CoWIN has been developed as a digital platform to support Covid-19 vaccination efforts in India. While most are familiar with the interface for citizens to book vaccination slots, CoWIN also supports multiple other functions. It is part of a sophisticated digital ecosystem, which monitors the vaccine supply chain, the vaccination staff and facilities, and records after-effects of immunisation.

In addition, CoWIN is an important part of a 2019 service delivery ecosystem known as the National Digital Health Ecosystem (NDHE), which facilitates better information flow in the healthcare sector. Various sectors and jurisdictions in India are slowly adopting such digitised, ecosystem approaches to deliver government services to citizens.

CoWIN has been central to the vaccine administration process as the single point of vaccination enrolment. Since CoWIN was deployed at a large scale, its unique experience as a service delivery platform developed to meet the time-sensitive needs of vaccine administration can offer learnings for other digital welfare delivery systems to adopt. Such learnings could provide critical insight to strengthen the digital public service delivery architecture in the country.

Key principles

We posit that a complex digital system such as CoWIN should be measured on four key principles: (i) how inclusive is the platform? (ii) does it handle citizen’s data responsibly? (iii) does it create efficiencies for the citizen? and (iv) is it built upon strong systems of accountability? In this piece we unpack each of these principles based on the CoWIN experience.

CoWIN has been successful in enrolling and facilitating approximately 48 million vaccinations, for 45 million registered beneficiaries in eight months. Government estimates from June suggest that on-site registration accounts for nearly 80 per cent of all vaccines administered. Complementing digital infrastructure with offline infrastructure is emerging as a global best practice in social protection.

The success of on-site registration in CoWIN reminds us of the need to support digital service delivery with offline infrastructure. We measure inclusivity of platform based on its ability to onboard all citizens and eliminate any exclusion, while offering the option for those excluded to re-gain access to the platform.

Usually, reduction in leakages, corruption and improvements in cost-efficiency have been compelling reasons to digitise welfare delivery. On the other hand, it is important that digital systems focussed on cost-efficiency have led to instances where eligible citizens have been denied their entitlements. With a digitally focussed delivery system, evidence from other countries has shown that the most affected by these unintended consequences are the most vulnerable communities of citizens. The Supreme Court of India even flagged that India’s stark digital divide impedes access to CoWIN, and could have serious implications on the rights to equality and health.

Registration

Vaccine registration was initially accessible only via digital platform with no assisted or offline substitute. Though offline alternatives were progressively introduced six months post initial rollout, they too faced problems: the network of Common Service Centres (CSCs) remained sparse, helpline numbers for phone-based registrations have been down, and ASHA workers who assist in rural vaccine registration had declared strikes. They contributed to increasing vaccination rates, though many had already been excluded at the crucial initial stages.

The evidence suggests that minimising exclusion requires complementing offline and digital components in welfare delivery systems. Over the coming months, for CoWIN to become a stronger enabler of the vaccination effort, it should emphasise and increase the use of complementary, offline models of access. The experience of CoWIN shows that even a robust digital system can have limitations when it does not take into consideration universal inclusion.

CoWIN was rapidly deployed to facilitate registration of beneficiaries for vaccination. It was designed to support traffic of up to 20 million vaccinations daily, collecting personal particulars from citizens for the same. Like other digital platforms, CoWIN accumulated a significant amount of personal data which enabled real-time policy decisions. However, unlike other platforms, CoWIN did not have a privacy policy until it was prompted by an intervention from the Delhi High Court around 140 days after its initial launch.

While the development and deployment of CoWIN was under unique circumstances, having relied on the platform to deliver vaccines without a privacy policy was a major flaw. Since the Puttaswamy judgment and the Personal Data Protection Bill of 2019, privacy protecting frameworks have been an extant requirement for digital delivery systems. CoWIN’s privacy policy now adheres to key data protection principles such as use limitation, purpose specification and data retention. However, it is silent on issues such as data storage and encryption, access control, and a time-bound data retention policy.

Health IDs

Another concern has been the allocation of Unique Health IDs in citizens’ vaccine certificates without citizen consent, raising concerns regarding the legitimacy of consent obtained. The CoWIN experience offers a lesson for those developing and deploying end-to-end digital ecosystems for service delivery to focus setting up protocols for responsibly handling citizen’s personal data. These instances highlight systemic lessons for designing digital ecosystems: citizens’ autonomy and trust in the use of their data must be preserved.

Another key role of CoWIN has been in real-time monitoring of vaccine supply chain and administration. A primary reason for the adoption of CoWIN was its role in creating efficiencies in a critical vaccination effort. However, when a critical public good such as Covid-19 vaccines are made available primarily through a digital platform, the hope is that the system may create efficiencies (of time, effort) directly for the citizen as well.

While any digital system may have bugs, some inefficiencies that impacted citizens came up — many people wrongly received vaccination confirmation texts, certificates were issued to the unvaccinated, and confirmed appointments were cancelled. Given that rollout through a digital platform was to avoid such growing pains, it is worrying that these errors persisted.

Redress mechanism

The lack of an effective grievance redress mechanism for citizens further exacerbated such concerns. Such issues are symptomatic of a system which has potential to reconsider how efficiencies can be realised for citizens. Digital ecosystems should be designed to minimise the costs incurred by citizens while accessing welfare schemes, while incorporating feedback to improve the system. In the case of rapidly deployed systems such as CoWIN, there is a need for faster feedback loops to ensure consistent improvement.

Service delivery for critical goods such as vaccines limit the choices of citizens. Citizens cannot opt out of consuming essential services like vaccines, nor can they choose between service providers. It is then essential to ensure that citizen voices are responded to by embedding accountability into the system. The absence of strong accountability mechanisms led to abuses of power in vaccine administration through CoWIN.

For instance, an elected representative in Pune was able to facilitate vaccinations for acquaintances without appointments on CoWIN. Far more concerning were reports that grievance helplines were not functioning. Such instances indicate the need for a two-fold structure of accountability: to the exchequer who funds welfare activity, and to beneficiaries who benefit from it.

In conclusion, digital ecosystems that facilitate service delivery must be inclusive, responsible of citizen data, efficient to the citizen, and backed by systems of accountability. Despite any hiccups in the CoWIN vaccine administration system, some of which were recognised by the Supreme Court, CoWIN provides a unique opportunity to help create even better digital delivery systems in the future. The success of the CoWIN experiment shows that transitions to such platforms must be made with active focus on citizen-centricity.

The writers are Research Associates, Dvara Research