Plastic Packaging Tax
The report for HMRC's Plastic Packaging Tax alpha assessment on the 24th of September 2021
Service Standard assessment report
Plastic Packaging Tax
| From: | Central Digital & Data Office (CDDO) |
| Assessment date: | 24/09/2021 |
| Stage: | Alpha |
| Result: | Met |
| Service provider: | HMRC |
Service description
Entities that import or produce plastic packaging will soon be liable for a tax. This service allows users to register, fill in returns and pay the tax due.
Service users
Usersers come from a range of business areas and sizes including:
- Manufacturers
- Converters
- Importers
- Tax agents
From which we’ve identified key personas:
- Administrator
- Researcher
- Accountant
- Tax agent
1. Understand users and their needs
Decision
The service met point 1 of the Standard.
What the team has done well
The panel was impressed that:
- the service team have carried out extensive research with businesses who will be affected by the tax and the individuals who will be expecting to use the service. This has been a particular challenge as using their normal recruitment supplier was not possible given the relatively small population so the team themselves managed recruitment as well as carrying out the research
- it is clear that the project is listening to the findings from research and changing direction when necessary. A good example of this was the halting development of a tool which was found not to meet any significant user need thereby saving two months of development time. It was also clear that the research team were able to report strong negative feedback from users in the knowledge that it would be taken on board and lead to significant iteration
- some elements of the policy are not finalised yet and it is encouraging that the conversations the teams are having directly with users are being fed into the policy team and members of the policy team are attending research sessions. This will significantly reduce the risk that final alterations to the policy have unintended consequences when the tax comes in to effect in April 2022
What the team needs to explore
Before their next assessment, the team needs to:
- the research has shown that one of the most difficult challenges the service has to meet is around guidance. It is critical that when working with GDS the extensive research and testing that they have carried out is central to the development of the gov.uk pages to meet those guidance challenges
- the team have struggled to find individuals who are lower on the digital inclusion scale and who would be users of the service. As a result they have attempted to use proxies who are lower on the digital inclusion scale to test the service but we would question what value this testing would actually deliver. It may simply be that “Assisted Digital” users are not present in the population in significant enough numbers to be identified at this point
2. Solve a whole problem for users
Decision
The service met point 2 of the Standard.
What the team has done well
The panel was impressed that:
- the team identified from the start that Guidance would play a key role in users understanding of the Plastic Packaging Tax. They worked directly with users to understand which forms of guidance would be most suitable and challenged preconceived ideas regarding the tools that would be needed
- the team has worked with industry bodies throughout Alpha to get feedback on their ideas, reaching a wide range of user groups
- the team have involved policy stakeholders in the research sessions to help them understand the pain points faced by users
What the team needs to explore
Before their next assessment, the team needs to:
- we would encourage the team to work in the open and share any insights they’ve uncovered in their exploration with wider Government teams
- where possible the team should try to work across organisational boundaries with other teams working on similar problems, to offer a more consistent experience for users, and maximise the opportunity for reuse of user data
- if not already completed by policy labs before the Alpha phase, we would recommend exploration of any risks that could result from the introduction of the Plastic Packaging Tax, in particular if it might increase the use of other non-plastic packaging materials
- with the tax due to go live in under 6 months, we would encourage the team to do all they can to release finalised guidance at the earliest opportunity, as users will need time to understand the legislation and gather their data before submission
3. Provide a joined-up experience across all channels
Decision
The service met point 3 of the Standard.
What the team has done well
The panel was impressed that:
- during Alpha, the team have undertaken research into their support model, to understand the needs of the different user groups, and get feedback on the proposed support methods
- there is an expectation that users will need support to understand the legislation. The team mentioned that there will be telephone support available for users on every page, with Plastic Packaging Tax specific handlers available to help with any queries, who also have a direct link into policy for more detailed questions. Users will also be provided with email text help on every page
- there are 2 individuals dedicated to communications for Plastic Packaging Tax and there are flyers signed off to raise awareness with users
What the team needs to explore
Before their next assessment, the team needs to:
- the team mentioned there is a risk of email notifications not being in place for go-live, we would encourage the team to try and resolve any issues so that these are in place, as there will be an expectation from users that they would get confirmation emails throughout their journey
- there have been assumptions from policy that users will automatically be aware of the new tax, which seem to have been proven false. It’s positive that the team have 2 individuals dedicated to working on communications and have been working with industry groups to raise awareness, however there could be a risk that some users will slip through the gaps unintentionally and be unaware of their responsibilities. We would encourage the team to explore other ways they could communicate directly with these users
4. Make the service simple to use
Decision
The service met point 4 of the Standard.
