5. Towards more inclusive, accessible and people-centred public service design and delivery in Portugal
This chapter considers the experience of designing and delivering more inclusive, accessible and people-centred public services in Portugal. First, it reviews the experience of digital government with a focus on context, underpinning philosophy and key enablers. It then analyses two case studies, the Digital Mobile Key and the Family Benefit for Children and Young People, and evaluates their performance against Portugal’s Guiding Principles for a Human Rights Based Approach on Public Services. It concludes with observations on how the government can deliver on its reform agenda for the two services.
The demand for quality service experience is at an all-time high. The transformative impact of digital technologies and data has made service experiences of all types more competitive and consumer-driven. In such competitive environments, the quality of service design and delivery becomes a point of difference, making it crucial to prioritise inclusion, accessibility and user-centricity. These considerations reflect broader societal changes that emphasise access, participation, literacy, information and concern for individual rights.
The same holds true for public services where citizens and businesses are constrained in their choice of providers. Governments are now increasingly aware of the benefits of improving service design and delivery processes, as well as their responsibility to make public services more accessible, ethical and equitable. Digital technology, data and a transformed approach to service design and delivery can help governments achieve policy outcomes and benefit all members of society as well as the internal operations of government (Welby and Tan, 2022[1]).
This chapter follows a review of the core legal and institutional frameworks that protect civic space in Chapter 3 and an analysis of the enabling environment for civil society in Chapter 4 to explore how to design and deliver more inclusive, accessible and people-centred public services in Portugal. The first part of the chapter provides an overview of digital government in Portugal, and the second part evaluates two key services, presented as case studies, against Portugal’s Guiding Principles for a Human Rights Based Approach on Public Services. The chapter concludes by outlining ways in which the Government of Portugal can make better use of civic space to deliver on its ambitious reform agenda (Section 1.2 in Chapter 1).
Portugal is known for its effective and forward-looking approach to digital transformation and user-centric service design and delivery. Initiatives such as SIMPLEX+, Citizen Spots and the Automatic Social Energy Tariff1 (Section 3.5.1 in Chapter 3) have won awards for their innovative approach to service design. Moreover, as noted in Chapter 1, successive Portuguese governments have consistently emphasised the importance of the transformation and quality of public services.
One indicator for the effectiveness of public sector transformation is the maturity of digital government. As discussed in Section 2.2.2 in Chapter 2, the OECD’s Digital Government Index (DGI) ranks Portugal tenth among 33 participating countries (29 OECD Members and 4 non-Members) and third among European Union (EU) countries (OECD, 2020[2]). Table 5.1 summarises Portugal’s performance against the six dimensions of the Digital Government Policy Framework (Section 3.5.1 in Chapter 3).
Portugal ranks in the top ten for four of the six dimensions, including third place for “Government as a Platform”. Portugal’s strengths in these areas allow for the use of emerging technologies and data to create proactive services that meet needs without users having to engage government in the first place (OECD, 2019[3]). A good example of how strengths in different areas of the Digital Government Policy Framework combine, leading to Portugal’s recognition as one of the most mature digital governments in the world, is the Automatic Social Energy Tariff (Box 5.1). Portugal can improve by adopting a more strategic approach to data and reaching a consensus on the use of data under the EU’s General Data Protection Regulation (GDPR) to maximise the benefits of data, especially where personal data are not involved (European Union, 2016[4]).
The Portuguese government created a Social Energy Tariff to assist with energy costs in 2010. The service required eligible users to sign up and register to receive it, but the initial data showed that those who should have benefited from the tariff were not registering to receive it. User research identified that these people were unaware that they needed to apply for it. This prompted a decision to automate the process. Using Portugal’s Interoperability Platform for the Public Administration (iAP), data could be shared between the Directorate General for Energy and Geology, energy companies, the tax system, and the social security system. As a direct result of being able to use the iAP, the now Automatic Social Energy Tariff resulted in an almost fivefold increase in the number of households benefitting in just three months, from 154 648 in March 2016 to 726 795 by June of that year, providing financial support to 7% of the Portuguese population for the cost of their energy without requiring them to validate their eligibility.
Digital by design with the government reimagining an existing policy and then redesigning the existing solution to take advantage of technology.
A data-driven public sector that uses data to baseline initial adoption rates, interrogate why adoption was lower than expected and measure the impact of the change. The automated process relied on having quality data in different public institutions and effective data sharing.
Government as a Platform in having the underlying technical infrastructure to facilitate a transformational approach to providing the service.
Open by default in recognising that solving a whole problem from end-to-end necessarily means collaborating across organisational boundaries to share data and collaborate effectively.
User-driven in recognising and understanding the needs and behaviours of eligible users to design an effective service.
Proactiveness by removing the need for citizens to initiate a transaction with government, allowing eligible citizens to automatically receive the benefit to which they are entitled.
Source: OECD (2019[3]), The Path to Becoming a Data-Driven Public Sector, OECD Digital Government Studies, OECD Publishing, Paris, https://doi.org/10.1787/059814a7-en.
Table 5.1 also shows two areas in which Portugal’s performance is less impressive. These areas – namely “open by default” and “user-driven” – are where the linkage between digital government and civic space is at its strongest.
Being user-driven is a crucial aspect of inclusive, people-centred public services. This ambition is contained within several strategic documents discussed more fully in Chapter 1 such as the XXII Constitutional Government Programme (2019-2023) (Government of Portugal, 2019[5]), the National Strategy for Innovation and Modernisation of the State (2020-2023) (Government of Portugal, 2020[6]), the National Recovery and Resilience Plan (Government of Portugal, 2021[7]) (Section 1.2 in Chapter 1) and the Open Government Partnership plan (AMA, 2021[8]) (Section 1.3 in Chapter 1). Governments that are user-driven adopt inclusive methodologies to emphasise the participatory role of people in identifying their needs and shaping the processes, services and policies that respond to them (OECD, 2020[9]). Leading countries in this area use policy levers or monitoring efforts to embed particular ideas and habits into the activity of government, but these are less well-developed in Portugal. The DGI highlights three areas – structured guidelines for engaging users, connecting work on digital divides across government and coherently measuring satisfaction – on which Portugal could place more focus.
Portugal’s lowest performance in the DGI is in the area of “open by default”. This dimension looks at how government data and policymaking processes (including algorithms) are made available for the public to engage with, within the limits of existing legislation and in line with the national and public interest (OECD, 2020[9]). This is a crucial aspect of protected civic space as it allows people to inform themselves about public policymaking and to take informed positions in public debates. Portugal’s weaker position in this dimension echoes the findings of the 2019 Open, Useful and Reusable Data Index (OURdata) (Section 3.5.1 in Chapter 3), where Portugal scored below the OECD average, and was ranked 23rd out of 34 countries (OECD, 2020[10]). Although this was an improvement from the previous edition and there is optimism about Portugal’s performance in the forthcoming index, Portugal underperformed in terms of data availability and government support for the reuse of data. While efforts have been made to promote open data reuse outside the public sector, the level of support, including for open data training, remains low and reflects a gap between the stated strategic ambition for inclusive engagement and actual involvement of citizens and civil society.
The scores for “user-driven” and “open by default”, thus, indicate that despite strategic efforts and high-level commitment, there is work to be done in both areas.
Digital government maturity helps to strengthen civic space in general as it offers greater access to services and allows continuous feedback from users. Equally, better quality services are a result of a healthy civic space and active participation of citizens and stakeholders in their development. This Review offers the OECD an opportunity to perform a dedicated analysis of the relationship between civic space and service design and delivery.
The OECD Framework for Service Design and Delivery provides a comprehensive lens for assessing the opportunities for digital practices, enabling technology and the trustworthy use of data to design and deliver services that are suited to the digital age (OECD, 2020[11]). As outlined in Section 2.2.2 in Chapter 2, this Review examines the underlying context, philosophy and enablers of service design and delivery, which are all influenced by the degree to which civic space is protected in a country.
5.3.1. Context
Two elements are particularly important within the context of the reforms in the design and delivery of public services: leadership and the demographics of a country.
Leadership
In recent years, Portugal’s policy and strategy documents have consistently emphasised the ongoing commitment to transforming public services at the highest levels of government, despite changes in the country’s political landscape. This sustained political commitment is illustrated by the creation of a dedicated Secretary of State for Digital Transition during the XXII government, who led the development of an Action Plan for the Digital Transition (Government of Portugal, 2021[12]). The action plan recognised that achieving the full benefits of digital transformation requires a whole-of-society effort that prioritises digital inclusion, capacity building and transformation across both the public and private sectors. This commitment has been further extended by the XXIII government in 2022 with the appointment of a dedicated Secretary of State for Digitalisation and Administrative Modernisation reporting directly to the Prime Minister. While ministerial-level interest and focus have been powerful catalysts for change in Portugal, establishing governance structures that can embed a shift in the way public institutions and societies operate is crucial for achieving sustainable and resilient change (OECD, 2021[13]). The Council for Information and Communication Technologies in Public Administration (Conselho para as Tecnologias de Informação e Comunicação na Administração Pública, CTIC) and the Inter-ministerial Council for Digitalisation (Conselho Interministerial para a Digitalização) are important vehicles for supporting these efforts. The CTIC provides a technical committee and advisory board to identify the priorities for digital technologies and data to improve the quality of life for citizens, while the Inter-ministerial Council provides senior leadership support to the agenda as every ministry is represented by a Secretary of State.
However, research conducted for this Review indicates that within public institutions in Portugal, the leadership for a “user-driven” and “open by default” mindset, which responds to the needs of users with inclusive and civic space supporting service design, largely depends on motivated individuals lower in the organisational hierarchy rather than those in leadership positions. During the fact-finding mission, the OECD team heard examples of managers displaying resistance to ideas of digital transformation because they came from different political parties or different geographies, for example.2 Under AMA’s leadership, steps are being taken to develop a standardised methodology for working with the public in the design and delivery of public services (see Section 5.3.3) but these instruments remain voluntary and reliant on local leadership. This is in contrast to the way other aspects of participation in Portuguese public life are regulated and required by law.
