The DTO is hiring - and not in the traditional complex and clumsy public service way

Australia's Digital Transition Office (DTO) has finally lifted the covers on the personnel it's seeking to hire to fulfil its ambitious transformation agenda.

However, unlike traditional APS hiring, the DTO's positions vacant use modern corporate job titles and each job description clearly and in detail explains what applicants will be expected to do in the role.

There's no mention of APS level and no need for applicants to write a selection criteria essay based on standard public service capabilities and values.

In fact the DTO job descriptions look like a good example of how good modern companies recruit.

Hopefully as a result of this approach the DTO will attract a range of highly skilled people from across the private sector, people who normally would not apply to a government job due to the difficulty in doing so.

So if you're interested in working in an area where there's the potential to make enormous change and where you can understand from the job description what the role will involve - check out the DTO's positions vacant at www.dto.gov.au

It's not only government agencies who can survey their clients

There's an interest case emerging where an Australian Defense Force veteran has surveyed a large number of clients of the Department of Veterans' Affairs and identified a very different view of the department to that claimed in its own survey.

Before idespread internet and social media use, surveying a large number of agency clients or citizens on their views of an agency's performance was an expensive, difficult and time consuming undertaking.

I recall conducting surveys in the early 1990s before the World Wide Web, on behalf of large fast moving goods manufacturers, to establish customer views of their products. It was a slow, expensive and complex process that required significant casual manpower making thousands of phone calls to get a reasonable sample size of responses.

First it required contact details for each client - something that generally only the agency itself held centrally, and this wasn't shared for privacy reasons.

Beyond this, the process of designing and putting a survey into the field was an expensive undertaking, requiring specialised researcher and either a mass mailout (with a paper survey and reply paid envelope) or the employment of large numbers of casual phone researchers to physically call all the potential respondents to seek their feedback.

Finally, the analysis of surveys was a complex matter, with data needing to be accurately input into relatively primitive analysis tools. I recall using SPSS in one of its earliest incarnations. It was powerful but very finicky and operators had to essentially write raw, command line, database calls in order to segment research data in useful ways.

Today this process has entirely changed, making it far easier and cheaper to survey large number of people and rapidly analyze and report on their views.

As a result it isn't only large organisations who can now effectively qualify and survey significant numbers of people - individuals who mistrust organizational survey results can do so too, potentially challenging the results that organisations claim by identifying issues that organisations would prefer to keep on the lowdown.

We saw this kind of citizen action with the Vodafail survey and report back in 2012, where an individual who was upset with evasive corporate claims and a lack of service improvement, marshaled 50,000 reports of issues with the Vodafone national mobile phone network through his social media connections and providing a damning analysis of the situation to government authorities.

The actions saw Vodafone widely scrutinised by the public and authorities and the company was forced to change its behaviour (and leadership) to address the concerns, losing almost half a million customers while this took place.

Tellingly the company has survived, even thrived, as a result of changing its engagement approaches, but was referring publicly to its efforts to lay the issue to bed as recently as a few months ago, vowing at the end of March 2015 to 'reverse Vodafail' and become Australia's best mobile provider.

Back then I doubt many government agencies were worried that a similar event could occur to them - that an individual or unaligned group could, or would, conduct research on an agency's clients and publicly release an independent view that contradicted the agency's own research on its service standards and how the agency was perceived by those it served.

I did flag the potential issue in this blog back in June 2013, highlighting that we now live in an age where an individual can 'pierc the veil of silence' and expose an agency to criticism and scrutiny in ways it had never faced before.

Now this has happened for real, with an individual conducting a survey about the Department of Veterans' (DVA) conduct that provides a very uncomfortable view of military veterans' experiences with the department - a view that contradicts the extremely high satisfaction rates that the department itself claims in its research.

The individual, Angus Sim. a veteran of Iraq and East Timor, had had a rough personal experience with the DVA. So when the department released a glowing and entirely positive report on how clients felt when dealing with the DVA, and refused to release any negative comments at all about the department,  he felt that the DVA's own research was not providing a true view of how veterans really felt, and was potentially misleading both the public and the elected government.

So using the Web 2.0 tools at his disposal, Angus set up a survey for veterans using SurveyMonkey, and a Facebook group where vets could connect. He also created a Change.org petition to marshall support and filmed a short video for YouTube to communicate the issue he was attempting to address.

