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• What exactly does the exemption mean,
is it merely a deadline extension?
taken
(Via comment on slide 6) ‘clarify your objectives’ –
No action taken
We consider this is incorporated as part of
may want to clarify what our definitions of success
criteria 9 and 10. We also note that the DSS
are for the service
should not be applied in a linear way and
therefore it will be applied consistently
throughout the project lifecycle. We will make
sure the guidance reflects this.
(Via comment on slide 6) ‘Do you understand the
Added policy as part of the following dot point: Agreed. We have updated the text accordingly.
Act
policy lever this service is trying to address? The
impact to the citizen?’
Understand how your service supports delivery
of policy and strategic government initiatives
such as the Data and Digital Government
Strategy.
(Via comment on slide 6) If we are removing the
Added a dot point to refer back to Services
We have been working with Services Australia
'Don’t forget the non-digital experience' should we Australia’s Customer Experience Standard.
on their multi-channel
Customer Experience
be encouraging at this stage to also identify how
Standard, so have referred to this as the
the service can be accessed outside of the scope of
Consider the non-digital experience through
appropriate angle for considering the non-
under FOI
digital to keep the services in alignment at least?
Service Australia’s Customer Experience
digital experience.
Standard
(Via comment on slide 7)
– There is a train of
No action taken
We do not have a lot of detail about this
thought around Personas being dead, and a shift to
concept. Lisa will reach out to Andrew to discuss
mindsets. May be worth considering if we want to
further.
articulate that explicitly.
https://www.nsw.gov.au/onecx/blog/designing- Released
content-for-customer-mindsets
https://govservicedesign.net/programme/mindsets-
vs-personas
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https://codefor.ca/blog/goodbye-personas-how-
mindsets-can-help-you-build-empathy-and-reduce-
bias
(Via comment on slide 8) It may be also worth
Updated to incorporate language from the
We have been working with Services Australia
around digital inclusivity also around bandwidth,
DDGS around digital inclusion on Slide 8.
on their multi-channel
Customer Experience
device (mobile vs desktop), connectivity (poor or
Standard, so have referred to this as the
sporadic internet availability)
Consider the non-digital experience through
appropriate angle for considering the non-
Service Australia’s Customer Experience
digital experience and those with poor
Standard
connectivity.
(Via comment on slide 8) Should we call out explicit Have included a reference to the Australian
We have referred back to the Australian
Act
standards such as the Flesch-Kincaid readability
Government Style Manual.
Government Style Manual to support alignment
test, and factor that into the AGA as a standard?
with Government requirements. We could
Use plain English to support people to
connect to the other resources mentioned in
understand what they need to do, through the
the criteria’s resource section (once built out).
Australian Government Style Manual.
(Via comment on slide 9) - Would we also activity
Updated slide 9 to include:
encourage engagement with states and local for a
true-joined up experience? So 'For Bonus Points -
Consider how you can link-up with existing state
join up with the states!'
and territory digital services, where appropriate.
under FOI
(Via comment on slide 9) - Not only ask for it once,
No action taken.
We consider this is addressed in criteria 7.
but from the outside, architect what you must have,
and what is nice to have. What will you do with the
data from a cybersecurity perspective? Only use it
for the transaction and then discard it? Keep it
ongoing? Will you make that data available to other
services or systems?
(Via comment on slide 9) - Also support
Updated slide 9 to include:
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interoperability between sharing common datasets
(open data)
Encourage interoperability between sharing
common datasets (open data).
(Via comment on slide 10) – Should we be also
Updated slide 10 to include the following dot
encouraging to seek out during this stage what are
point:
the security requirements, or breach notification
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requirements? The Cybersecurity theme may not be
Consider the cyber security requirements
strong enough in this message
needed to support your service.
(Via comment on slide 11) - Are we actively
Noted.
Chris has highlighted a preference to move away
dropping the making 'source code open by default'
from open source to open standards. It would
principle? Is there a reason that we arent
be good to understand the two sides of this
encouraging the share-back approach?
argument a bit further – we will schedule some
time with you to discuss.
(Via comment on slide 11) - Could we make this
Updated Slide 11 to include:
stronger to help understand at this point what the
spectrum of reuse may be? The service they are
Understand what processes or documentation Act
designing could be anywhere on the spectrum of
could be re-used.
1. Re-use of documentation/process (business case,
architecture, operating models, procurement
approaches)
2. Re-use of the system (make the system
modular/configurable so that it is relatively easy to
provide a copy of the service or solution to
someone else to build upon/extend your solution or
change it slightly)
under FOI
3. Is it a candidate for a white-label service (or
components of your service)? What components
could you white-label to allow others to use in real-
time also? (an API gateway to a service, a dataset).
What costs or operating model should be
considered?
