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Understanding the ethics of environmental health reporting

After decades of technological progress, it is no secret that today’s technology acts as a mirror to human bias. Take this famous case in the US as an example, in which risk assessments used by the police to predict future criminals were resulting in an inaccurate prediction of reoffence for black Americans. ProPublica’s analysis of a series of such cases sparked outrage across the globe, with people expressing disapproval of the use of algorithms in justice calculations, where the decision could have a significant impact on people’s lives. 

Whilst EnviroWorks, our private and secure environmental health reporting and case management system, does not use algorithms to make decisions on case prioritisation or issuing Community Protection Notices (CPNs), cases such as these show how technological systems can reflect bias and have significant consequences for marginalised groups. In our design, we wanted to be sure that we understood – and thus could prevent – the possible unintended consequences of our environmental health reporting tool. 

As EnviroWorks could involve the collection of personally identifiable information (PII), including video, voice or images of people and their homes, we knew there could be privacy concerns. As a long-time provider of reporting and civic engagement services, we were confident we could manage this risk effectively (see the end of the blog post for our design principles).

Our main concern with this service was that it could include people-reporting-on-people, meaning that biases and prejudices could play a part in reporting. By making it easier for people to report, we didn’t want to inadvertently increase reports against marginalised, vulnerable, or minority groups. We didn’t want technology to play a part in reflecting or amplifying existing human bias. 

In this blog, we detail our concerns around the ethics of this service, the findings of our research, and the guardrails we put in place to manage risk.

Understanding the risks

Environmental reports, particularly those related to noise and smell complaints, can cause divisions within communities. Reports are often social and moral judgements rather than objective facts – i.e. not just “I hear a noise” but “my neighbour is being inconsiderate or unreasonable”. They can therefore be wrapped up in a person’s opinions and biases. 

As such, marginalised and low income groups are more likely to be the subject of reports about antisocial behaviour (ASB) and environmental health concerns. There is a notable absence of research on who is reported and the consequences of such reporting, though news stories abound where minority groups are reported on for ostensibly routine activities, such as having small social gatherings or playing music. 

A few studies suggest that cities with diverse ethnicities and religions and more deprived cities and regions receive more nuisance complaints. A 2013 University of Glasgow study showed how complaint systems can disproportionately target groups whose presence is viewed as socially undesirable, such as young people. 

According to research by the Housing Ombudsman, most noise reports can be better categorised as daily household noise, rather than being antisocial in nature. This shows how subjective reports can be.

Graphic depicting how EnviroWorks looks on different devices
EnviroWorks is an expansion of our existing noise reporting service, known as NoiseWorks, co-designed with the London Borough of Hackney in 2021.

Pursuing EnviroWorks as a democratic function

The issues of subjectivity and discrimination were at the forefront of our minds when developing EnviroWorks. The prospective tool would be people-reporting-on-people, as well as on “things”, adding a type of reporting that is different from our existing street, highway and environment fault reporting service, FixMyStreet. We were concerned that giving people the ability to more easily report certain environmental health issues, like noise or nuisance behaviour, could risk the further marginalisation of the already marginalised groups who are most often the subjects of such reports.

Local authorities have guidance for staff on dealing with environmental health reports fairly, including strict standard operating procedures and enforcement policies. For us, it was vital to ensure that the reporting mechanism itself does not create opportunities for unfair reporting, but rather assists council staff to best ensure fairness in case management. 

Councils have a statutory duty to protect public health and the environment by investigating issues that could impact health or become a nuisance, so people have the right to report and to have their reports addressed.  We knew that, if done well and fairly, a reporting tool could be a useful democratic function. Balancing this duty with the risks, the SocietyWorks team recognised the need for extra care in design, to ensure the service aligns with our aims to help the public sector better serve citizens, without unfairly favouring or excluding any group.

Putting the right guardrails in place

We had a good understanding of the potential consequences of noise reporting, based on a consequence scanning exercise we conducted in 2020. Through an exercise with Hackney Council staff during the development of NoiseWorks (the precursor to EnviroWorks), we were able to look at the positives and negatives from the different viewpoints of council staff, citizens and the wider community. Revisiting this work as we explored the development of EnviroWorks, this exercise helped us to understand what mitigations should be put into place.

As we developed our design principles, we integrated intelligence from desk research into environmental health reporting, including expertise from Freedom in Every Day Life on the current approaches to CPNs. CPNs are often issued in response to environmental and ASB reports and can have a detrimental effect on the subject of the report, such as stress. We followed their guidance, which aims to ensure that powers are used fairly, impartially, and proportionately.

Bringing together the findings from our consequence scanning with best practice from the experts, we solidified our understanding of how best to design a tool that suited the needs of case managers in local authorities, as well as the needs of reporters and report subjects. This process brought us to a set of design principles to act as guardrails and mitigate against risks of harm.