AMA and LabX have traditionally been well-regarded and given high levels of political support. High-level political support is essential for AMA and LabX to ensure that when they advise public institutions on how to redesign services, priority is given to implementing these ideas beyond experimentation and pilot schemes.
Demographics
It is important for those responsible for designing and delivering public services to recognise various demographic trends in Portugal. These include a consensus among interviewees that richer, younger, Portuguese-born individuals residing in urban coastal environments are more likely to have access to public services and have greater digital confidence than their poorer and older counterparts living inland or in rural settings and having been born outside of Portugal.3
According to data from the United Nations, the median age of the population of Portugal will be 46.6 by 2025. This will make the country the third oldest population in the OECD after Japan (at 49.9) and Italy (at 48.5) (United Nations Department of Economic and Social Affairs, 2022[14]). In the public sector, 36% of the workforce is over the age of 55, compared to the OECD average of 26% (OECD, 2021[15]). Although it is important not to assume that older individuals lack digital proficiency, there is evidence of a significant generational divide in terms of those with the knowledge, experience and appetite for how digital technologies and data can transform public services.
Socio-economic status is another significant demographic variable intersecting with the geography of Portugal. Over half (54.4%) of the country’s gross domestic product (GDP) is concentrated in urban coastal areas, often leaving inland areas with less access to services (European Commission, 2021[16]). Efforts have been made to address this disparity by increasing the network of Citizen Spots and Citizen Shops (Box 3.6 in Chapter 3) by 25% in the last two years.4 The Commission for Regional Development (Comissão de Coordenação e Desenvolvimento Regional) is also working with communities in each territory to better understand their needs, but the large scale of these regions presents challenges. For example, in the north of the country, there are 200 municipalities, which presents a challenge for the Commission to effectively understand and represent the particular needs given that variety.
The diversity of nationality in Portugal also shapes the experience and contribution of service design and delivery. The Portuguese agricultural sector only accounts for 2.3% of the national GDP, but it is seen as an entry point into the labour market for people looking to settle in Portugal from a range of countries including Algeria, Bangladesh, Bulgaria, India, Moldova, Nepal and Thailand (European Commission, 2021[16]; de Sousa, 2020[17]). However, these workers may be at risk of exploitation, or live in precarious conditions, and some lack the necessary documents to formalise their presence in the country. In a very positive step discussed in Section 3.6.1 in Chapter 3, the government has established a dedicated Citizen Shop, called the National Support Centre for the Integration of Migrants, to help normalise the presence of those without documentation.
5.3.2. Philosophy
The culture, attitude and behaviour of public servants play a significant role in ensuring that the outcomes of public service reform efforts reflect an aspiration to focus on people’s real needs rather than responding to government priorities or desk-based assumptions. This necessitates understanding whole problems, achieving end-to-end solutions, consistently involving citizens and stakeholders and being agile and iterative in design and delivery activities.
Understanding whole problems and designing end-to-end solutions for users and public sector employees
Portugal has worked to solve cross-governmental challenges and understand whole problems facing users. For example, the Citizen Shop was inspired by the opportunity to gather multiple public institutions in one location to ensure different parts of connected processes could be completed at the same time. Under the previous XXII government, the Strategy for Innovation and Modernisation of the State and Public Administration 2020-2023 included a number of targets reflecting the importance of working collaboratively among different public institutions to respond to the needs of users (Government of Portugal, 2020[6]).
As discussed in Section 1.2.1 in Chapter 1, Portugal’s National Recovery and Resilience Plan identifies 25 services to prioritise and transform in line with a “life events” model that focuses on the end-to-end resolution of a whole problem regardless of current institutional responsibility (Government of Portugal, 2021[7]). The “life events” model can be a helpful lens for bringing together different elements, but it remains important to understand a whole problem as it manifests for a user in a particular context.
One of the most important mechanisms for carrying out efforts to solve whole problems is the SIMPLEX Programme. The SIMPLEX Programme launched in 2006 to ease the burden of interaction between citizens and government. As an agile consultation process and space where public sector actors convene alongside members of the public, civil society and businesses, SIMPLEX helps to aggregate multiple views, consider issues from different perspectives and turn those insights into action.
SIMPLEX has been complemented by the creation of AMA in 2007 and LabX in 2017. AMA and LabX have had the responsibility to inspire new ideas and encourage ministries through a collaborative approach to redesigning public services. The long-term focus on capacity building aims to give public institutions the confidence and familiarity to take greater ownership for themselves, supported by AMA and LabX offering direct delivery and mentorship as each relationship requires. The success of these efforts relies on building relationships, especially where ministry staff may find it threatening when external voices arrive to espouse new ways of working and thinking. Because both AMA and LabX have been operating without a mandate to implement recommendations, this makes it essential to build relationships with organisational leaders who are open to responding to their recommendations. It is possible that following the elevation of AMA in 2022 under the responsibility of the Prime Minister, it will be able to operate with more authority, but this will not change the importance of working in a relational way to ahieve its objectives.
These initiatives have influenced a change in the approach to reforms in two notable ways. The first is in terms of access to information given the crucial role of ePortugal.gov as a focal point for online access to Portugal’s public services.5 The second change relates to how services are provided and is discussed in the second half of this chapter (Section 5.4.1).
The result of these efforts is that the culture underpinning the reform process is changing in Portugal with a greater receptiveness toward user-driven thinking about people and particularly vulnerable groups who cannot access services for a variety of reasons (Section 3.5.3 in Chapter 3) as well as creating a more proactive government that obviates the need for citizens to perform unnecessary transactional interactions. However, there is still more to do in this area. During the fact-finding mission, some interviewees reflected on a lack of end-to-end transformation in more complicated areas that did not address whole problems being experienced by a citizen.6 There is also evidence of more narrow e-government approaches being preferred with a focus on making individual interactions electronic rather than pursuing the digital government ambition of redesigning services end-to-end to benefit from digital practices, technology and data.
Transforming the design and delivery of public services is not just about changing technology, but also about changing culture (OECD, 2021[18]). In order to move beyond technological interventions, it is crucial that public servants have a baseline of skills for the digital age, such as those reflected in the OECD’s digital government user skills (OECD, 2021[18]). The OECD advocates for providing all public servants with a foundational understanding of the potential offered by technology and data to transform government, including the importance of understanding users and their needs, how to work openly and flexibly and the essential nature of building trust through the use of data and technology. The focus of the Portuguese government on developing the competencies of its public servants can be seen through the Public Administration Digital Competencies Centre (Centro de Competências Digitais da Administração Pública, TicAPP) and the Competence Centre for Planning, Policy and Foresight in Public Administration (Centro de Competências de Planeamento, de Políticas e de Prospetiva da Administração Pública, PlanAPP) (OECD, forthcoming[19]), These Centres will be essential in building a capability for public service design and delivery that can scale beyond the 25 services identified in the National Recovery and Resilience Plan (Government of Portugal, 2021[7]).
Involving the citizens and stakeholders on an ongoing basis
The intersection between service design and delivery and civic space is critical, as it surfaces opportunities to engage with citizens and stakeholders and respond to their needs. As discussed in Section 4.2 in Chapter 4, Portugal has recognised the value of participation in the process of developing strategies, policies and services. Indeed, almost half of the proposed measures in the XXII government’s transformation strategy came from a participatory approach that used workshops to secure suggestions from across government and society (Government of Portugal, 2020[6]).7 These ideas align with Portugal’s strategic vision and the legal provisions set out in Decree-Law No. 135/99, which requires all service providers to pursue administrative modernisation, including through the consideration of feedback from users (Government of Portugal, 1999[20]). In practice, the SIMPLEX Programme (Section 5.3.2) and the use of participatory budgeting, both in schools and through the Ministry of Health’s “healthy neighbourhoods” initiative, serve as examples of these principles. Digital platforms have also been developed to support public contributions, such as ePortugal.gov and ConsultaLex.gov, as discussed in Section 4.2.1 in Chapter 4.
Nevertheless, involving the public in co-designing and co-developing policy and service responses does not necessarily mean acting in line with a course of action specified by external voices without weighing up those inputs and taking a wider perspective to understand the whole problem and the full context of how best to respond to the need. During the fact-finding mission, the OECD heard of one example where senior leaders had directed a team to implement a very specific solution as defined by members of the public even though complementary research had found more effective ways to meet the need. In this situation, the focus was on implementing the requested intervention as proof of listening to the public, not in terms of actually achieving the best outcome in terms of responding to the underlying issue. 8
In designing and delivering public services, it is essential to involve users in the research and testing of new features and functionality. Prior to 2017, there were efforts to measure satisfaction, but it was uncommon for Portuguese public service teams to conduct in-person exploration. Since its creation in 2017, LabX has led the way in developing a different approach that has popularised the use of experimentation, co-creation and user engagement in the design and testing of services (Agência para a Modernização Administrativa; Centro para a Inovação no Setor Público, 2020[21]). As a result of these efforts, there are now standardised approaches for ensuring accessibility and usability that set the expectation of testing services with users, particularly those with specific needs.
