems can heighten difficulties rather than help ease them.

Would any benefits outweigh the inevitable downsides?

Any scheme that grants freedoms and rights to part of the population and denies them to others will lead to discrimination and other drawbacks. Access to vaccinations and tests will vary and any scheme could exacerbate inequality; already privileged groups might benefit and already marginalised ones suffer (for example, vaccine take up is already lower in some BAME communities). This is particularly true of any primarily digital scheme that relies on smartphones.

The government also needs to consider the data and digital infrastructure around any such scheme. Personal data doesn’t get much more personal than that around our health and our identity. We currently trust the NHS with our personal data more than anyone else – what impact would using the NHS app have on that trust? Note the concern when test and trace data collected for one purpose was then shared with police for another, for example. ^[10] How will we feel about others – our employers or bouncers at hospitality venues – having some sort of access to that data?

Some schemes could also accelerate efforts to introduce digital identity systems that could be used more widely. The government is currently consulting on a new digital identity framework, ^[11] and working out how best to replace its existing Verify system. If government or identity providers want to have a conversation about digital identity systems, that is a discussion they should have with the public on its own terms; rapid development around vaccine passports should not drive future decisions.

The government might conclude from its review that it should not roll-out a national vaccine passport scheme, but individual businesses could adopt their own certification system. These systems will have an impact on public health, on the economy and on privacy, rights, equality and discrimination. The government will need to take a position, which might include some form of regulation. 

The success of the vaccine roll-out and the government’s roadmap full of lockdown-lifting dates has created much optimism around the prospect of restrictions being lifted soon. If that is the case, then the government must be sure of the benefits, if any, that certification can add to the collective immunity against the worst consequences of Covid being built by vaccination and better treatment; and whether any such benefits outweigh the harms any scheme could cause.

Gavin is currently working as a consultant on the Ada Lovelace Institute’s project on vaccine passports and COVID-19 status apps, but is writing here in his capacity as an associate of the IfG.