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The Information Commissioner’s Office has just replied to an email from UCDx about the Department for Education’s wallet pilot, which is being tested in the ICO’s Regulatory Sandbox.
DfE has not publicised its wallet plans. But details revealed in response to a series of FOI requests indicate that it proposes to enable secondary school leavers to use Microsoft wallet software to show qualifications from the Learning Record Service as part of an application to an FE college.
Quite why the learner should use LRS as a data source, rather than pulling data direct from the secondary school, has not been explained. But a strong possibility is that DfE is trying to justify the continuing existence of LRS, despite the case for doing so wearing rather thin.
On which point, it’s worth noting a response from the Education and Skills Funding Agency (part of DfE) to a more recent FOI request. They state that, contrary to the implication in the Learning Records Service’s privacy notice, learning providers do not receive extra funding from DfE if a learner has failed to achieve a certain minimum level of qualifications by a threshold age. Thus DfE’s case for LRS being a necessity is weaker than it at first seemed.
Yes, LRS does allow DfE to compile statistics about a learning provider’s performance, but these could be based instead on anonymised data submitted by each learning provider. And yes, LRS does allow a learning provider to look up a learner’s qualification record, but almost the same result could be achieved by asking the learner to share their record from a personal wallet.
Given these alternatives, it seems unlikely that LRS would be built today. Whether, given that LRS does exist, it is worth retaining is a separate question. The answer in the short term, while a UCD-like wallet infrastructure is constructed, is a maybe; in the longer term, the probable answer is no.
Returning to ICO, it seems from their reply that they too are not completely convinced by DfE’s designs. However, they are reserving judgement for a report due later this year, after completion of DfE’s participation in the Sandbox.