Despite this positive step to involve users, interviews revealed that challenges remain in establishing an ongoing approach to user research and public engagement for all projects, rather than just those with high profiles.9 For example, while the “life events” model (Section 1.2.1 in Chapter 1) is being used to identify cross-cutting issues in 25 priority services, relevant staff do not always have the time or resources to engage citizens and stakeholders and may instead draw on the experience of their colleagues. This falls short of learning from the lived experience of users in an unbiased environment.10
AMA conducts annual surveys through the Citizen Shops and Citizen Spots. While these provide a valuable snapshot of service performance once a year, they lack real-time insights that could be used to iterate services and improve outcomes for users. There are more reactive models of feedback associated with Portugal’s service delivery channels. For example, surveys are conducted at the end of every call to access services via call centres and visitors to Citizen Shops are invited to evaluate their experience via QR code or SMS. A further example is ePortugal.gov, where every page contains a feedback mechanism in line with a consistent, star-rating design being rolled out across the EU as part of the Single Digital Gateway project (European Union, 2018[22]). Overall, this is an area where Portugal has feedback mechanisms that inform decision making but there are opportunities for modernising these efforts to reflect the changing needs of the digital age.
5.3.3. Enablers
The OECD Framework for Service Design and Delivery encourages the creation of “Government as a Platform” ecosystems to support the delivery of services through the collation of tools and resources that enable high-quality outcomes at scale and with pace (OECD, 2020[9]; 2020[11]). Box 5.2 highlights a selection of the technical tools available within the Portuguese public sector. The most effective Government as a Platform ecosystems recognise that enabling a transformation of public service design and delivery involves more than technical solutions. In applying this lens to the relationship between public service design and delivery and civic space, three areas will be considered: 1) the role of governance and assurance as a mechanism for guiding and enforcing particular habits and behaviours; 2) efforts to increase digital inclusion; and 3) how to achieve an omni-channel approach to services.
Autenticação.gov allows any public or private entity to authenticate its users.
The Digital Mobile Key (Chave Móvel Digital, CMD) is a simple and secure means of authenticating citizens via a mobile device.
The Professional Attributes Certification System (Sistema de Certificação de Atributos Profissionais) is a citizenship certificate that can be used in physical or digital form to identify, authenticate and allow citizens to electronically sign documents according to their professional attributes.
The Integration Platform (Plataforma de Integração da AP) allows for web services to be securely integrated between institutions and shared services to be developed across government.
The Payments Platform (Plataforma de Pagamentos da AP) provides a single solution for public services receiving payments.
The Messaging Platform (Gateway de SMS da Administração Pública) provides a mechanism for sending and receiving SMS between public sector institutions and citizens.
Electronic Notifications (Serviço Público de Notificações Eletrónicas) allows citizens to receive online notifications from public entities either through ePortugal.gov or Android and iOS applications.
The Document Bag (Bolsa de Documentos) is a feature of ePortugal.gov where citizens can receive and share documents.
The Catalogue of Entities and Services is a directory of public sector institutions, the services they provide, and the associations between entities and services.
Dados.gov, the Portuguese open government data portal, is built on the open source data platform, originally created by Etalab, the organisation responsible for open government data in the French government.
Source: AMA (n.d.[23]), ePortugal.gov.pt – your public services portal, https://eportugal.gov.pt/.
Governance and assurance mechanisms to guide habits and behaviours
AMA and LabX are working to bring transformational change to the way public services are designed and delivered, with a focus on building people’s capacity to independently emulate good practices and follow guidance. As the public sector adopts the service design and delivery philosophy outlined earlier in this chapter, it could be helpful for AMA to play a more direct role in establishing the rules that encourage specific habits and behaviours.
As was noted in Portugal’s DGI performance, policy levers are not often used to encourage user-driven behaviours in public service delivery teams (OECD, 2020[2]). To shape how teams respond to user needs, policy levers such as the business case process for securing funding, standards to define quality and assurance activities to monitor implementation against those standards can be used. These processes can also utilise and reinforce civic space by ensuring accessibility and quality via public feedback mechanisms and involving citizens and stakeholders in the oversight and monitoring of services, thereby making government more accountable and transparent.
By implementing these policy levers and embedding these practices into standardised models and methodologies for service design and delivery, countries can create a common understanding of how to make services more accessible, ethical, equitable and designed to meet user needs. The OECD Good Practice Principles for Service Design and Delivery in the Digital Age guide countries in their pursuit of these goals (OECD, 2022[24]). Adopting common models and methodologies can help to achieve uniformity and consistency, increased inclusion and accessibility, an improved user experience, the re-use of existing components and greater agility in delivery. In Portugal, the Mosaico Common Model for the Design and Development of Digital Services (hereafter “the Common Model”) sets out principles, standards, guidelines, reference architectures and common technologies underpinned by 18 pieces of national legislation and seven pieces of European legislation.11 AMA leads this initiative in collaboration with the Council for Information and Communication Technologies in Public Administration (Conselho de Tecnologias de Informação e Comunicação na Administração Pública). Box 5.3 lists the 11 principles underpinning the model.12
The following principles are the core of the Common Model by establishing 11 statements of purpose and guidelines that public entities must abide by:
Source: AMA (2023[25]), Mosaico principles, https://mosaico.gov.pt/principios.
Several of the principles outlined in the Common Model are relevant to civic space and complement work carried out by AMA and LabX in developing the Guiding Principles (AMA, 2021[26]). In Section 5.4, these Guiding Principles will form the basis for assessing two case studies. Under the provisions of the National Recovery and Resilience Plan (Government of Portugal, 2021[7]), the Common Model and the Guiding Principles will be applied to 25 priority services. Those 25 services have the potential to serve as models for other public institutions wishing to apply the same standards, thereby presenting Portugal with a huge opportunity to establish these policy levers as a mechanism for transforming public service design and delivery across the entire public sector.
Efforts to increase digital inclusion
A second enabler for ensuring that public services use digital technology and data to support and encourage access is digital inclusion. As discussed in Section 3.5 in Chapter 3, there is scope to improve the general level of digital skills in Portugal. This also applies to the public sector workforce. Thus, efforts to equip citizens need to be complemented by the work of the digital competency centre, TicAPP, to raise the baseline among the public sector workforce to understand the opportunities and benefits of digital technologies and data and PlanAPP in considering strategic foresight in relation to service design and delivery (OECD, 2021[18]; 2017[27]; forthcoming[19]).
In addition to digital literacy, accessibility is crucial for ensuring that digital public services are inclusive (Section 3.5.3 in Chapter 3). The EU’s Web Accessibility Directive sets a new baseline in the EU to secure better access to public services for people with disabilities, through websites and mobile apps (European Commission, n.d.[28]; European Union, 2016[29]). This directive challenges both the public and private sectors to consider how to avoid excluding any groups of users. In Portugal, the National Institute for Rehabilitation (Instituto Nacional para a Reabilitação) has provided important leadership in this area, especially during the COVID-19 pandemic when the Secretary of State requested it to offer guidance for the public sector to raise awareness about accessibility issues related to the provision of digital services.
A further aspect of digital inclusion is access to the Internet. In terms of connectivity, almost the entire country is covered by at least a 4G mobile network. However, despite this high level of coverage, general connectivity for all households falls below the OECD average (Section 3.5.3 in Chapter 3).
Portugal’s ambition to develop a genuinely “omni-channel” experience where citizens can be served in person, over the telephone or digitally is commendable but needs a consistent way of consolidating, learning and responding to feedback from different sources. Under the current system, ePortugal.gov uses a different model to the call centres and the Citizen Shops have a third way of doing things.
The current “multi-channel” model in Portugal presents challenges for designing solutions that address whole problems and ensuring easy access to services that operate across institutional boundaries. The development of ePortugal.gov as a centralised platform for accessing services and online resources is an important unifying measure that places emphasis on the citizen. Equally, Citizen Shops and Citizen Spots are an important consolidated approach for in-person services. Whereas some OECD Members have looked to reduce competing sources of information or access to services by focusing on a single brand for online and in-person services, Portugal is maintaining independent web and physical presences for various organisations and sectors. While this approach offers a range of channels for users, it also means they may need to navigate or travel to multiple places, which hinders the user experience. This divergent approach creates a need for greater co-ordination from the centre, poses challenges in solving whole problems and obstructs the ambition for seamless, end-to-end services, because the starting point is one of divergence and autonomy rather than federated collaboration.
The number of different locations and sector-specific approaches included in Box 3.6 in Chapter 3 underscores the need for a more strategic approach to maximise the benefits of the various networks. The “Government as a Platform” ecosystem (Box 5.2) allows for technical integration and organisational interoperability for digital services. A similar collaborative approach could prove beneficial in consolidating other physical service centres. Given Portugal’s geography, it is crucial to work with all government entities, including municipal governments, to create an effective network that avoids duplication, takes advantage of economies of scale and scope and ensures equal access to services for all.
As discussed, Portugal has developed a suite of guiding principles and norms related to public service reforms, influenced and informed by its membership of the EU and the OECD. These include the Common Model (Section 5.3.3), the Guiding Principles (Box 1.2 in Chapter 1) as well as those covering the once-only principle, interoperability and digital identity. The country has gone beyond many governments in creating the Guiding Principles, which prioritise respect for human rights in the design and delivery of public services. The goal is for these principles to become second nature to public servants and serve as the foundation for the way public services are designed and implemented. The drafting of the principles followed the aggregated experiences of user research on individual services, which highlighted a gap between strategic ambitions for inclusive public service design and delivery, and the practical implementation in the way those services were being experienced by users. To help develop the principles, user research interviews were carried out with 700 citizens and 500 public servants in Citizen Shops around the country.13
Examples were shared with the OECD that had been a catalyst for developing the Guiding Principles in emphasising the need for public service teams to think more deliberately about how their behaviours and processes value the users of public services.14 The first example came from user research conducted with people queueing for service channels many hours before they opened. The research found that three out of four of those waiting in line were migrants to Portugal who struggled with navigating their integration into Portuguese life. The second example was the introduction of a “digital by default” approach to tax services, where staff at tax service centres were instructed not to accept paper forms or provide additional support to the public. User researchers witnessed users being turned away without any assistance despite going to the relevant desk with their forms, receipts and paperwork.15 Both examples highlighted a failure to address whole problems, to consider the end-to-end experience of the service user and to prioritise a more people-centred approach.