I think this is an important piece, as it really goes to
Released
re-use. Reuse doesn’t have to be the whole system,
but we should try to articulate what parts could be
re-used.
(Via comment on slide 12) - Including data lifecycle Updated slide 12 with the following dot point:
and retention management. Do you need to store
it? What is the risk of capturing it and being able to
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Organisation, personnel, collective training, major
Consider the fundamental inputs and
systems, supplies, facilities, support, command and
integration required for your service.
management. Obviously not all relevant but they go
to considering all elements of success are
considered and not overlooked. A good example I
have found was where a focus was on building a
plane but everyone forgot about alterations to the
runway. If you are joining up services they need to
design in consideration for not only users but those
integrating with the service.
Act
Design for everyone is implied but might need more
detail
(Via comment in slide 8)- people may consider from Noted.
only a UX perspective rather than a back-end
perspective
(Via comment in slide 9) - Can reference AGA on
No action taken.
This is reflected on slide 11 – criteria 6.
reusable technology
(Via comment in slide 10)-
There could be a missing Noted.
We will build on this throughout the detailed
under FOI
piece around POCs and pilots to build trust through
DSS document and guidance.
testing and design. smaller investments over large
big bang approach that try's to do too much but
then doesn't deliver.
(Via comment in slide 12)- Consider adding in a
No action taken.
We consider this is covered on slide 11 under
reference to check AGA for the latest advice and
criteria 6.
guidance,
(Via comment in slide 14)- Agree there should be
Noted.
While we understand your point, the DSS should
Released
something about establishing a what good looks
not be applied in a linear way and therefore it
like before you even start and understanding
will be applied consistently throughout the
desired end state and mapping out how you PLAN
project lifecycle. We will make sure the
to get there. Metrics should be set around success
guidance and detailed documentation reflects
milestones ie if your not adding value along the way
this.
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https://www.accessibility.sa.gov.au/policy/south-
australian-government/online-accessibility-policy
(Via comment on slide 5) - Working in State
Updated slide 5 to include the following dot
We may reach out to you to understand this one
Government, this was the single point of failure for point:
further and how we can build out the definition
the old/current standard. The Digital Service
in the detailed DSS document.
Standard was quoted as a reason why internal
Internal to government (staff facing) services,
solutions were not being made accessible (out of
such as:
scope) when teams redevelop internal facing
•
Intranets
solutions such as intranets, learning management
•
Learning management systems
systems, records management etc. In general APS
Act
•
Records management system
and State Gov staff are trying to do the right thing
but just having the scope as public facing seems at
odds with the quoted move to increase
employment opportunities for people with
disability in the APS (if internal solutions are not
being made accessible, how are we going to attract
and keep staff with visible and hidden disability?).
For an example of internal facing see scope at:
under FOI
https://www.accessibility.sa.gov.au/policy/south-
australian-government/online-accessibility-policy
(Via comment in slide 5)- Why just ‘high volume’?
Noted. Updated to remove ‘high volume’ as
Shouldn't this be setting the standard required
language could be confused with ‘existing high
from/expected by government for all digital
volume services’.
channels whether public facing or staff facing? APS
as the employer of choice etc.
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SAGOV experienced the same issue when
redesigning their policies, when should the new
policy apply, as in it's not feasible or realistic to
retrofit existing/old solutions
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deliver the product or service. Whether this takes
on the old 'discover, alpha, beta, live' or possibly a
re-arrangement of the 10 principles to articulate
the importance of a staged approach.
How are we considering the non-digital
Added a dot point to refer back to Services
We have been working with Services Australia
experience/channels? It's important to draw
Australia’s Customer Experience Standard.
on their multi-channel
Customer Experience
attention that digital or one channel is unlikely in
Standard, so have referred to this as the
any service and that designers, researcher and
Consider the non-digital experience through
appropriate angle for considering the non-
developers need to consider the integration to
Service Australia’s Customer Experience
digital experience.
deliver a seamless experience. This should consider
Standard
Act
things like digital literacy or experience overlaps.
Slide 7 - User researchers prefer "behavioural
Updated to include the below dot point:
archetypes" or "user types" which may have been
mentioned in slide 6 by other commenters. There is
Identify your user groups and any behavioural
an ongoing debate in this space and the language
archetypes that need consideration.
may shift over time, but there is a preference for
this language currently over "personas". The first
article you provided to the group when seeking
feedback also outlined the reasons for this
under FOI
language.
Slide 18 - There are a number of external forums
Noted.
We are running a session with the Digital
that this can be tested with. This includes the “Data
Profession community in 2 weeks to take them
and Digital Professions members' community” run
through this.
by APSC Digital Profession.
(Via email) It's worth considering how these
Noted.