Angus hen marshaled support through his networks online, getting the survey featured on several websites, such as ADSO, and in a number of social media groups frequented by Aussie veterans.

He even reached out to the politician seen as most supportive of veteran affairs, and had Jacquie Lambie tweet a link.

As a result Angus has attracted over 900 responses to his survey thus far, and has already conducted preliminary analysis that suggests that there are many veterans who do not feel as positive about the DVA as the department's own research suggests.

The survey analysis is now starting to filter into the media - which means it is likely to attract even more participation from veterans.

Representative or not, this survey will impact on the trust placed in the DVA to report accurate sentiment to its political masters and the public. It could damage the ability of the DVA to carry out its job and dent or even end the careers of public servants, as the Vodafail report did for Vodafone management.

The DVA research that found 90% satisfaction levels and for which the DVA only published positive comments from respondents, cost over $170,000 to conduct.

Other than his time, Angus would not have spent a cent on his citizen-led research, using free online tools to build his network, collect responses and analyst the results.

Keep in mind that Angus did not take these steps because he wishes to damage or destroy the DVA. He took them because his experience cr did not match the DVA's published perspective on the experience of veterans. He wants the DVA to see and acknowledge its failings, to advocate to government for the resources to do right by Australian veterans and to deliver better outcomes for their clients.

More often than not when citizens come out in opposition to agencies they are simply seeking a fair go, not to ridicule or damage the reputations of agencies, governments and senior officials.

Agencies need to take this as constructive criticism, not as an attack on their existence. Ignoring, downplaying or rejecting criticism will only result in an escalation and actual damage to agencies, where as working constructively with individuals and groups fostering public accountability can result in improved outcome and satisfaction.

This is no longer a theoretical situation for government agencies, that an individual or small group could run 'counter research' where they perceive government research to be implausible or absent.

Every agency and council needs to be mindful that, at any time, their constituents, clients and stakeholders could organise and present a dissenting view which doesn't reflect the view the organisations itself wishes to project.

Public agencies are on notice - citizens are organised, watchful and they want to help, whether the agencies want their help or not.

Dinosaurs are rarely good fashion designers

Euan Semple has a great post over on LinkedIn about the challenges in giving the people responsible for maintaining the status quo in organisations and institutions the responsibility for generating and embedding radical change in the same institutions and organisations.

I see this too. The people best qualified to maintain stability in institutions are rarely the best people to institute and embed meaningless change - and likewise the people best at instituting change are often not the ones needed to run the reformed organisation after change is embedded.

That's why we see change CEOs established in corporations in various forms - and even there they often fail due to the many unintended and unpredictable consequences of a major change.

I am increasingly of the view that replication is the key to true change - a lesson that a billion years of evolution has taught us. The 'only one of its kind' approach allows no fallback if a particular evolutionary change process results, unintentionally, in a deadend, non-viable solution.

This is the reverse of how most organizations think, but as we see time and time again the markets with more competition are more successful, those that concentrate down to a few players tend to need more external regulation to continue to serve their customers adequately.

For government in particular this is a challenge - it is the ultimate in geographic monopoly, and places barriers on free movement that restrict the ability for citizens to shop around (the highest barriers at national levels).

While our societies may never support the notion of totally free choice in government (which is possible for all but the most geographically restricted services), we can move government to the backroom, an infrastructure platform rather than a service provider.

Then government services can be offered and bundled competitively with private sector services by a variety of providers, creating that competition for outcomes that a single government will never be as good at achieving.

Digital Transition Office to make creating APIs mandatory for federal agencies

Last week the Digital Transition Office (DTO) released a draft of its API Design Guide for public review.

An API, or Application Programming Interface, is an approach that defines consistent methods of inputting and outputting data into a software system based on internet protocols. APIs are regularly used by Web 2.0 services as a standard way to connect to each other, share information and support seamless integrated functions (such as connecting your mailing list service with your survey tool).

The government already has a few APIs, generally around the edge of its services and functions - such as for the National Library's Trove service and the Pharmaceuticals Benefit Scheme.

However what is suggested in the DTO's post is that the DTO is looking to make it mandatory for government agencies to create APIs for all new services, and to consume their own APIs when delivering those services.

