Time. perhaps, to find something positive to say about HMRC and their approach to customers and their data.
Income tax is a system within which people accrue liabilities to pay money to government, which they meet either by not seeing the money in the first place because tax is deducted at source or by paying money directly. When money is due to be paid, there is a bill and a due date. If the due date is missed, reminders follow – no doubt getting increasingly strident as time passes.
The congestion charge is another system in which people accrue liabilities to pay money to government. Money is due to be paid on the day the liability arises and, more recently, can also be paid on the following day, albeit at higher cost. If that payment window is missed though, there are no reminders, there is simply a penalty.
There are two differences here. One is that HMRC behaves as though it is operating a debt collection system while the congestion charge behaves as though it is operating a traffic offence penalty system. That’s odd to start with, since there is a pretty big difference between parking on double yellow lines or driving through a red traffic light and driving into central London. The first two are inherently things which should not be done and for which there are penalties, the third is a perfectly legitimate thing to do but for which a payment is required. So the first problem is that Transport for London – or a least the congestion charging bit – is in a different business from the one it thinks it is in.
The second problem massively reinforces the first. It is that HMRC has very deliberately chosen to assume that most customers want to be compliant. It follows from that assumption that if people become non-compliant, they need encouragement and help rather than punishment. Of course HMRC can turn nasty if it needs to, and if it puts its mind to it, it can turn very nasty indeed, but that’s not where they start from. TfL assumes from the outset that non-compliance is an attempt at evasion and its first response is to impose punishment.
There is no obvious reason why TfL could not instead send polite reminders that a payment is due and keep the penalty charges for those whose further inaction suggests an intent to avoid paying. But something quite subtle about how they saw the problem they were trying to solve has sent them down altogether the wrong path.
Of course this moan is triggered by having to pay £50 for having forgotten to pay £8, so I may not be taking a wholly balanced view. But two further ways occur to me of not needing to inflict that pain:
- I live not much more than ten minutes’ walk from the edge of the congestion charging zone, so I, my car and crucially, my record of compliance are all know to TfL. So if I pay five times and fail to pay the sixth, there’s a pretty obvious assumption to be made about the likelihood that my reason for not paying was dishonest
- Another bit of TfL runs the oyster card. The pay as you go version permits small overdrafts, in effect, if the journey to be charged for turns out to be more expensive than the amount stored on the card. Someone in that position could avoid paying the shortfall by throwing away the card and getting a new one – but TfL clearly assume that most people won’t. A little bit of leeway reduces congestion at the barriers and probably has a vanishingly small impact on lost revenues.
In other words, there are opportunities to design compliance in, given a willingness to assume that at least some customers intend to be compliant. Instead, TfL has assumed that non-compliance has to be dealt with separately. There are all sorts of lessons there for service designers.