As of undertaking the Review, the Guiding Principles are still a relatively new addition to the governance of public services in Portugal. During the Review process, interviewees did not express a deep knowledge or awareness of the principles (Section 1.4 in Chapter 1).16 There was, however, a consistent willingness to put the ideas into practice, highlighting the important role of the TicAPP and PlanAPP competency centres in equipping public servants with the skills and principles to support inclusive and continuously improving public policy and services. The work of multidisciplinary teams is crucial for carrying out participatory, co-designed activities that respond to whole problems to transform the end-to-end user experience.
One challenge in successfully implementing the Guiding Principles is understanding how services will be evaluated against these and other tools, such as the Common Model. Currently, there is a methodological gap in assessing the quality of a given service. This Review is a first attempt to understand how the different elements of the Guiding Principles might be assessed and understood retrospectively in the case of the Digital Mobile Key and the Family Benefit for Children and Young People.
5.4.1. Case studies
Digital Mobile Key
The Digital Mobile Key (Chave Móvel Digital, CMD) is Portugal’s national mobile digital identity solution that allows citizens to access digital services and electronically sign documents using their smartphones, tablets or laptops. The CMD offers a simple and convenient way to access multiple services provided by both the public and private sectors, with all authentication handled through two-factor authentication via SMS or email, providing enhanced security.
Before the introduction of the CMD, authentication was managed by logging in with different credentials for each service provider or using an individual’s Citizen Card with a physical card reader and authentication with their personal PIN (which had been generated when the card was issued), which was inconvenient for most Portuguese people. The CMD replaces the need for a physical card and reader with a personally chosen four-digit PIN paired with a temporary six-digit PIN sent to the user’s mobile device on demand, allowing this portable solution to be used anywhere with a mobile signal at any time. AMA has been responsible for the implementation and co-ordination of the CMD since 2014. It has worked with other national entities to broaden the availability of the CMD as a mechanism for accessing services provided by Social Security, the Ministry of Health and the Ministry of Justice. While these services are also available using the original Citizen Card and card reader approach, the improved usability of the CMD is a clear advantage and helps to further encourage the use of Portugal’s digital identity and trust services by both the public and private sectors.
The CMD design approach emphasises security, privacy and usability, using a simple SMS mechanism to take advantage of the ubiquity of mobile devices in Portuguese society. The CMD team conducts user research and embraces an agile methodology, releasing updates and improvements in two weekly sprints based on user feedback. Adoption of the CMD has accelerated in recent years, growing from around 250 000 activations a year to over 1 million for the last four years, with a cumulative total of 4.8 million active CMD accounts representing approximately 59% of the eligible population in Portugal (Figure 5.1).17
Source: Autenticacao.gov (2022[30]), Digital Mobile Key statistics, https://www.autenticacao.gov.pt/web/guest/estatisticas-de-chave-movel-digital.
The CMD associates a person’s mobile phone number with their civil identification number for Portuguese citizens or with their passport number or title/residence card for foreign citizens. There are multiple routes for users to access their CMD. They can activate it in person while renewing or obtaining their Citizen Card, through in-person support at Citizen Shops, Citizen Spots, business spots or registry offices (Box 3.6 in Chapter 3) and, since January 2023, through biometrics using the autenticação.gov app.
In 2022, 44% of CMD activations were done by pairing it with existing account details for the Portal das Finanças, which deals with tax-related enquiries. To activate the CMD through the Portal das Finanças, users start their journey on autenticação.gov and enter their unique tax number and associated password. They then confirm the association of their Portal das Finanças account with the CMD and provide their contact details to generate a one-time temporary code. After confirming the temporary code, a physical PIN is printed and dispatched through the post to arrive within five business days. This step is designed as a further layer of security to demonstrate that the person attempting to use the CMD is associated with the address connected to the Portal das Finanças account. Receipt of this PIN code, along with a validation provided by SMS, enables users to fully activate their account and use the CMD. This process is not as quick as other options but the fact that such a high proportion of activations are carried out through this route indicates the importance of connecting digital identity solutions to practical use cases. The need for people to carry out interactions related to taxation is a driver for the first-time use of the CMD, even though there is a delay in being able to use the service compared to alternative options.
Activations through autenticação.gov are faster but only accounted for 17% of activations in 2022. Part of the reason for this low proportion is that activating CMD through this route requires users to have access to a card reader. If they do so, then they must also download and install a browser plugin and place their Citizen Card into their card reader before using their PIN to access the information associated with their Citizen Card. They then associate their autenticacao.gov.pt account with a mobile phone number or email address, specify a PIN for their CMD, and agree to the terms and conditions before receiving a two-factor authentication code to activate the CMD and signature.
To address the challenges of speed and usability with these options, the ability to activate the CMD through biometrics and using the autenticação.gov app was launched in January 2023. The biometric functionality of the CMD leverages a user’s facial image as well as their fingerprints to confirm their identity against the data contained within a user’s Citizen Card instead of using a PIN to carry out authentication. The biometric functionality being added to the CMD is not new, but reuses biometric data already held by the Portuguese government as part of the established Citizen Card infrastructure. There was an immediate response to this innovation with the number of activations in the first month accounting for 29% of the total.18
A final option, used by a small proportion of Portuguese users, is the Serviços Públicos app on Vodafone TV. Prompted by a proposal made through the SIMPLEX Programme, this app allows users to access a handful of services, including requesting the CMD, which generates a letter sent to the user’s address with the necessary confirmation details.
Family Benefit for Children and Young People
The Family Benefit for Children and Young People (Abono de Família, hereafter “the Family Benefit”) is a monthly allowance paid to help families support and educate their children. It is managed by the Social Security Institute (Segurança Social, SSI). The procedure can be initiated by parents, legal representatives, the person or entity responsible for the child or the young person themself if over the age of 18. To apply for the benefit, both legal representatives and the child need to have a Social Security number.
Several elements determine eligibility for the Family Benefit. Children and young people are eligible if they live in Portugal and do not work.19 The allowance can also be claimed by Portuguese nationals living abroad and receiving income from the Portuguese state as well as foreign citizens with the necessary qualifying documentation. In all cases, the household must qualify on two fronts: the total worth of movable assets must be less than EUR 105 314.40, and the family’s reference income must be equal to or less than the fourth income bracket level, which was EUR 19 696 in 2022.20 Figure 5.2 shows that after a dramatic reduction in the number of those eligible for family benefits between 2010 and 2011, the figure was 1.17 million in 2021, the lowest figure since 2005.
Source: SSI (2022[31]), Statistics, https://www.seg-social.pt/estatisticas.
To receive the Family Benefit, eligible claimants must apply for it, either in-person or online. The benefit is not proactively provided based on government-held data about the family’s composition and income. As household circumstances can change, it is the responsibility of households to maintain an accurate picture of their eligibility. If they are no longer eligible, they are expected to inform the government, and if they become eligible after a change in circumstances, they need to initiate a claim for this and any other benefits for which they now qualify.
Applying for the benefit requires significant documentation to demonstrate eligibility and complete the application and, once submitted, takes 25 days to be actioned. In-person applications can be made at a service centre operated by the SSI or a Citizen Shop or Citizen Spot offering this service. Online applications are made through the Social Security Direct (Segurança Social Direta) website. Each social security benefit is offered independently and only when requested by a citizen. There is no unified approach that simplifies the experience of applying for social allowances based on data already held by the government.
To apply for the Family Benefit, applicants must provide identification and other documents, including a form for the allowance, a form detailing the change in the household’s composition and income and a form to request a re-evaluation of the household’s income scale. If the child has a disability, the household can benefit from additional allowances after providing documentary proof and completing additional forms. Foreign citizens must provide valid documentation that proves the right to residency in Portugal. Evidence of educational status for children aged 16-24 is also required.
The digital service to support the Family Benefit can be accessed using the CMD or other credentials managed by the SSI. Applicants provide their Social Security or tax identification numbers to retrieve the associated records from the Portuguese public sector under the once-only principle. The use of these numbers provides a check to establish whether an applicant already receives other allowances. When necessary, applicants supply proof of their legal residence in Portugal and any evidence concerning the receipt or cessation of a family benefit from other institutions. They also need to upload evidence of school registration and any other relevant documentation.
The above process is cumbersome, requiring users to assemble different documentation and complete multiple application forms. Much of the information required by the SSI to validate a claim could potentially be sourced from within the government, thereby reducing the administrative burden on users as well as the time it takes to process the claim. The SSI recognises that there are opportunities to design its services to be more user-centred, and has worked with researchers to understand how to make services easier to use, more accessible and transparent. For example, research into the opportunities for a more proactive process that would automatically respond to changes in household circumstances has looked into completing the application in hospital following the birth of a child or using data provided to the Portuguese Tributary and Customs Authority about household income. However, recommendations have yet to be implemented.21
These research efforts do not reflect a broader user-driven culture of co-design and participatory practices. Furthermore, the SSI does not have a structured or real-time approach to obtaining quantitative or qualitative feedback, which limits the extent to which these services can reflect an agile and iterative approach to continuous improvement. Citizens can submit written complaints that districts are expected to address within ten days. However, this process is not designed to make it easy to lodge a complaint, and the complaints themselves are not managed within a centralised system, meaning there is no mechanism for understanding any recurring themes or providing insights into how to improve the system as a whole.
5.4.2. How these services reflect the Guiding Principles for a Human Rights Based Approach
This chapter has so far examined the relationship between digital government, public service design and delivery and civic space in Portugal. The chapter will now focus on the specific experiences of the two case study services described above, in the context of the Guiding Principles (Box 1.2 in Chapter 1).
The nine principles are discussed in three subsections followed by an overview (Table 5.2) and service-specific conclusions (Section 5.4.3). Under Principles 1-4, questions about the design of services and the role of users in relevant processes are discussed. Under Principles 5 and 6, the importance of technical maturity is examined. Under Principles 7-9, the extent to which the two services reflect an inclusive and transparent operational maturity is explored.