Design principles for EnviroWorks

  1. Informal resolution. Recognising that the service is serving a statutory function, we wanted to ensure that people are able to report, but are not encouraged to report. By signposting to Citizens Advice, providing advice on mediation and informal resolution, and providing information on what isn’t a statutory issue, citizens have the information they need to make an informed decision on whether a report is appropriate and necessary. A reduction in reports can reduce unnecessary reporting against minorities and marginalised groups, and reduces the burden on already stretched environmental health teams. This benefits councils, the subjects of the reports, reporters, and has broader benefits for the social fabric of the community.
  2. Accountability. In the fully-private, back-end case management system, all actions, decisions and reasoning are documented. This provides a full evidence trail for oversight.
  3. Transparency. The case management system prompts council staff to update reporters and people being reported on. It is vital that both sides are updated, with the subjects of reports given rights of appeal information. The system also makes it easy to generate statistics, which allows staff to understand where reports are happening and identify clusters or trends. As our software is open source, a public repository provides publicly accessible information on what types of information is being collected and how it is processed.
  4. Proportionality and due process. Prompts in the case management system encourage a problem solving approach. Staff are reminded to give informal warnings, communicate with the person who is the subject of the report, and provide them with the right to appeal. Prompts will be developed alongside the local authority’s own due process. 
  5. Objectivity. When issuing formal Community Protection Warning (CPW) or Community Protection Notice (CPN), Officers could be provided with statutory guidance on objectivity from the Home Office and Chartered Institute of Environmental Health (as recommended by Manifesto Club). Complementing the council’s own guidance, this would support staff to engage with reports objectively.
  6. Accessibility. As with all SocietyWorks products, EnviroWorks follows high standards of web accessibility. Our digital services are all WCAG 2.2 AA compliant, as per W3C’s Web Accessibility Initiative. For example, we use clear language and ensure a simple user interface and provide information on alternative contact points e.g. telephone. EnviroWorks is a Progressive Web App, meaning the user does not need to download an app, but can use it in their browser. This makes it more accessible for people with older devices or wanting to work in a browser.
  7. Personal data collection and access minimisation.  Reports are fully private on EnviroWorks. Personal data is subject to strict technical and contractual scope limitation, with data protection agreement clauses strictly scoped to environmental health reporting, data retention and anonymisation policy. We operate on a principle of requiring the least amount of data access necessary to do the job.

As with all of our tools, we will be learning with each new implementation and tailoring the system to meet specific needs of each local authority we work with. We’ll be back with case studies and lessons learned as we have them! 

 

Are you in need of a better environmental health reporting and case management service?

If you’d like to find out more about EnviroWorks, or any other aspect of the SocietyWorks local government suite, then please contact us through our online form.

Image: Robin Vintevogel on Unsplash


Introducing EnviroWorks: reporting and case management for environmental health teams

We are pleased to be launching our new environmental health reporting service: EnviroWorks. It is a private and secure environmental health reporting and case management system, designed for the unique needs of environmental health teams.

In a series of blogs, we’ll explore how we got to this point and look in detail at the service. Let’s get started.

Understanding the need

As with any good user-centred design process, let’s first take a look back at our core users and the needs that brought us to create EnviroWorks.

Environmental health teams at our local authorities play a critical role in improving public health and protecting the environment. They deal with air quality management, noise pollution, food safety inspections, and housing standard enforcement. These are key issues affecting our health: noise is one of the leading environmental risks for physical and mental health and well-being. Bad odours can cause nausea, headaches and irritability. Poor air quality is linked to cancer, stroke, asthma, and heart disease. 

And environmental risks don’t impact everyone equally: minority ethnic groups, low income households, and those with inadequate housing conditions are more likely to be exposed to environmental health issues, such as poor air quality or excessive noise.

Whilst playing such a vital role, environmental health teams in some local authorities are struggling with capacity. As of 1 October 2023, on average 13% of environmental health posts in local councils were vacant. But reports from citizens are not going anywhere. Over just a three month period, local councils in London and the South East received over 90,000 and 40,000 noise complaints respectively. And that’s just noise! 

It is within this context that we received requests from our local authority clients and their environmental health teams, who wanted support managing their case load and a more user-friendly frontend reporting system.

Starting with noise

In 2020, Hackney Council came to us wanting to make the process of submitting noise reports a smoother one for residents and for council staff.  We worked intensively with Hackney’s Environmental Health team on a Discovery and Alpha project to understand the challenges they were facing, and to launch a brand new minimum viable case management solution for them.

A mock-up of Hackney's NoiseWorks service

This solution helped the team gather and manage information; helped them make decisions with all the information they needed; exposed useful data patterns; facilitated  sharing of information with reporters and relevant internal teams; and allowed them to retain information for compliance purposes. We called it NoiseWorks.

Building on our existing services

NoiseWorks has now been running successfully for five years. During that time, we have been seeing a growing need among our local authority clients for a service that covers broader environmental health reporting. 

To address this need, we wanted to create something that (like all our services) is accessible and easy to use for citizens, whilst being flexible enough to accommodate the unique needs of each council. With a user-friendly interface, comprehensive case management system, and private and secure back-end, EnviroWorks helps the public sector better serve citizens. 

EnviroWorks is a step on from NoiseWorks, with additional reporting categories, the ability to provide supporting documentation (such as recordings), and some other additional features. 

In an upcoming blog, we’ll show the tool in more detail… watch this space!

In the meantime, if you are interested in EnviroWorks, drop us a message and we’ll get back to you.

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Image: Joshua Brown on Pexels


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