To people who know little about IT this might be a 'so what' moment. However if you think about the impact of this shift on how governments design services, who delivers them and how they are integrated with other services across agencies, this is a very big deal indeed.

AGIMO (Australian Government Information Management Office), as the former body established to guide federal technology use, always suffered from not having the ability to mandate certain techniques and approaches. It could cajole, suggest, recommend and advise agencies on good technology paths, and its position within Finance gave it a few teeth, however AGIMO never had the capability to mandate or enforce technology standards without the goodwill of every other major department's CIO.

So for the DTO to have a mandate in this area means it can design and enforce the practice, providing more standardisation across agencies and opening the door to knowledge and expertise sharing within government and certainty on how to engage agencies from outside.

One of the potential outcomes of making APIs mandatory is that 3rd parties outside of government will be able to deliver any new government service, mash together services from different agencies into new service approaches, or even combine government and private services into a single unified offering.

Anyone with a website and a little expertise could become a front-end for people seeking to access government services or information.

Equally, government agencies (whether local, state or federal) could connect federal services to their own, likewise potentially in a seamless way.

Theoretically there could be a single system across government for changing your address, or you could register a company, your ABN, for GST and for a state license for your business in the same transaction.

The DTO's draft design also says that agencies will have to consume their own APIs ('eat their own dogfood') when delivering their services.

This means agencies will have to build robust and effective APIs to support their service requirements, rather than build them as an afterthought (a very good thing) and it support the development of usable interfaces that aren't limited by a particular IT back-end approach.

Of course all of this relies on how well the mandate is executed - which leaves Paul Shetler's team with some challenges.

First they have to build recognition within government, as a mandate, agency CIOs can no longer go their own way, they need to work together with the DTO to establish appropriate standards that suit agency deliverables and services.

Secondly they will have to address any skills gaps. Few agencies have experience developing APIs - particularly where there's complex services that require them, or there's need for secure APIs.

Finally they'll have to keep all the cats herded. Ministers have a tendency to ask for things at short notice - such as new services or changes to existing ones. When agencies face these requests they often are limited in time, money and the skills to achieve them. Developing APIs will hardly be on the top of their priority list, they will be hardpressed just to get a service in place in time to meet the Minister's announcement deadline.

However despite all these challenges, the cause is a great one and could do more to transform how government IT operates than many more public steps.

If the DTO can pull this off, have agencies fall in line and have APIs start rolling off government IT 'production lines', it will have single-handedly justified its own existence and transformed how government works, even if it doesn't achieve anything else in the next few years.

Government digital service designers need to start thinking with their stomachs

Traditionally governments have taken cues from banks and social networks for innovative ways to design online services to make them easier to use.

However it may be time for public servants to think about online service design with their stomachs.

I don't know how many public sector digital design professionals have visited McDonalds lately, but the new 'Create your taste' service provides an interesting approach to digital design.

Using relatively new touchscreens deployed in a number of stores, the interface used for building hamburgers employ a number of innovative navigational and selection approaches to create a usable and enjoyable experience.

I've taken several colleagues in and bought them a meal just to watch how they learn the interface and interact with the menu while designing their perfect meal.

None have needed any support to get started, with the menu providing a simple and intuitive way to progressively select ingredients.

All have found the experience a pleasant one - to the extent where one colleague recently went into a McDonalds seeking a 'create your taste' experience, but left when it didn't have a touchscreen.

Sure the McDonalds experience is just about designing a meal (although designing salad could be considered 'rocket' science), but the lessons around ease of use and delivering both a usable and enjoyable experience are consistent across all kinds of service delivery.

Yes many government services may be complex, but that doesn't justify delivering a complex user experience. It simply means that more work is required to break down the process into easy steps, drop any unnecessary questions and make it clear upfront what people need in order to complete the process in one go.

If government can make online services appealing and remove the need for people to switch channels to complete a process, there's the potential for vast cost savings in face-to-face and phone transactions, plus the potential to reduce error rates.

Of course, the McDonalds example isn't the only one government service designers should be considering.

Dominos has taken a very interesting approach to real-time pizza tracking, from being made, through cooking and delivery to the customer's door. The example, highlighted by The Mandarin, is already being taken on board by the federal Department of Human Services, which hopes to make more Centrelink services just as simple to access and just as clear to their clients.

So if you're designing digital services for government, you may wish to take a long lunch or two to check out some of the digital service design being pioneered across different food establishments.