Principles 1-4: Shaping the design of a service
The first four Guiding Principles highlight considerations that are important to take into account when designing new services. These principles determine the level of user involvement, recognition of the whole problem and how to manage the opportunities and challenges associated with digital technologies and data.
These ideas are ambitious and require a particular approach to the overall design of a service, which can be challenging to implement retrospectively. It is important to note that the CMD and Family Benefit are established services and may struggle to reflect the ambition of these principles as they were not initially designed with them in mind. This is in contrast to the 25 services identified in the National Recovery and Resilience Plan, which will benefit from a fundamental redesign and present an opportunity to incorporate these principles from the outset.
1. Promote citizens’ participation at all stages of the process, particularly from excluded or disadvantaged groups (partially met)
The first principle emphasises the importance of integrating the perspective of users throughout the entire life cycle of a service, from its conception through implementation and ongoing operations and improvement. This principle recognises that the design of a service should involve citizens in various ways, all of which rely on the presence of a protected and vibrant civic space, and can include research, co-creation, and new service piloting and monitoring. Involving the people affected by a policy is critical to ensure that user research captures the actual problem, not based on assumptions, to ensure that inequalities, discriminatory practices or unfair power relations are avoided. This requires targeted outreach to affected communities, including using tools and plain language that are accessible to them. Research indicates that self-selection processes (e.g. general calls for feedback on services) risk being confined to responses from particular demographics (OECD, 2021[32]). In contrast, reaching excluded or disadvantaged persons who may have good reason to mistrust state institutions requires a concerted effort, creativity and resources, including to identify appropriate methods to engage them and understand their needs.
While the respective teams of CMD and Family Benefit incorporated user input into their design approach, the ambition expressed by this principle to promote participation at all stages and from disadvantaged groups was not central to their initial design or ongoing practice. Neither service assessed the extent of adoption among eligible recipients, leaving both lacking insight into the experiences of potentially excluded groups.
However, despite being established services, there are opportunities to reconsider their operations to promote a more participatory and inclusive model. For example, the Family Benefit service already has an existing structure that could facilitate the participation of vulnerable groups. The SSI works in the community with households through its national network of social workers, providing a real opportunity to develop approaches that consistently embed user-driven and user-centred understanding of people’s needs throughout the service life cycle.
2. Design, first and foremost, for the communities in vulnerable situations (partially met)
The second principle challenges those designing public services to address the most fragile and vulnerable communities before considering other user groups. This involves understanding the circumstances of someone when they express a particular need, and being able to identify the whole problem they face. Further steps need to be taken to ensure that all citizens can access services independently and, if external support is required, it should be designed with accessibility in mind and available at no cost to those in need. This is essential for ensuring inclusive and non-discriminatory access to services (Sections 3.3 and 3.5 in Chapter 3).
The Family Benefit responds to a well-understood and articulated need for vulnerable communities. Its eligibility criteria indicate its purpose of targeting those who need it most. This benefit is provided by the SSI, an organisation created to respond to the needs of households and individuals facing different circumstances with a variety of allowances and support. However, while the policies themselves are strong, their execution raises concerns about how the SSI considers the design of its responses to be inclusive, participatory and people-centred in addressing whole problems on an end-to-end basis.
The SSI provides many allowances, and the complexity of the relationship between their provision and eligibility criteria can be a source of confusion, particularly for those whose native language is not Portuguese. Each SSI allowance is presented as a separate transaction on ePortugal.gov, and while the website attempts to be clear about the requirements for each, there are dependencies and relationships between them that are left up to the user to navigate. For example, expectant mothers can claim a prenatal allowance, but this must be requested at the same time as the Family Benefit, even though the eligibility criteria are the same for both.
A second challenge is that the onus is on individuals to apply for services. Several SSI allowances are intended to support individuals in vulnerable situations, such as following the loss of a pregnancy or due to the disability of a loved one. However, applications for these allowances are not proactively triggered and assessed through the use of data already held by the government or in conjunction with other sources, such as medical records. A pilot study for the Family Benefit explored the possibility of triggering the allowance automatically on the birth of a child. Despite being well received internally, implementing this change poses challenges, including navigating the complexity of existing legislation. Additionally, the scope of the pilot was just one allowance, the Family Benefit. Drawing on this experience, there is an opportunity to redesign and reimagine the user experience for making these allowances more available to those in need.
The Family Benefit and other allowances are available online through Social Security Direct, but users can also access these services in person. This is crucial in terms of ensuring that the family allowance is available to those with capability, accessibility or connectivity needs. The SSI has a network of 450 locations across the country and users may also complete their application at selected Citizen Shops or Citizen Spots. Unfortunately, the way in which this information is presented online means users may struggle to locate their nearest physical location. Although ePortugal.gov contains a browsable list of different “public service bureaus”, the design of the Citizen Map (Box 3.6 in Chapter 3) does not display the same filters or locations. The SSI website is better suited for users wishing to identify their most convenient location, as its version of the Citizen Map offers greater functionality. The dynamic between ePortugal.gov as the focal point for accessing digital services on the one hand and the continued independence of the SSI in maintaining its own website and network of service desks on the other highlights the importance of developing a clear strategy for achieving omni-channel service provision in Portugal.
The CMD has an underlying policy intent that recognises the importance of improving people’s lives. Digital identity is increasingly a critical element in the public infrastructure of the modern, 21st century state and, when implemented well, can empower citizens to fully participate in society and the economy. Before the CMD, the adoption of digital identity in Portugal was limited by a reliance on physical cards and card readers. The CMD aims to overcome this by being a more flexible, portable and convenient option and becoming a ubiquitous part of daily life, enabling access to both public and private sector services.
Although people can acquire and activate their CMD through different channels, there are still barriers to access, especially for those in vulnerable circumstances who may not have access to a mobile phone or the necessary documentation. While the design of the CMD as a self-contained solution is helping to achieve greater levels of adoption, it needs to be understood in the context of more general challenges related to authentication. These include the need to recognise cross-border digital identities and empower citizens to control and manage consent about how their data are used and exchanged within the government. Consideration of these wider challenges about the utility and role of digital identity in society requires explicit thinking about how they impact communities in vulnerable situations. Although there is evidence of user-centred design practices in the way in which the CMD operates, there are opportunities to explore genuinely participatory and user-driven models of co-design when it comes to thinking through an omni-channel model for identity that can work for all.
3. Analyse, in a systematic way, the expected and unforeseen consequences of service availability (not met)
The third principle stresses the importance of being analytical in framing, understanding and mapping the impact of public services, both expected and unforeseen. By engaging users in the design process, services can better meet the needs of vulnerable populations, and become more responsive.
However, new policies and services always have consequences, and this principle reminds service teams to continually assess risks, consider alternatives and implement mitigation measures where necessary.
Commitment to protecting and enhancing civic space requires reflection on the impact of new initiatives on society. Consequence scanning is therefore essential as a tool for ensuring teams are aware of how their work affects users. Unfortunately, there was limited evidence that the Family Benefit or CMD teams had established practices, either ad hoc or systematic, for analysing the consequences of their services.
For example, when the SIMPLEX Programme proposed incorporating biometric authentication into the CMD, this was piloted with a group of only 100 users before being rolled out nationally in January 2023. Surprisingly, this development was not accompanied by a broader conversation in society about its consequences, or with the participation of civil society organisations (CSOs) or other users in determining whether this development was appropriate.22 This represented a missed opportunity to conduct a systematic analysis of the consequences and risks of a service or its features, with input from the wider public.
4. Value the process as much as the outcome (not met)
The fourth principle is a crucial aspect of changing the mindset of public service teams in Portugal. While the outcome of a service is important, this principle calls for teams to focus on the process as well. This means that internal aspects of the service should be sustainable and reflect the ideals of being inclusive, accessible and people-centric. Building an internal culture of public service design and delivery that draws on the values of utilising civic space and participatory practices can lead to better outcomes for users and improve the government’s internal practice and experience. However, the focus cannot be on obtaining one-way feedback on services. Placing value on the process also necessitates an exchange and dialogue between service providers and citizens, providing responses to inputs, and building trust with users by showing how inputs are utilised. Building relationships with expert CSOs representing different groups and interests can be a valuable part of the exercise.
Both the CMD and Family Benefit teams are focused on delivering the intended outcomes for their users. However, the process has not been given as much prominence as it could have and there are clear opportunities for improving the user experience and, consequently, the overall outcome. Furthermore, neither service considered opportunities to include the perspectives of expert CSOs to gauge their support, or otherwise for any planned activities. This was particularly evident in the CMD team’s focus on the outcome of delivering biometric authentication without considering the relevant sensitivity towards the civic space in terms of the process for carrying out that development.
In the case of the Family Benefit, two areas that have already been discussed are priorities for improving the process. The first is in designing a service that addresses whole problems facing users and exploring whether there are opportunities to consolidate and simplify the allowance landscape. The second is progressing plans to make the availability of these allowances a proactive and seamless user experience.
Both teams were observed as experiencing delays between identifying new ideas and being able to implement potential solutions, despite the valuable benefits such changes could provide.23 While a cautious approach to understanding the consequences and building consensus is understandable, these delays were not due to the need for building a broader base of support. The slow pace at which relevant teams are iterating and improving their services indicates that contextual factors are limiting their success.
For example, the Family Benefit team has been working iteratively for many years and employing good user research theory to meet with users and go on location to understand their experiences and needs. However, in several cases, acting on the insight generated by these activities requires the need to change existing legal provisions or introduce new ones, the complexity of which has constrained the capacity for achieving transformative change.
