By the time Emma* started showing mild symptoms of COVID-19, she was presented with two options: request a Home Testing Kit or attend a drive-through testing facility. As Emma can’t drive, and social distancing meant getting a lift was impossible, she opted for the mail-order kit.

Emma made three attempts to access a Home Testing Kit. Each time she was told her identity couldn’t be verified and therefore she would not receive her test. Instead she was told to attend a drive-through testing centre.

“I thought I might have the virus so I tried to get a test,” Emma told openDemocracy.”In the process I learned in order to get a test you have to have a car you are capable of driving, or a credit check company needs to verify your identity.”

The identity verification for the NHS’s contact tracing programme is contracted to TransUnion, a US company who told openDemocracy they are “supporting the NHS response to the current pandemic in its provision of testing kits to those throughout the UK that have shown symptoms of COVID-19.’ Their identity checks on behalf of the NHS ‘help ensure testing kits are sent to the correct recipients and to minimise the risk of fraud.”

But as Emma’s case shows, not everyone can be verified by TransUnion, and therefore not everyone who needs to can get a Home Testing Kit, leaving a hole in the government’s test and trace strategy.

On the electoral roll

Emma decided to dig a little deeper into why TransUnion couldn’t verify her identity and left her unable to access a coronavirus test. She used the multi-agency credit support service CheckMyFile.com to learn the NHS had used TransUnion to check her three times.

The data showed TransUnion had run numerous checks on Emma but, unlike other credit agencies, they failed to confirm she is on the electoral roll.

“But I am on the electoral roll,” Emma explains. “I’m just on the ‘hidden’ register,’ along with 3,400 other “anonymous electors.”

TransUnion told openDemocracy that “those who are registered anonymously on the electoral roll will not appear on the open register, which is used for these identity checks.”

If TransUnion is using only the ‘open register’, this could have implications not just for those on the ‘hidden’ register (usually for reasons of their own safety), but potentially for the much larger group of voters on the ‘closed’ register.

However, TransUnion told openDemocracy that if someone experiences issues with electoral registration it “does not mean they cannot get a testing kit. The electoral register is just one of the sources used to verify identity.”

This still leaves unanswered questions. TransUnion used a range of measures to verify Emma’s identity. They checked Emma’s accounts, linked addresses, credit applications, fraud warnings and court judgements, which were all fine. And yet, her identity still couldn’t be verified and she couldn’t get a test.

‘I’m just going to stay in’

And she’s not the only one. The Health Services Journal has also covered how gaps in TransUnion’s database have left people unable to access a test. Louise O’Day in Brighton ‘agreed to let her information be checked with TransUnion but her identity could not be verified and she was told to go to a drive-through centre.’ Like Emma, she didn’t have a car. She commented, “I’m just going to stay in my house and take [cold and flu] medicine.”

The Health Services Journal gave other examples, and there have been other reports of problems on social media. Some felt that their recent house moves had been a factor in failing the verification checks. The Department of Health and Social Care declined to confirm to HSJ a percentage of how many people were unable to pass the identity verification.

Emma’s own situation got worse when her partner also came down with symptoms, this time more severe. He attempted to get a Home Testing Kit, but TransUnion was unable to verify his identity. Another person who couldn’t be verified, another test that couldn’t be delivered.

“At the end of the day,” Emma says, “I should have been allowed a test. I’m on the electoral roll, I have my bank accounts registered to this address. What else could they need?”

Who else is being excluded?

Relying on a credit agency to verify identity before delivering a Home Testing Kit disproportionately impacts people who are less likely to pass such checks - perhaps due to frequent house moves - or who are wary of them, perhaps due to having debts, working in the informal economy, not having a bank account, or having uncertain immigration status.

People within these groups include asylum seekers, refugees, travellers, sex workers, and people who may not have a stable address such as domestic abuse survivors. These groups are also likely to be more vulnerable to the virus due to health inequality, deprivation, and overcrowded accommodation.

The government’s response is to point people whose identity cannot be verified towards the drive through testing centres, telling openDemocracy: “if an individual is not able to verify their identity, they can still access in-person rapid COVID-19 testing at dozens of Regional Test Centres and Mobile Test Units across the country. The Government is committed to ensuring everyone who needs a test can get a test.”

But people in vulnerable or minority groups, including black people who are at higher risk of the virus, are less likely to have access to a car than white people. And people with uncertain immigration status may not have a legal right to drive at all.

As a result, some of the UK’s most vulnerable people risk being doubly excluded from a testing system that relies on a credit check agency to deliver: first because they cannot be identified, and second, because they cannot drive to a testing centre.

Some people may also be unwilling to share their data with TransUnion at all. A 2017 survey found most people don’t trust private companies with their data.

Again, this is a particular issue for people with uncertain immigration status, who may have had negative experiences with public services due to the government’s “hostile environment” policies.

Healthcare charity Doctors of the World explains how “fear and mistrust of health professionals, the NHS and the government caused by legislation that increases certain groups’ risk of criminalisation [...] are preventing people seeking advice on and healthcare for COVID-19.’

And a report published by the charity Women for Refugee Women found that ‘overwhelmingly’ the women seeking asylum they surveyed ‘with COVID-19 did not get tested, and women who tried were frequently told they needed a car to access drive-through testing.”

The government promised a “world-beating” test and trace system. But this is all happening in a context where the NHS test and trace system is still failing to reach thousands of people in the most affected, poorest areas of the country.

We don’t need a world-beating system, just a system that works – including for the poorest and most vulnerable.