If you have any suggested private sector
guidelines will be used by non-government
partners that we could engage with, we would
designers, researchers, product managers, and
appreciate you passing on their details.
Released
developers as a signpost for best practice. It is
extremely valuable to have something with gravitas
to point to when you are working in the private
sector. To this end, it might be beneficial to reach
out to private sector users for feedback about
accessing the standard and any additional
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digital solution and the current users are not
Involve users in the development, build and
should not be applied in a linear way, so
offered a digital option. It may need to be refined to
testing of the service.
agencies will be using it at different points.
guide the initial user consultation and exploration
of available digital technologies to support user
needs. Further, a point about involving users in the
development, build, and testing of the initial design.
(Via email on slide 8)– this seems to overlap with
Noted.
Based on feedback from stakeholders, we
the previous element and might need to consider
consider that it is important to keep criteria 2
the cultural diversity within the Australian citizen
and 3 separate. Criteria 3 is very much about
base. There are over 3 million migrants and about
increasing accessibility and inclusion in digital
Act
30% of citizens that were born overseas and English
services. In the detailed DSS documentation, we
is not their first language (in some regions up to
will be sure to draw out the differences
60% of citizens are born overseas). In addition,
between 2 and 3 in a more clear way.
there are different levels of digital literacy, provision
of internet connectivity, and barriers to access such
as those with disabilities, and other vulnerable
groups within the population (e.g., prisoners,
domestic violence, refugees, etc.).
(Via email on slide 9)– the more commonly used
Updated criteria 4 to reflect the DDGS language
under FOI
digital systems term could be ‘connected’ rather
of ‘connected’.
than ‘joined-up’. An issue that is often raised
around connected services is the limitations of
citizen consent and the obligations under the
Privacy Act, especially in relation to the use of
personal or sensitive information.
(Via email on slide 10)– it may be beneficial to
Updated slide 10 to include the following dot
We will build out the broader guidance on this
consider the selection of providers and their sub-
point:
as part of the detailed DSS document.
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contractors within this element. It could also be
helpful to reference alignment with the whole-of-
Understand how your service will align to the
government Hosting Strategy and compliance with
Whole of Government Hosting Strategy and the
the Hosting Certification Framework requirements
Hosting Certification Framework.
for providers that host government data. In
addition, a point about budgeting to seek expert
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advice for the legal, security, and other aspects of
the design. Another important consideration could
be having a mechanism for users to report bugs,
security issues, lodge a compliant and escalate, if
needed.
(Via email on slide 11)– I’m not sure if using an &
Noted.
We will build out the broader guidance on this
and dropping the ‘of’ is appropriate for a standard.
as part of the detailed DSS document.
There are digital government systems that are used
by Australian citizens located offshore (e.g., DFAT,
Defence, born overseas, on holiday) It could be
Act
good to add a point about any relevant
international standards and requirements such as
the need to process international payments.
Another consideration is sector specific standards
and patterns such as the Fast Healthcare
Interoperability Resources (FHIR) standard for
exchanging digital health data for use in a variety of
settings and systems.
(Via email on slide 12)– some data has legislated
Noted.
We will build out the broader guidance on this
under FOI
retention obligations that may need to be
as part of the detailed DSS document.
considered, such as those within the National
Archives Act. There are also requirements under the
Privacy Act that may need to be considered around
the collection, use and storage of different types of
information. Some specific uses and sectors have
additional ethical and legal obligations such as
ethics for medical research or specific legislation for
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systems such as the My Health Record Act and
Rules.
(Via email on slide 13)– perhaps another
Updated slide 13 to include the following dot
consideration is the need to balance the use of new point:
technology with the rate of user adoption, user
expectations and perceptions (may not want the
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government to be leading edge) and trust of the
Understand the rate of adoption of new
technology. It also requires funding a significant
technologies and if users would want to see it in
change management effort to train citizen or APS
a government service.
users.
(Via email on slide 14)– it may be relevant to refer
Updated slide 14 to include the following dot
We consider that the transparency piece fits
to the whole-of-government Digital and ICT Benefits point:
best in criteria 10 (as it currently sits).
Management Policy, noting that it is voluntary but
offers policy standards, assessment criteria and
Consider and apply the Whole of Government
guidance on measuring the benefits of a new digital
Digital and ICT Benefit Management Policy
solution. Another consideration would be
Act
transparent reporting of the appropriate
measurements of the success and user satisfaction
with the solution. The Benefits Management Policy
could also be flagged in the first element ‘clarify
your objectives’ as best practice is to consider the
metrics that will be used and/or reported to
demonstrate the objectives have been achieved.
(Via email on slide 15)– it could be valuable to
Noted.