It would be valuable to analyse the factors as part of these processes that slow down or impede the implementation of validated ideas. This responsibility could fall to a central co-ordinating actor such as AMA, which can assess and analyse teams’ day-to-day practices to understand where greater support might be targeted. By doing so, the teams can overcome contextual barriers in the processes they encounter and deliver the intended outcomes more efficiently.
Principles 5 and 6: Technical maturity
The second group of principles comprises two that reflect on the need for public services to be robust, resilient and well-managed from a technical point of view. These ideas speak to the importance of trust, privacy and ensuring that in the event of a problem, there is an appropriate response.
For Portugal, a country with a strong record of technology in government, it was not surprising – but still encouraging – to see that effective models were in place. This strength reflects the importance of both the Family Benefit and the CMD to the functioning of Portuguese society and demonstrates some of the elements that contribute to the foundational maturity reflected in Portugal’s performance in the DGI (Section 5.2) (OECD, 2020[2]). Portugal’s membership of the EU and the influence of directives such as the GDPR underpin this technical maturity (European Union, 2016[4]).
5. Ensure privacy and citizens’ personal data security (met)
The fifth principle is core to designing and delivering public services in the digital age. In recent years, incidents of mishandled data and privacy breaches have damaged trust in the government. To address this, various safeguards and provisions are needed to ensure the trustworthy and secure handling of data throughout the government data value cycle (OECD, 2021[33]; van Ooijen, Ubaldi and Welby, 2019[34]; OECD, 2019[3]). These measures include: minimising the collection of data; ensuring data are only used for the agreed purpose; providing users with mechanisms to provide and revoke consent; and taking steps to guarantee data quality.
The Family Benefit and the CMD have implemented several measures to ensure privacy and data security in line with the GDPR requirements. The CMD is part of Portugal’s digital identity suite of services, which includes a mobile wallet for carrying digital versions of documents of the same legal value as their physical equivalents. CMD users can access functionality that provides them with control over their data, allowing them to provide, or revoke, their consent for who has access to what.
For the Family Benefit, greater interoperability and data sharing among different government actors would simplify the eligibility process and enable a more proactive service. Internally, the SSI is taking steps to manage its data more effectively with the development of a 360° view of each user. This approach aligns with the omni-channel model, and equips support agents to identify a claimant and respond to their needs regardless of whether contact is made by email, phone or in person.
Security and privacy are crucial considerations from a civic space point of view, and CSOs are active in arguing for greater protection for citizens (OECD, 2022[35]). Protecting personal data supports an enabling environment in which citizens, journalists and civil society actors can gain access to information, express their views, operate freely and thrive without fear of arbitrary or unlawful intrusion or interference in their activities or violations of data protection laws.
While data-driven technologies can enhance public services and identify emerging societal needs, the vast amounts of data collected as well as the potential linking of public datasets also come with risks including data breaches resulting from accidents, the identification of individuals, malicious hacking and unauthorised access or disclosure. Such breaches greatly diminish trust in the digital ecosystem and may affect how citizens and CSOs conduct their online activities and access public services.
It is important to prioritise security and privacy, but there is also a need to reflect on the trade-offs required to unlock the value derived from enhanced access to, and sharing of, data among relevant parties (OECD, 2008[36]). The CMD could be a powerful tool for managing trusted relationships between different organisations in Portugal and providing an interface for users to approve, and revoke, consent.
6. Consider misuse cases as a serious problem to tackle (met)
The sixth principle is about protecting against issues with any underlying technology and rectifying any misuse that occurs. While the benefits of technology and data are a huge motivating factor in the digital transformation of society, it is important to recognise the challenges that may arise from their use in terms of limiting fundamental citizen rights or harming citizens. The CMD is notable for how its design increases security and prevents fraudulent use or access to services and data by the wrong people.
An essential aspect of this principle is to limit fraud and misuse of services by mitigating security flaws and designing services to withstand fraudulent actors. These considerations need to be present throughout the creation, testing and evaluation of each service and regularly tested with the use of “anti-personas”, which simulate the behaviours and motivations of criminals and other malicious actors. The Family Benefit service has placed a high value on security, even at the expense of usability. While the process of providing multiple documents, completing several forms and waiting almost a month for the application to be processed may not be user-friendly, the friction this multi-layered approach to security introduces for the claimant helps to minimise and reduce fraud in the system.
Principles 7-9: Inclusive and transparent operational maturity
The final principles focus on areas that shape the ongoing experience of public services for users. These principles emphasise continuous service improvement, investment in users’ capacity and understanding, and transparency in service delivery.
As with the first four principles, the measurement of their success when applied to a given service will depend on the quality of service design. The Guiding Principles form the basis for considering the design of services as an exercise in continuous improvement, starting with baseline measurements and continuing to monitor and assess performance over time to maximise effective and inclusive responses. In this way, the Guiding Principles and the Common Model are important steps towards remedying the lack of any established methodologies for guiding public sector teams in their design and delivery of public services.
Both the Family Benefit and the CMD are designed primarily as transactional interactions between the user and a service, rather than considering the broader context of the user’s situation. While the CMD is a valuable tool, it is an enabler of other services and therefore operates at the threshold of every service, which means it is not possible to break the user experience down into a single set of experiences. Similarly, the Family Benefit forms one part of the much larger policy domain of social security provision. As discussed in Section 5.3.2, the Family Benefit is one element in a “life events” understanding of what happens when a dependent joins a household. In both cases, the important reflection is that when an individual needs government support, they are likely experiencing a collection of different challenges, making it important to collaborate with other public institutions and involve a diverse sample of those affected to ensure that services respond to whole problems on an end-to-end basis.
7. Promote a continuous services monitoring and assessment (partially met)
The seventh principle highlights the importance of government services being able to adapt in response to feedback from a variety of monitoring and assessment activities. The agile and iterative approach discussed in Section 2.2.2 in Chapter 2 and applied to the Portuguese context in Section 5.3.2 creates an expectation of establishing mechanisms for obtaining both qualitative and quantitative insights on an ongoing and reliable basis, to learn from, and respond to, rather than carrying out an ad hoc or unstructured analysis. A human rights lens should be applied to this process to challenge public service teams to use performance data to identify possible cases of misuse, discrimination, inaccessibility or other violations that may limit citizens’ rights, and respond with corrective measures.
At a foundational level, the CMD exists because the team responsible for digital identity in Portugal identified deficiencies in the earlier model, particularly from an inclusion point of view. Given that it involves highly sensitive public infrastructure, the service is continually monitoring its systems and processes to ensure that they are secure and functional. While ensuring that the technical maturity of the CMD is important, the service also needs continuous monitoring and assessment of its role in society. As discussed under Principle 4, the CMD team tends to focus on technical implementation, rather than considering its wider contribution to designing more inclusive services.
The Family Benefit team is also monitoring and assessing the security and safety of its service, as well as routine service performance indicators, such as the proportion of applications processed within 25 days. However, the OECD’s desk research found that the Citizen Map on ePortugal.gov was not displaying accurate information compared to the SSI’s own map (discussed under Principle 2) suggesting that monitoring of the Family Benefit is not considered in terms of resolving whole problems on an end-to-end, omni-channel basis. Moreover, interviews during the fact-finding mission found that the relevant team was unable to provide data on the number of households eligible for the Family Benefit but that had not applied for it.24 For a service designed to support the needs of vulnerable communities, one of its priority objectives should be to achieve close to 100% uptake and this data would be essential to understanding accessibility challenges and identifying how they might be addressed.
8. Develop the right-holders’ and duty-bearers’ capacities (partially met)
The eighth principle emphasises the importance of public service taking a holistic approach to meeting the needs of its users beyond completing a transaction. This involves empowering citizens, as rights-holders, with the necessary knowledge, skills and opportunities to be able to fully participate, without discrimination, in accessing public services and contributing to their design and delivery. It also means ensuring that public sector institutions have the resources, skills and motivation to provide those services as duty-bearers.
While there is a growing preference for digital services, it is important to address the potential digital divides that may exclude certain right-holders from accessing public services. Portugal’s ambition for an omni-channel model of service design and delivery recognises the need for in-person support to accommodate the capacity of all right-holders to access services. For instance, both the CMD and the Family Benefit services offer in-person support to those who may not have confidence in using digital services, which helps to develop their capacities to thrive in the digital age. Moreover, by increasing users' familiarity with the CMD and the Family Benefit, they may be more likely to access and claim other services that can support their daily lives, in both the public and private sectors. Without this support, these users might face difficulties expressing their rights to access such services.
However, beyond the Family Benefit, the SSI could do more to embed this idea into the design of its services more broadly and throughout the service life cycle, and consider the rights of service users. In the context of the Family Benefit, it is essential that access is made available to the necessary information in a way that everyone can understand, particularly vulnerable communities who may struggle with language barriers or the complexity of application forms. An important element in ensuring the capacities of rights-holders is providing access to the information they need to understand their entitlements. In this context, it becomes even more important to design services, such as the award-winning Automatic Social Energy Tariff (Box 5.1), which solve the hardest parts of a problem, such as the initial application, without a citizen needing to negotiate it.
The other part of this principle considers the development of the capacities of duty-bearers. The service teams responsible for the CMD and the Family Benefit belong to two high-profile organisations in Portugal and are therefore well-resourced. Nevertheless, developing the internal capacities of public servants in respect of transformational service design and delivery did not appear as a priority within the service teams themselves. Instead, the Review identified that the Guiding Principles and the Common Model are important foundations for creating a shared understanding and unifying methodology for service design and delivery in Portugal. These tools are enablers for creating a whole-of-government approach, which, as discussed in 5.3.3, forms part of a wider “Government as a Platform” ecosystem. As has been noted, important contributions to the capacities of public servants are being led by the teams at the TicAPP and PlanAPP competency centres in effecting consistent and coherent change in the underlying culture rather than this being seen as a responsibility for service teams themselves.