What the team has done well
The panel was impressed that:
- the team have gone through a series of rounds of testing with the guidance and eligibility checker designs, providing detail of how they iterated the designs based on user feedback and the challenges they have faced
- the team made the understandable decision to focus their MVP on the ‘Ltd Companies’ audience, which they believe accounts for 85% of their users. They also provided details of how they are addressing the remainder of the audience
- the team have completed some testing of the designs with the ‘Groups and Partnerships’ audience, acknowledging the potential challenges that these users will encounter, and displaying a good understanding of pain points they need to resolve for this user group
- the team were honest and acknowledged that some aspects of the design are unlikely to be resolved within the Alpha phase. They provided an overview of how they intend to use the Private Beta in November 2021 to uncover real-life insights and improve the designs
- the team has experience of working with the Service Standard and has made use of GOV existing patterns and components in the designs, whilst also utilising previously developed HMRC components such as the account homepage
- impressed by the approach the team employed when creating the service name, running two collaborative sessions with users to understand which name would be most suitable
What the team needs to explore
Before their next assessment, the team needs to:
- the team highlighted challenges with various aspects of the eligibility checker. Whilst the team detailed how they had iterated the eligibility checker numerous times, it wasn’t clear if the current approach would be successful with users. As this is a significant step in the journey, we would encourage the team to prioritise the improvement of this in Private Beta and explore alternate approaches to the problem. Involving policy throughout this process should help them to understand the pain points users are experiencing
- the team has a good understanding of pain points in the existing design for ‘Groups and Partnerships’ users, specifically large groups who have 50+ organisations. We recommend that they use the Private Beta to resolve this design problem, as the current approach would be cumbersome for users if it went live
- the team mentioned that they have been testing the returns and payments journey, however this wasn’t part of the demo, making it difficult to assess. These are two key parts of the end-to-end journey, and any future assessment should include details of testing that has been undertaken, any iterations made, and general success of these sections. If possible, testing the whole end-to-end solution as one could give a better understanding of performance
- the service prototype relies on users manually entering their data into the service via the online portal, there was no mention of exploration of other methods such as spreadsheet upload. If not already undertaken, we recommend exploration of other data upload methods alongside manual upload to judge if there is a user need for these
- the guidance for the service references ‘tonnes’, but the screens in the service ask for ‘kg’ weights. The team stated that some users would measure their plastic in ‘tonnes’ and the ‘kg’ weights are a policy requirement. This disparity could make the reporting step more complex for users, as they may have to convert the numbers themselves, or worst-case scenario they could enter the wrong values into the service. We would encourage the team to explore the other solutions they have been considering in relation to this problem
- the team should explore the impact of using the acronym ‘PPT’, which is already established and used in relation to Microsoft PowerPoint files. To avoid confusion, recommend that early in the Plastic Packaging Tax journey, the acronym should be featured alongside the full title more than once, to educate users. Also, the team should understand any impact this acronym may have on users searching for content via search engines. GDS guidance on ‘Abbreviations and acronyms’ is available on this page: https://www.gov.uk/guidance/style-guide/a-to-z-of-gov-uk-style
5. Make sure everyone can use the service
Decision
The service met point 5 of the Standard.
What the team has done well
The panel was impressed that:
- within the Alpha phase, the team have a undertaken a round of assisted digital research, and have a further round of research planned for October
- the team mentioned that they would be completing an internal HMRC accessibility audit in the new year and would be working on their Accessibility Statement which will be in place prior to go-live on 1st April 2022
What the team needs to explore
Before their next assessment, the team needs to:
- the team must test the working version of the end-to-end service with assisted digital users in private beta to ensure there are no issues before launch
- if possible, the team should also attempt to test the end-to-end service with users on various screen sizes and devices
- the team should complete their internal HMRC accessibility audit and make improvements to the service in-line with any recommendations. The team may also want to consider an external accessibility audit such as Digital Accessibility Centre (DAC) audit before launch
- the team should test non-digital ways to use the service (phone and post), for assisted digital and business continuity needs
6. Have a multidisciplinary team
Decision
The service met point 6 of the Standard.
What the team has done well
The panel was impressed that:
- there was a full, well resourced cross-functional team in place, able to discover user needs and iterate the service. Importantly, the team included a content designer and a performance analyst - which gave them an early opportunity to ensure content is appropriately considered from the early stages, and put in place a robust set of metrics that will enable them to shape research and improve the service in the future
What the team needs to explore
Before their next assessment, the team needs to:
- present a robust plan for staffing the service with more permanent Civil Servants. Whether they are apprentices whose main task will be learning from the high-skilled contractors, or more senior permanent team members, the panel would like to see the key roles resourced on an internal, long term basis to make it more likely that the service will have longevity and be iterated
7. Use agile ways of working
Decision
The service met point 7 of the Standard.