Is it your job to create or reduce friction?

One of the big distinctions I've noted between working in the public and private sector is in the level of friction when attempting to get things done.

I define friction as the amount of red tape, process, procedure and protocols that slows down the achievement of a defined goal.

The more red tape, the more friction, and generally the longer it takes to get things done.

Some roles in organisations are defined around friction - such as a procurement team, lawyers and accountants. All exist to create or reduce the level of friction in achieving a specific goal.

Other roles can influence the level of friction around a given decision or topic - from senior management through to communication and IT teams.

Now friction isn't necessarily bad. By slowing down decisions, friction can mean more viewpoints are considered and fatal errors do not occur. In fact many of the checks and balances in government are there to prevent decisions being taken too quickly or unilaterally.

However reducing friction also has benefits. The faster an outcome can be achieved, the more likely it will be relevant. Fast decisions also mean fast learning decisions - 'failing fast' - and iterative improvement towards a desired state.

Balancing the level of friction required for good decisions and outcomes is the real challenge. How much or little friction is good?

This obviously depends on the outcome desired, the level of scrutiny required around a decision and who is affected as a result.

However, generally, the aim should be to have as little friction as possible within the overall constraints of the goal.

So what about your role in the public sector, is it to create or reduce friction - and do you create or reduce friction for others?

If your focus is on increasing friction, consider whether this actually advantages your organisation and its goals. Sometimes people simply create friction out of fear, rather than in the best interests of an organisation's goals.

If your focus is on reducing friction, consider whether some friction needs to be preserved for good decision-making. Also think about how your colleagues may feel as it gets faster and easier to achieve certain outcomes - many will welcome this, but a few will be concerned about a loss of control, fear greater failure or scrutiny.

When you work with others think about whether you are creating or reducing friction - and whether you're taking the appropriate stance for a situation.

Friction isn't necessarily bad, but the least friction possible is almost always good.

Why not include ordinary citizens on the MP remuneration review panel?

Australia's Prime Minister, Tony Abbott, has now announced the review panel for MP remuneration expenses, and in my view it's close to becoming another missed opportunity to improve government engagement, accountability and transparency with the community.

The panel will consist of five 'eminent' individuals. Two will be former politicians (one Labor and one Liberal), one a business person and two will be former senior public servants (David Tune, former Secretary of the Department of Finance, and John Conde, Head of the Remuneration Tribunal).

In other words, the usual suspects - members of the major political parties (who are most under the shadow of the expenses issues), a friendly CEO or senior business advisor (who knows what side his - and it will be a him - bread is buttered on) and two public sector insiders who have worked closely with current and former politicians.

On the five person panel, there's apparently no room for ordinary citizens, the involvement of a citizen's panel or anyone unconnected to politicians who is actually concerned or enraged by the way MPs are using their entitlements or is concerned about the falling legitimacy and credibility of our political system.

Of course such participants would likely be more 'unruly'. They'd not be members of the cozy Canberra club which decides what is good for citizens (often based on mistaken, shallow or lobbyist influenced impressions of public sentiment). They'd not understand the rules of the game, the way in which things MUST be done in order to satisfy the egos and perceptions of those on the top of the political pile.

Participants from outside the Canberra insider club may not even share the group think of what is appropriate for politicians to spend, and could even disagree with the 'eminent' appointees on what is appropriate expenditure by politicians.

Of course the Prime Minister's hand-picked 'eminent' panel will be thorough and comprehensive in its review. It will consult citizens - allowing people to provide their views. And then it will weigh those views and provide its recommendations, based on their own filters, future career ambitions, relationships and experiences of being within the 'club'.

The upside of this insider approach is that the review will be less harsh on politicians, that the 'eminent' insiders understand the needs of politics and provide limited restrictions on politician entitlements, allowing politicians more freedom to rely on the public purse rather than personal or party finances.

The risk for politicians is that the public don't feel the review recommendations go far enough, that traditional media and social media continue to pursue senior politicians for their expenditure, that citizens don't feel they have been appropriately included in the process. The outcome of this would be further erosion of trust in both Australia's political system and in our public sector.

This risk could be partially or wholly mitigated through including ordinary citizens as part of the eminent panel, or creating a citizen's panel to oversee and support or reject the eminent panel's review.