9. Ensure transparency on obligations, responsibilities and rights regarding services (partially met)
The final principle is an extension of Principle 8 and further emphasises the importance of openly communicating with users to ensure they have a full understanding of everything they need to know about a given service. This places an obligation on public service providers to be clear about related obligations, responsibilities and rights, including information about costs as well as mechanisms for providing feedback, seeking redress and filing complaints.
For the CMD and Family Benefit services, Principle 9 is reflected in Portugal’s “Government as a platform” ecosystem of enabling tools and resources (Box 5.2). Although the lack of a clear omni-channel strategy to govern the relationship between different organisational websites impacts the dynamic between ePortugal.gov and the SSI’s own web presence, the consistent approach to providing information through ePortugal.gov does create momentum for at least standardising the process of ensuring that users are aware of what they need to know to successfully complete a service interaction. The Catalogue of Entities and Services (Box 5.2) is an important contribution to collating information about public sector organisations, the services they provide and the relationships among them. Such a data set could also provide the basis for exploring how different organisations can work together to solve similar and related problems that involve multiple actors.
For both services, this principle poses a challenge for future work in effectively communicating any transformational use of digital technology or data to service users. For example, the greater use of biometric data or making services more automated may introduce negative outcomes. Open and transparent communication about the visibility of algorithms and the role of automated decision making or data-handling is crucial for demonstrating this principle, and a human rights-based approach in general.
5.4.3. Service-specific conclusions and recommendations
Table 5.2 shows how the two services have been examined in light of the nine Guiding Principles. In both cases, the CMD and Family Benefit services only failed to meet Principles 3 and 4; partially met Principles 1, 2, 7, 8 and 9; and successfully met Principles 5 and 6.
This exercise indicates that the Guiding Principles will be most valuable as a set of ideals for teams to embrace when services are being transformed or to guide the design of new services, rather than as an effective mechanism for analysing the current state of an existing service. This is because the reality of these existing services will fall somewhat short of the ambition contained within the principles.
To ensure that the Guiding Principles can facilitate an inclusive and participatory transformation of public services in Portugal, public servants will need to become deeply familiar with the ideas so that they are applied instinctively. Policy levers such as the guidelines, the Common Model and assurance mechanisms are important components of “Government as a Platform” ecosystems, but there needs to be a more comprehensive approach to developing enabling tools and adequate resources to support multidisciplinary teams in transforming public services.
Overall, the Guiding Principles have the potential to bring significant benefits to Portugal's public services by promoting a human rights-based approach to service design and delivery. However, it will take sustained effort and commitment from public servants and policymakers to fully realise these benefits.
The Digital Mobile Key
The adoption of the CMD is increasing in line with the high ambitions for the service but one in three eligible Portuguese are not making use of it. To ensure the success of the CMD, it is crucial for Portugal to continue to prioritise digital inclusion and make the service accessible to as many people as possible. Although users were involved in testing the service, user engagement does not appear to have been a priority during the development of the CMD25 and participatory practices as envisioned by the Guiding Principles were not used. They also did not appear to be an ongoing part of the service design process for digital identity and authentication services in general. It is essential to explore continuous opportunities for users to engage in testing, iterating and improving the service throughout its entire life cycle.
While the benefits of an agile approach are understood, delays in releasing new features indicate the presence of internal barriers preventing the CMD service team from releasing changes to the service as quickly as needed. The wider organisational culture would benefit from being encouraged to develop a bias for exploration, experimentation, learning and incremental improvement.
Stakeholders should be engaged on an ongoing basis throughout the design and delivery process to ensure accountability and quality. Unfortunately, the description of how biometric functionality was developed appeared to reflect a deliberate decision to limit awareness rather than to have had an open dialogue about a topic that has proven controversial in other jurisdictions.26
Finally, metrics are needed to improve the availability of insights into the quality and outcomes of the service, in addition to user satisfaction levels. The CMD is an influential service, and adopting an exemplary approach to understanding, and responding to, performance data could inspire ongoing iteration and improvement elsewhere. Individual users and expert CSOs representing marginalised and vulnerable groups have valuable roles to play in providing insights, and civic space should be utilised more effectively to obtain data.
Family Benefit for Children and Young People
The Family Benefit service in Portugal can be improved by engaging more with users, including expert CSOs. The SSI has many opportunities to engage users in discussions about the effectiveness and experience of their services. By doing so, the SSI can gain a better understanding of its users’ needs and ensure that they are informed about their rights.
While doing more to engage the public is important, SSI’s services would also benefit from an investment in the quality of language and explainability of underlying algorithms. Using simple language and ensuring that algorithms and automated decision making are explained would help users to understand how the Family Benefit is calculated and communicate the parameters of eligibility to a wider audience, thereby strengthening overall transparency of the service.
In addition to proactively looking for ways to utilise civic space more effectively to involve the SSI user base, the Family Benefit service also presents an opportunity to use qualitative user journey mapping and quantitative data analytics to understand how to improve the service on an ongoing basis. By inviting feedback and measuring the use of services, the SSI will gain a better understanding of its users and be able to iterate services accordingly.
Finally, there are great opportunities to use digital technologies and data to transform the Family Benefit. The current application process for the Family Benefit can be cumbersome and places a burden of supplying evidence on users. The SSI should consider using existing knowledge to proactively activate services for all qualifying households. The fact that a more proactive model has been piloted is an extremely positive step and a key recommendation is to accelerate the use of data to achieve an even more proactive and seamless service.
This Review comes at a valuable moment in the evolution of Portugal’s commitment to achieving people-centric, inclusive services and embedding a participatory, user-driven approach to societal needs that uses and takes full advantage of its protected civic space. Portugal has made significant strides towards developing a strong foundation in terms of both civic space and leadership at a political and organisational level for embracing people-centred ways of working.
As discussed in Section 1.2 in Chapter 1, Portugal’s political leadership has consistently advocated for people-centric transformation of the functioning of the state to address societal needs. This is supported by a record of valuing open government and committing to ambitious OGP action plans that promote transparency and accountability, while also fostering public participation through innovation and technology. The fact-finding mission indicated that there is a diverse and active network of CSOs across the country with a willingness to act as an intermediary between government and vulnerable or potentially excluded groups.27 While there is room to improve the support and level of participation from these organisations, Portugal has several opportunities to build further on existing initiatives.
One of the initiatives that has helped to achieve an inclusive and people-centric mindset is the SIMPLEX Programme. It has helped to simplify daily life for citizens and businesses by reducing administrative burdens and inspiring more creative and transformational uses of digital technologies and data. Additionally, the cross-departmental initiatives spearheaded by AMA in order to modernise public services and encourage co-operation among public sector institutions have contributed to creating this mindset. LabX has also been successful in protecting and enhancing the innovation ecosystem in the Portuguese public sector and promoting the renewal of public services in line with the lived experience and real needs of citizens and businesses.
While these efforts have resulted in some notable successes, there is inconsistency in applying these ideas and methodologies as a default, baseline practice. However, skilled and motivated individuals who understand good service design are making a difference in their organisations. Equally, the ongoing work of the TicAPP and PlanAPP competency centres to build and develop the digital government and strategic foresight capacities of the public sector workforce will continue to increase the appetite and confidence for working in a different way (OECD, forthcoming[19]). Those efforts will be encouraged and supported by the enabling tools that AMA is developing and curating, such as the Guiding Principles and the Common Model. These set a new benchmark for how teams should consider the needs of users and respond to them in ways that are inclusive, open and participatory from the outset.
There are opportunities for Portugal to build on existing good practices and scale them to become the default model and habitual practice within the public sector as a whole. The National Recovery and Resilience Plan provides the perfect opportunity to focus on the 25 “life event” services and model a different way of operating that puts ambitious ideas and practices for transformational, participatory and iterative public service design and delivery into practice. However, it is important to go beyond the 25 services and recognise the opportunity to embed lasting, people-centred, inclusive cultural change across the entire public sector.
The following provides a summary of the main recommendations and actions for the Government of Portugal to consider, based on the Civic Space Review of Portugal: Towards People-Centred, Rights-Based Public Services. The government could consider:
1. Placing people at the front and centre of public service design and delivery. To further strengthen its ambitious reform processes, Portugal should promote people-centred, rights-based, end-user perspectives in the design, delivery and evaluation of public services that reflect the needs, concerns and behaviours of diverse audiences, particularly those who are vulnerable or under-represented. Service providers are well placed to take advantage of Portugal’s healthy civic space environment to ensure that people are actively engaged in shaping public services by collaborating with community leaders, national and local CSOs, and other non-governmental actors to ensure that reform processes are inclusive, participatory, non-discriminatory and responsive to real needs.
2. Harnessing bottom-up energy for change. Top-down decision making from the centre of government can use organisational hierarchies to impose reforms and direct behaviours using policy levers. However, true transformation that embeds a more inclusive, accessible and people-centred approach to public services by engaging citizens throughout the public service life cycle will require inspirational champions at every level of the public sector, from senior management to frontline officials. Drawing on existing mechanisms to promote the participation of public servants, frontline officials should be engaged in the discussion, design and assessment of services in a regular way. Identifying leaders and harnessing their passion can be powerful in building momentum and could be facilitated by creating and investing in multidisciplinary practitioner networks to encourage peer communities with common purpose within and between different public institutions. Public recognition of their work could also help to build momentum.
3. Facilitating inclusion more systematically. Besides ad hoc consultations on in person services and online platforms, there is no systematic monitoring of who is able to access services, and which groups are excluded and why. Inclusion could be enhanced by: monitoring and evaluating relevant services; utilising civic space to collect feedback from citizens, CSOs and other stakeholders more systematically; and engaging in targeted outreach initiatives to under-represented groups to understand and respond to particular needs via tailored services.
