The former architect of Australia’s immigration visa system has warned moves now afoot to outsource the processing of millions of applications to private infrastructure carries “immense” IT risks.

And he's called for any proposed contract to be first vetted by Australian National Audit Office and Australian Competition and Consumer Commission before it is inked.

With the clock rapidly ticking down to a decision on who will pick up the deal valued at around $1 billion, respected former Deputy Secretary of the Department of Immigration, Abul Rizvi, has used a Senate inquiry submission to catalogue a raft of IT pitfalls surrounding the proposed privatisation.

“The risks associated with visa privatisation, once Home Affairs has become totally dependent on a monopoly owner of the visa processing IT platform, are extensive,” Rizvi said in a submission to the Legal and Constitutional Affairs References Committee inquiry into the impact of changes to service delivery models on the administration and running of Government programs.

“Home Affairs has provided no explanation of how these many risks are to be managed.”

The essence of the alarm bell Rizvi is sounding goes to the commercial-in-confidence shielding from public view of the visa processing outsourcing program’s business case and the assumptions it is based on.

The submission notes that previous major tech refreshes at Immigration have not always run well or have hit experienced difficulties, with execution capability an obvious key risk.

“Previous attempts at major redevelopment of Australia’s visa processing IT platform have encountered significant delays and cost blow-outs due to developers underestimating complexity and the constantly changing nature of immigration policy,” Rizvi cautions.

“What allowance has Home Affairs made for the winning bidder similarly underestimating complexity? How will Home Affairs deal with delays and cost blow-outs? How will these be paid for?” his submission questions.

While there is still a paucity of official acknowledgement on who is bidding for the work, the two main contenders are known to be 'Australia Visa Processing' – a conglomerate consisting of Ellerston Capital, PwC, Qantas Ventures, NAB and Pacific Blue Capital – and Australia Post and Accenture consortium.

Envisaged as an online self-service platform – dubbed the global digital platform – the first visas to run through the new outsourced platform are tentatively slated for first half of 2021, with a bid winner expected to be announced this year, potentially as soon as October.

Part of the outsourcing push's appeal to the government is delivery of fixed cost transactions and the divestment of expensive infrastructure that has become a burden on an otherwise a lucrative revenue stream.

The current timeline suggests the new outsourced system would need to be built in less than two years, although some preliminary modelling work has already been undertaken, Home Affairs went looking for a partner to deliver the platform in September 2017.

A co-design phase ran over 16 weeks between March and July 2018 and was based around “two separate journey teams, each comprising of staff from a shortlisted respondent and the department”, iTnews reported at the time the tender documentation was released.

“Over 16 weeks, these journey teams worked collaboratively to solve critical design questions and develop a more detailed view of the proposed platform solution,” the 2018 tender documents state.

However Rizvi cautions there is still ample potential for the project to choke and become bogged down in complexity, thus putting pressure on commercial viability, with visa applicants potentially forced to absorb any financial hit.

“While Home Affairs has for years talked about visa simplification, that remains a pipe-dream. If anything, Home Affairs has in recent years made the visa system more complex and more confusing. The replacement of the sub-class 457 visa is a good example,” Rizvi argues.

“Maintaining an IT platform for such an increasingly complex visa system will inevitably involve growing costs. Will Government agree to ever increasing visa application fees to meet the demands of the private company that would be the monopoly owner of the IT platform?”

Where does the data go?

A further concern for the former visa scheme chief is that cost blowouts could prompt any successful bidder to try and monetise sensitive data.

“Another ‘innovative’ way for the owner of the IT platform to increase profit would be through the extraordinary data the owner would hold,” Rizvi said.

“Australia’s citizenship and visa databases hold some of the most extensive and detailed data on Australian citizens, family and humanitarian sponsors, education providers, overseas students, tourists and companies who sponsor overseas workers. This database would be incredibly valuable.”

Aside from the issue of data protection, Rizvi questions if and how “the IT platform owner could use and/or sell the data.”

“While Home Affairs may argue it would never agree to this data being used inappropriately, the pressure from the owner of the IT platform to chip away at Home Affairs’ resistance would be relentless.”

But perhaps the most telling recommendation id for the government to build in escape hatches to mitigate consequences in the event the new system croaks at either a technology or commercial level.

“If the privatisation proceeds, the contract must include a pathway and mechanism for the government re-acquire the IT platform at reasonable cost, if the privatisation fails,” the Rizvi says.

Advice from hard headed former mandarins may not always be palatable. But that doesn’t mean it’s not pertinent.