Citizens could be selected through nomination or random selection from the electoral role - our court jury model is one approach that could be used. This group should, of course, be paid for their time and not expected to donate it for free - Iceland's Constitutional process, where they paid citizens their travel expenses and the salary of an MP for the days they worked is a good model to emulate to reflect the value of citizen involvement and the cost of their lost time.

In this approach, citizens would decide whether the review went far enough, not political insiders who may stand to gain from lighter recommendations.

There's a risk for politicians in taking this approach. They may end up with tighter restrictions on entitlements. It could be uncomfortable for parties struggling to raise the funds they need to operate, or costly for politicians' own finances.

However it would be far more likely to meet public expectations, to help rebuild credibility in political parties and allow politicians more certainty that something they spend won't haunt them in years to come. It could even provide a huge boost to the Coalition's re-election chances by demonstrating how the current government was genuine about listening to citizens and governing for all Australians.

There's still time for the Prime Minister to shape the form of the remuneration review, to take a bold step to respect citizens and embed greater accountability and transparency in the review process.

It's not a missed opportunity yet, but if it becomes one, the consequences could further damage Australia's democratic credibility and institutions.

Governments are still very backwards in most of their online engagement - and it's not due to a shortage of tools

I've been reading about a new entrant in the government online consultation market - Balancing Act, a simulation tool for involving the public in government budget consultations.

It joins a range of other tools for this type of 'trade-off' consulting online - including Budget Allocator from Bang The Table and, my favourite, Budget Simulator from Delib (which I used to run in Australia).

These are only a few of the advanced online consultation tools available for government - of which there are many kinds, from surveys and geospatial mapping through to forums and blogs.

Many vendors have years of experience, having run thousands of consultations with hundreds of clients internationally (particularly Delib and Bang The Table).

However most governments are still very backwards and inconsistent in their online engagement - with many consultations still just having an email 'black box' for submissions, or employing expensive market research firms to do work that can be done by specialist public sector online consulting companies for a fraction of the cost.

I've seen agencies charged tens of thousands for basic SurveyMonkey surveys, or mistakenly use forums to capture a few dozen comments for quantitative consultations that would receive far more and higher quality responses and outcomes using specialist budget or survey tools.

I've had agencies so 'no thanks, we'll build rather than buy' when presented with tools that have been used by hundreds of agencies over many years, and have had millions invested in their development and refinement to make them work well - and seen the outcomes where they invested tens or hundreds of thousands (far more than the cost of buying in the capability) and ended up with a consultation system that didn't do what they needed it to do.

Even today most local councils and governments, when they engage online, buy or build a capability just for a specific consultation, then 'throw it away' afterwards - only to reinvest the next time they need to consult.

And that's in an environment where agencies know that they'll be consulting stakeholders or the community tens of times throughout a year.

So why do government agencies not take a pragmatic and sensible approach to consultation, invest in sound capability and use it repeatedly across all appropriate engagements, providing a consistent and managed experience at a very low amortised cost?

After years of running consultations and leading Delib Australia, I've come to the following conclusion.

I believe that fundamentally agencies and councils don't think of consultation as a critical step in policy and service design.

Instead consultation is usually either a 'sop' to their Minister, or to affected groups in the community, to provide necessary cover for whatever decisions they choose to make.

In my experience, while policy specialists and senior public servants are always interested in reviewing the synopsis of what consultation respondents say, they often suffer from the 'expert issue', where they already know the right solution, and simply don't believe that the public would have anything useful to add.

This bias is often reinforced during consultations. Due to the ways in which agencies consult it's common for many responses to be brief and poorly considered, or reflect ideas an agency has already investigated and rejected, or tried.

When experts, interest groups, companies and lobbyists respond to consultations, their responses are given a little more attention - partly because they are written formally in language that public servants respond to, and partially because they may be groups that can derail a government's goals.

However even these responses are often largely disregarded as the bias or slant of a particular group seeking advantage. Or they may be =taken as gospel - a mandated approach that already has the support of the group purported to be represented (even where this may not be evidentially the case).

Of course there are exceptions to the cases above and I've been fortunate enough to work with a number of agencies, councils and individuals who truly value and respect community input and understand how it can effectively inform and improve policy and service outcomes.

However until governments think more like start-ups, recognising the immense value that consultations have in uncovering policy issues and new ideas as a critical part of a design process, I expect we'll continue to see the poor use of online consultation tools even though many of the tools available today are superbly well-developed and tested.

