National Horse Traceability Register for all horses
2 April 2019
Senate Standing Committees on Rural and Regional Affairs and Transport
PO Box 6100
Canberra ACT 2600
Submission to your Inquiry into the feasibility of a National Horse Traceability Register for all horses
I am writing to make a submission to your Inquiry as it is described on your website¹.
I write on behalf of a new company, equiprove, that has been set up to disrupt the equine industry in a way that is both positive and that could contribute to many of the outcomes that your Inquiry has been established to examine.
Our purpose here is not, of course, to persuade you that equiprove has the answers to any or all the questions that your inquiry is to address, though we think that we (and any similar technology solutions) have some insights to offer.
From the moment a breeder selects a stallion for a mare, provenance is in play across the life events of any resulting foal - from birth to death. Tracking and recording a horse’s provenance makes these life events traceable and transparent. Our service is designed to secure the provenance of a horse and make distributed information available to interested parties in line with clear use and access rules.
As such, equiprove supports the idea of a system, or a set of integrated systems, that facilitates the registration, tracking and reporting on horses. We believe, however, that there are better ways to achieve this than to build a centralised register and create a layer of government bureaucracy that may not be necessary. We also hold to the principle that people should own their own data: traditionally the typical approach of Governments is that people must surrender their data if they are to comply with legislation and regulation. The private sector is no different: to use Facebook, Google or Amazon, for example, we must give up our data.
However, alternative business, regulation and technology models exist that enable people to retain ownership of their data and license the Government with a right to use and access some of that data. This is aligned with Tim Berners-Lee’s ideas for the development of the Internet. Under such an approach, it would be the license to access data that would be the subject of regulation. Government does not need to own data, it needs to know that it can access the data it needs. Failure to permit to that data would be a regulatory breach rather than the failure to provide it.
We encourage you to engage with the technology sector and look to emerging software solutions as a way forward. The software industry is an essential part of the Australian economy. Its contribution to product and service innovation is significant. The Government has the opportunity, through policy direction in matters such as the subject of your inquiry, to encourage innovative solutions to be put forward rather than accepting a potentially problematic traditional remedy. We have already seen how embracing the software industry can work to national advantage. Two examples are Standard Business Reporting and Single Touch Payroll. Both these initiatives succeeded because the Government (in the shape of the ATO) included the software industry in the digitisation of the taxation system.
Perhaps I may comment more specifically on some of the terms of reference for your inquiry retrieved from your website.
1. the existence and adequacy of state or industry-based registers
Existing registers are generally either paper-based or are technologically unsophisticated databases (e.g. flat files, spreadsheets) that are difficult to access or search, and that cannot conveniently be used for reporting. Most importantly, they are not consistent or integrated across registers: the data held in one register may appear different to the data held in another and a particular data item may be represented differently across registers. The existence of these registers is probably not a good starting point for the construction of a national system;
2. the benefits of a national register, including for animal welfare, biosecurity safety (including for the prevention and management of Emergency Animal Diseases, such as equine influenza and African Horse Sickness), backyard breeding and the integrity of trade in horses
There is no doubt that the creation of a national register for the purposes that you outline would be a useful instrument. Our view, however, is that a traditional, centralised register might not be the most effective mechanism to achieve the outcomes that might be required.
One problem with regulation is that, once it exists, people will seek to avoid or evade it. Any regulatory system will demand compliance and compliance will attract those who wish to game the system. No approach will eliminate this although, of course, even though the proportion of people who will try to game the system will be small.
Our proposal is that through consultation with the software industry (probably via the offices of the Australian Business Software Industry Association (ABSIA)), the Government develops the standards necessary for the development of a distributed, virtual register and the mechanisms for licensing access to data.
Such an approach would be a world leader in Government regulation.
3. Overseas models of national tracking systems for horses
While we have reviewed overseas systems and plans (both private and public sector), we make no comments about our research in this submission.
4. Funding, enforcement and penalty implications
There are three aspects to this statement:
Funding: the approach that we propose means that the level of funding that the Government would need to outlay would be significantly less than that required for constructing a centrally managed system. Most of the money required for collecting the data would come from the private sector investing in provenance platforms and applications. Regulation and compliance are key activities and core competencies of Government: building systems and managing and owning data need not be.
Enforcement: our approach means that registration is essentially voluntary. Of course, this means that some people would not register their horse(s). But when someone came to sell a horse the cautious buyer would look for the provenance of the animal through a service such as equiprove. Clearly, those horses with limited provenance information will be less attractive or seen to carry greater risk than those with a full history. This approach is essentially leaning towards industry self-regulation, equally it could be an offence not to have registered your horse’s provenance with an approved provenance provider (but see the next sub-paragraph).
Penalty: there need be no penalty for failing to register a horse with a provenance system. The challenge with applying penalties is, of course, to apprehend a transgressor. This would be no easier, or indeed harder, under a centrally managed Government owned system than it would be using the approach we are proposing.
There are some other advantages with taking the approach that we propose:
The Government would be encouraging the development of new technology capabilities. Industry could be expected to look at improved mechanisms for identifying horses, such as iris recognition
The concepts behind animal provenance is not limited to the equine industry. It could equally be applied to any other domestic animal; that is, to any animal that is owned and traded. We know that systems that store the provenance of cattle are as technologically unsophisticated (and therefore, less secure and less tamper-proof) as those in the equine world.
Thank you for the opportunity to make this submission to your inquiry. Please let me know if there is any more information I can provide.
CEO and Co-Founder equiprove
0432 530 003