4. Facilitating civil society collaboration and leadership in public service reform processes. By identifying relevant organisations with expertise and seeking to partner more proactively and consistently with them, Portuguese service providers can utilise civic space more effectively. The government could consider creating an advisory board composed of private sector, academia and civil society representatives to institutionalise collaboration and provide ongoing inputs in the development of policy levers such as the Guiding Principles, Common Model or other forthcoming initiatives aimed at enhancing public service design and delivery.
5. Promoting regular participation of stakeholders throughout the public service life cycle. Portugal has established an impressive stakeholder participation ecosystem through its multi-stakeholder forum in the framework of the OGP, existing consultation platforms (i.e. ConsultaLex.gov and Participa.gov) and other relevant initiatives (e.g. National Participation Day, participatory budgeting). However, apart from efforts led by LabX, opportunities for Portuguese citizens to participate in the design, implementation and evaluation of public services beyond what is strictly mandated by law (e.g. providing suggestions, feedback and complaints on services) are limited. Learning from the experience of LabX and building on the existing infrastructure for participation, Portugal could seek to enhance the quality and quantity of opportunities, both online and off line, to engage stakeholders across all stages of the public service life cycle. One way to do so is to measure the adoption of services against their eligibility criteria in order to gain insights into the experiences of potentially excluded groups, and proactively use this information to address barriers and improve engagement at different stages of service design and delivery.
6. Facilitating cross-institutional cooperation for public service design. The SIMPLEX programme has been very successful at facilitating co-operation and collaboration across organisational boundaries. This focus on collective endeavour is essential for solving whole problems, avoiding duplication and repeated pain points for users. AMA plays an important convening role and, through the Council for Information and Communication Technologies in Public Administration (Conselho para as Tecnologias de Informação e Comunicação na Administração Pública) and the Interministerial Council for Digtialisation (Conselho Interministerial para a Digitalização), could secure the leadership and mandate to convene multiple institutions to solve problems facing users that would otherwise continue to be treated in a fragmented and siloed way.
7. Continuation of a strong central mandate and leadership on public service reforms. Portugal’s public sector modernisation has benefited from the support and commitment of senior politicians in advocating for inclusive, accessible and people-centred public services. To sustain this momentum, it is crucial to continue investing in AMA and securing the necessary resources to attract and retain a talented workforce that can effect change across the government. AMA will benefit from being empowered with the mandate and authority to propose cross-cutting changes to public service design and delivery.
8. Continuing to invest in, and develop, digital government transformation. The government of Portugal may consider using the Digital Government Policy Framework to inform strategic approaches for the effective design and implementation of digital technology and data. This will help to further enhance the digital government maturity of the public sector.
9. Seeking clarity about the channel strategy for Portugal. Portugal has made commendable efforts in complementing digital channels with access to in-person services, particularly to reach marginalised communities and serve the elderly. However, the presence of different web channels and in-person networks managed by multiple organisations could lead to fragmented user journeys. The Citizen Shop and Citizen Spot networks have helped to decentralise operations at the local level, but there is a need to empower municipal governments to tailor service delivery to the needs of the local context and population. The diversity of in-person networks is an opportunity for consolidation and collaboration throughout the country. Although their presence is clearly valued by users and valuable to the government, they currently reinforce organisational silos rather than unlocking economies of scale and scope to address whole problems on an end-to-end basis. The government of Portugal could further articulate a whole-of-government approach building on the existing commitments in its 2nd OGP National Action Plan, which is focused on strengthening service delivery channels to increasingly tailor these to the needs of different population groups. There are positive indications that the adoption of the CMD is leading to organisation-specific credentials being phased out, but the experience of the Family Benefit indicates that maintaining separate organisational structures is more influential than creating a seamless user experience. The current approach to channels means users need to negotiate the structures of government both online and in-person. The 25 “life events” services provide an opportunity to consider the service delivery landscape in the context of demonstrating how to solve whole problems for users, without them needing to navigate between different public institutions.
10. Developing a consistent narrative and methodology for public service reforms that the entire public sector recognises and endorses. At a strategic and political level, there has been consistency in the language used to describe the ambition for public service transformation. However, this is not matched by a consistent narrative and methodology among practitioners, in part because relevant frameworks such as the Guiding Principles are not well known. It is essential that individual initiatives such as the Guiding Principles and the Common Model are brought together into a clearly communicated agenda for change. Furthermore, in order for AMA’s vision for the future of public service design and delivery to translate into everyday practice among public sector organisations, it will be essential to disseminate its vision and associated activities more widely. The consultancy model of AMA and LabX in working alongside practitioners in different organisations is one way of achieving knowledge transfer and building capability. The work of the digital competency centre, TicAPP, to raise the baseline of digital capability for all public servants is another opportunity to embed the Guiding Principles and Common Model. As LabX undertakes a process to update the Guiding Principles, engaging relevant public officials together with civil society, academia and citizens throughout relevant consultation will undoubtedly help to raise awareness, support their uptake and ensure their practical relevance.
11. Using policy levers (e.g. policy tools and resources) to guide behaviour and promote, support and incentivise change in teams leading public service reforms. Transforming approaches to designing and delivering public services relies on changing how teams operate and behave. AMA now directly reports to the Prime Minister and has the mandate for digital transformation across society, allowing it to offer incentives, set expectations and enforce policies to embed a different way of working. In this new role, AMA may wish to consider whether new policy levers could be introduced and tailored to the Portuguese experience, learning from the way other OECD Members have achieved these outcomes (OECD, 2021[13]). In some Members, the favoured policy levers focus on controlling access to funding and using business case and reporting mechanisms to shape behaviours and culture. A different approach could be to focus more energy on post-implementation activity, with an active assurance function assessing compliance against norms. A third model could be a softer approach to provide guidance, mentoring and coaching.
12. Setting ambitious performance targets and facilitating monitoring and watchdog initiatives. Increasing the frequency and availability of performance reporting in general will be a helpful contribution to enhancing efforts to respond to feedback and continuously improve individual services. Strong reporting metrics and ambitious targets focused on the questions of systemic change and organisational culture will help Portugal to understand the extent to which the narrative and methodology for public service transformation are helping public servants to design and deliver more inclusive, accessible and people-centred public services. Alongside the establishment of these mechanisms, it will be critical to empower and actively facilitate citizens and civil society to operate as independent assessors and watchdogs to keep the government accountable through continuous monitoring and evaluation of government targets. The facilitation of funding, whether from public or private sources, for independent expert think-tanks and CSOs could help in this regard.
13. Continuing to monitor the protection of civic space and addressing any restrictions. Ongoing monitoring of the different dimensions of civic space, as identified in this Review and using disaggregated data – including to identify and tackle any emerging negative trends particularly in relation to marginalised groups – will help to ensure the correct conditions are in place for Portugal’s ambitious public service reform agenda to achieve maximum impact. A coordinated approach to monitoring from the Centre of Government would enhance this effort across ministries and other public institutions.
References
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[1] Welby, B. and E. Tan (2022), “Designing and delivering public services in the digital age”, Going Digital Toolkit Note, No. 22, OECD, Paris, https://goingdigital.oecd.org/data/notes/No22_ToolkitNote_DigitalGovernment.pdf.
Notes
← 1. The SIMPLEX+ Programme won the overall 2019 European Institute of Public Administration’s European Public Sector Award with the same process recognising Citizen Spots (providing supported assistance for citizens to access digital services) and the Automatic Social Energy Tariff (automatically offering affordable energy tariffs to low-income consumers) as deserving of best practice certificates.
← 2. Based on interviews with 15 CSOs and 24 public institutions from 15 November 2021 to 4 May 2022.
← 3. Based on interviews with 15 CSOs and 24 public institutions from 15 November 2021 to 4 May 2022.
← 4. Based on interviews with 15 CSOs and 24 public institutions from 15 November 2021 to 4 May 2022.
← 5. Based on interviews with 15 CSOs and 24 public institutions from 15 November 2021 to 4 May 2022.
← 6. Based on interviews with 15 CSOs and 24 public institutions from 15 November 2021 to 4 May 2022.
← 7. Based on interviews with 15 CSOs and 24 public institutions from 15 November 2021 to 4 May 2022.
← 8. Based on interviews with 15 CSOs and 24 public institutions from 15 November 2021 to 4 May 2022.
← 9. Based on interviews with 15 CSOs and 24 public institutions from 15 November 2021 to 4 May 2022.
← 10. Based on interviews with 15 CSOs and 24 public institutions from 15 November 2021 to 4 May 2022.
← 11. See https://mosaico.gov.pt/
← 12. See https://mosaico.gov.pt/
← 13. Based on interviews with public institutions from 15 November 2021 to 4 May 2022.
← 14. Based on interviews with 15 CSOs and 24 public institutions from 15 November 2021 to 4 May 2022.
← 15. Based on interviews with public institutions from 15 November 2021 to 4 May 2022.
← 16. Based on interviews with 15 CSOs and 24 public institutions from 15 November 2021 to 4 May 2022.
← 17. Data received from the Government of Portugal, March 2023.
← 18. Data received from the Government of Portugal, March 2023.
← 19. Student jobs during holidays are permitted.
← 20. Data are from blueprints of the service undertaken for this Country Review.
← 21. Based on interviews with public institutions from 15 November 2021 to 4 May 2022.
← 22. Based on interviews with 15 CSOs and 24 public institutions from 15 November 2021 to 4 May 2022.
← 23. Based on interviews with 15 CSOs and 24 public institutions from 15 November 2021 to 4 May 2022.
← 24. Based on interviews with 15 CSOs and 24 public institutions from 15 November 2021 to 4 May 2022.
← 25. Based on interviews with 15 CSOs and 24 public institutions from 15 November 2021 to 4 May 2022.
← 26. Based on interviews with 15 CSOs and 24 public institutions from 15 November 2021 to 4 May 2022.
← 27. Based on interviews with 15 CSOs and 24 public institutions from 15 November 2021 to 4 May 2022.