We consider this is included as part of criteria 2.
consider a broad range of stakeholder and user
We will be sure to link back to it as part of the
under FOI
feedback for continuous improvement. For
more detailed DSS document.
example, global trends, consultation across
government with service owners of similar
solutions, following online relevant technical and
user forums, etc. I suggest the regular user research
and observations point may belong here too. the
service owner may also want to understand and
schedule regular meetings with providers to have Released
input into the technology roadmap for the solution.
For example, what are the technology providers
plans to improve or release new versions and what
is the duration of the support for the version in use.
Another consideration may be incorporating a
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mechanism for users to provide immediate
feedback on the user experience.
(Via email) Does the proposed scope of the new
Noted.
Have updated accordingly.
Digital Service Standard meet your expectations?
What is your overall impression of the proposed
scope of the Digital Services Standard?
The draft has a good coverage of the generic scope
of a new digital service. There are some
opportunities for minor refinements that are
outlined above. I also agree with the comments
Act
Andrew Morrison has added to the slide deck. I’m
not an expert on usability and accessibility
standards that have been referenced by Cliff
Edwards.
(Via email) Do any statements stand out more than Noted.
As highlighted above, based on feedback from
others? I was a bit unsure of the difference
stakeholders, we consider that it is important to
between ‘understand user needs’ and ‘design for
keep criteria 2 and 3 separate. Criteria 3 is very
everyone’.
much about increasing accessibility and
inclusion in digital services. In the detailed DSS
under FOI documentation, we will be sure to draw out the
differences between 2 and 3 in a clearer way.
(Via email) Are any statements obsolete/
Noted
As above.
redundant? Which, if any, statement may be
obsolete or redundant?
I wonder if the ‘Understand User Needs’ and ‘
Design for Everyone’ statements could be
combined.
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(Via email) Are any statements unattainable?
Noted.
We will consider this as we build out the
Which, if any, statements are unattainable?
detailed DSS documentation and guidance.
I’m not sure if all service owners would have
sufficient and current data to make ‘data-driven
decisions”. Perhaps ‘evidence-based decisions’
could more achievable.
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(Via email) Is there anything that you think that we Noted.
We will incorporate these as part of the detailed
have missed? What’s missing?
DSS documentation.
I think there are other Australian and International
standards, policies, and frameworks that could be
relevant (see above). Some guidance on considering
sector-specific requirements may also be helpful.
There are also government targets for SME, Net
Zero Emissions, Indigenous Participation, etc. that
may need to be factored into the Standard.
(Via email) Is there anything that you consider
Updated slide 3 to include the following dot
Act
needs more emphasis in the Standard? What needs point:
more emphasis?
Its not entirely clear if the use of the Standard is
Better enforce the use of the Standard across
mandatory and if any reporting, assurance checks,
agencies.
etc. may be required.
(Via email) How could we enforce the DSS to ensure Noted.
We are currently putting together a list of
it meets its intended purpose?
guidance materials and resources that we can
In addition to the answer to the question above, I
connect agencies to. We would love any
wonder if the approach required to foster use of
suggestions you may have in this space.
under FOI
the Standard is enforcement or education and
awareness through the provision of additional
guidance materials such as templates, links,
resources, etc.
(Via email) Could anything be done to improve/
Noted.
This is an early draft and we have a plan to
drive sentiment/ commitment? What could be
engage heavily across government over the
done to improve or drive sentiment and
coming months commencing week of 14
commitment to the applying the Standard?
August. We have also already commenced
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There are only two resources referenced at the start
informal engagement with agencies.
of this presentation and both are non-government
sources. I’m not sure if this is demonstrating
sufficient research and consultation was conducted
to develop/improve this version of the Standard. It
could be good to state the problem that this version
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this argument a bit further – we will schedule
some time with you to discuss.
(Via email) The team is keen to see how the
Noted.
We will continue to engage with you over the
underlying execution, processes and assessment
coming months about how we can support the
will work. DSS is currently considered as part of the
Contestability role and what guidance is
existing DCAP processes so this will result in some
required.
changes in this space.
(Via email) As communicated in the session,
Noted.
We are looking into how we can reuse existing
Agencies routinely express concern with the
data collection mechanisms to reduce burden
quantity of data the DTA already asks for as part of
on agencies. We would be interest in discussing
Act
Wave and other data collection mechanisms.
this further with you to understand where the
pain points are.
(Via email) The DSS content aligns with the AGA in
Noted.
We will continue to engage with you over the
specific areas such as re-use, so it is worth noting
coming months about how we can support the
that Contestability is working with the AGA team to
Contestability role and what guidance is
align processes and understand the re-use mandate
required.
and its enforceability. Our interest is in ensuring
that agencies are consulted, aware of their
obligations, and are provided with sufficient tools to
under FOI
successfully comply. This extends to understanding
Contestability’s’ role in any assessment or
enforcement activities.
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