Agencies and councils don't need to wait for or design better tools - they need to improve their thinking, or consultation will continue to be a weakness and a risk for them and their political masters.

The Australian Government's entitlements issue is an opportunity for a Gov 2.0 solution

Practically everyone in Australia has followed the entitlements issue triggered by media reports of House of Representatives Speaker, and Liberal politician, Bronwyn Bishop's helicopter trip from Melbourne to Geelong over the last three weeks.

While at times other politicians were reluctant to criticise Bishop's expenses, on the basis that most politicians spend quite a bit of money in meeting the requirements of their positions, the public and media was almost universally negative towards the rolling revelations of expenses that seemed either not in the public interest, or more expansive than necessary in her role.

Now that Bishop has resigned her position as Speaker, with a decade of her expenditures being reviewed by the Department of Finance, and the Prime Minister has announced a new review of parliamentary expenditures and entitlements, including those of senior public servants, it's a good time to look at how digital technology could help Parliament and politicians to regain and build public trust as well as explain how and why politicians spend money in carrying out their duties.

There's a real opportunity to make it easier for politicians to submit expenses, improve the speed at which they're made public, and provide a mechanism for explaining the value of their legitimate expenditures, while making it much harder for inappropriate use of entitlements.

It's hard to believe, in today's world of electronic banking, myTax, myGov and online accounting platforms like Xero, that parliamentarians still have to, by and large, manually collect their receipts and invoices and physically complete paper forms to claim and verify their legitimate expenditures.

The technology to digitally photograph and submit expenses directly into an online system is widely available, as is the capability to digitally verify that all expenditures are accurate and appropriate.

It is also easy to then make these expenditures visible to whoever needs to see them, and to conduct various forms of analysis and reporting (both automated and manual) to identify and query exceptions (such as extremely high cost taxi fares) and, of course, to repay any out-of-pocket work expenses that a politician may have incurred.

While off-the-shelf tools are not really designed for the type of visibility expected of politicians, it wouldn't be too hard to develop a digital system for capturing, querying, reporting and paying these expenses, with the ability for the public and the media to view, in near-real time, all expenses incurred by parliamentarians in their day-to-day roles.

It wouldn't be much harder to allow expenses to be analysed and compared, as the media is already doing in articles like this, to understand the relative spending by MPs and, over time, by Ministers in the same or similar portfolios. This would provide for better comparisons and consideration over time.

What would be truly visionary would be to build in mechanisms for the public to flag certain expenditures and request an explanation, allowing politicians (and their teams) to explain what they are doing and why - improving the democratic compact between politicians and their constituents. This could be based on a minimum threshold of 'please explain' requests and require all requesters to be registered in the system to minimise the risk of nuisance enquiries.

On top of this, the system could provide information on entire itineraries and politicians and their teams could include information on the outcomes of their expenditures. For example an overseas study trip that resulted in a report to parliament and a change in legislation could have these outcomes and outputs linked to the expenditure, helping to verify how valuable it was.

Some might see the above type of approach invasive, taking the view that, once elected, a politician should simply be trusted to do the right thing.

While I can sympathise with this perspective, the reality is that it hasn't been shown to be effective in the real world. Some elected politicians have been shown to misuse or misunderstand their entitlements, and the damage this does to the integrity of the parliament is extreme.

Trust in politicians is low - not just because of questions over their expenditures, but also because of broken promises, failed programs and continual infighting.

Redeeming the reputation of parliament can't be achieved simply by expecting the public to let bygones be bygones and start trusting politicians again, it must be won through positive examples and actions - as Malcolm Turnbull demonstrated in his tram and train trip from Melbourne to Geelong.

Creating a digital parliamentary expenditures system with full near-real time transparency would be a strong visible sign that politicians are committed to serving Australia, not to their own enrichment.

It would also help dispel misunderstandings about how and why politicians spend money and improve the understanding of how expensive it can be to be a politician - particularly one with a large electorate or significant travel requirements.

Of course there's still the need to review the entitlements system itself - or at least adopt the recommendations from the last review of entitlements, however with some shrewd application of Gov 2.0 thinking and digital tools, Australians could be confident in how their politicians behave, not simply confident in the rules that they are expected to follow.