What the team has done well
The panel was impressed that:
- the team was able to present many ways in which they improved their ways of working based on feedback, retrospectives, and simply observing how things were going
What the team needs to explore
Before their next assessment, the team needs to:
- explore how to effectively transfer knowledge to any permanent staff members across HMRC, whether they are new additions to the Plastic Packaging Tax team or profession leads, while continuing to deliver
- should more junior permanent staff members be included in the team, as mentioned in point 6, the team should be able to clearly present how they are upskilled and how the team processes had to adjust to accommodate that
8. Iterate and improve frequently
Decision
The service met point 8 of the Standard.
What the team has done well
The panel was impressed that:
- the team presented evidence of multiple iterations based on research and data, without being constrained by their own or their stakeholders’ assumptions
- a solid plan is in place for further development, with a clear idea how the service can be improved and extended in the next stages
What the team needs to explore
Before their next assessment, the team needs to:
- demonstrate an end to end service. We have seen the registration element of the process only, it would be great to examine the data upload portion including any unhappy paths at that stage
9. Create a secure service which protects users’ privacy
Decision
The service met point 9 of the Standard.
What the team has done well
TThe panel was impressed that:
- they are following standard HMRC practices around security and privacy
- they use a standard ROSM (register once subscribe many), for registration
What the team needs to explore
Before their next assessment, the team needs to:
- email verification dependency requires integration and testing. This is a standard service used by many services
- there are extensive HMRC assurance processes, including penetration testing, around security and these will need to be conducted through private Beta
10. Define what success looks like and publish performance data
Decision
The service met point 10 of the Standard.
What the team has done well
The panel was impressed that:
- performance dashboards for the service were very comprehensive and the team was clear on how the data gathered will be used to spot issues, make decisions, and shape the service
- one of the metrics recorded is the proportion of recyclable plastics used
What the team needs to explore
Before their next assessment, the team needs to:
- be clear on how the service helps achieve any bigger picture goals, including policy goals which led to its creation - and how those will be monitored and communicated to stakeholders and decision makers in and outside of the department
11. Choose the right tools and technology
Decision
The service met point 11 of the Standard.
What the team has done well
The panel was impressed that:
- they have used common HMRC platforms: Scala, Mokito, Mongo, Jenkins, AWS and MDTP (Multi digital tax platform)
- the team are confident all their technology and frameworks are commonly used across HMRC
- they use Mongo for save and return which is a common pattern across HMRC
What the team needs to explore
Before their next assessment, the team needs to:
- they have used a tool to pre-populate input forms. During private Beta they need to ensure proper user testing is carried out, not using pre-populated web form data
- they require updates to support their organisational entities in GRS (Generic Registration Service). They need to ensure this external development is progressing at a pace suitable for the project and for delivery time scales
- changes to the GRS need to be tested through private beta
12. Make new source code open
Decision
The service met point 12 of the Standard.
What the team has done well
The panel was impressed that:
- all code, apart from testing code, is publicly available on GitHub
- as their application interfaces with many common components documentation needs to be of a high standard. They are content documentation is of a good level within the project and also from areas they depend on
What the team needs to explore
Before their next assessment, the team needs to:
- continue to keep their code as open as possible
- ensure as they iterate through versions of their micro services and services around them evolve documentation is regularly updated
13. Use and contribute to open standards, common components and patterns
Decision
The service met point 13 of the Standard.
What the team has done well
The panel was impressed that:
- they are using common APIs and components used across HMRC including ROSM, GRS, MDTP and DES (Data exchange service) and IF (Integration Framework)
- they only use common HMRC standards and components
What the team needs to explore
Before their next assessment, the team needs to:
- continue to use common HMRC patterns and standards. Highlight at their next assessment if and where they have deviated
- confirm how common HMRC components have changed due to the service requirements
14. Operate a reliable service
Decision
The service met point 14 of the Standard.
What the team has done well
The panel was impressed that:
- they deploy to a highly available and resilient platform
- they use Jenkins and GitHub to efficiently roll back code
- they will have automated monitoring in place
What the team needs to explore
Before their next assessment, the team needs to:
- ensure performance and penetration testing is conducted as part of private Beta
- the user base of this service will be relatively small, around 20k they will tend to login at similar times. Ensure the service can cope with higher peak usage.
Published 11 October 2021