Accessibility
Building Inclusive Digital Trust and Identity Systems
March 19, 2026
#PrivacyInPracticeCA
Introduction: Inclusion as Shared Responsibility
Digital trust and identity systems should expand access to services, not create new barriers. When designed well, digital credentials can make identity verification faster, more convenient, and more accessible. When designed poorly, they can exclude vulnerable populations and widen existing inequalities.
The FPT Joint Resolution called for systems that are equitably accessible to all Canadians.[1] This principle is essential for system success. Digital trust and identity that excludes significant populations fails both the excluded and the system itself.
Inclusion is a shared responsibility. Governments must design public systems to be accessible. Industry must ensure products serve diverse users. Civil society must advocate for those who might be overlooked. Exclusion represents a form of harm that all stakeholders should work to address.
This article examines accessibility in Canadian digital trust and identity: who might be left behind, where inclusive design is working, and what genuine inclusion requires from all stakeholders.
Who Might Be Left Behind
Digital trust and identity create potential barriers for several populations. Some are unwilling to engage, due to trust deficits, past negative experiences, or perceived irrelevance. Many more are willing but unable to do so due to barriers related to devices, connectivity, accessibility, literacy, language, or identity verification. These barriers affect real Canadians who may find themselves unable to access services that increasingly assume digital capability.
Seniors
Older Canadians may have varying levels of comfort with smartphone applications. Not all seniors own smartphones; those who do may prefer simpler applications. Biometric interfaces can be less reliable for aging populations; research suggests that fingerprint readers may work less well on worn fingers, and facial recognition systems may struggle with age-related changes.[2]
The assumption that everyone can easily navigate digital applications overlooks significant portions of the population. Many seniors can and do use digital services successfully, but designing only for the digitally comfortable excludes those who are not.
Low-Income Canadians
Smartphones capable of running wallet applications cost money. Data plans and internet connectivity cost money. Low-income Canadians may lack the devices, data, or connectivity that digital trust and identity systems assume.
This barrier is not simply about device ownership. Even those with smartphones may have limited data plans that make downloading large applications prohibitive. Those with older devices may find that wallet applications do not run on their hardware. The digital divide intersects with the income divide.
Persons with Disabilities
Digital interfaces that are not designed for accessibility exclude persons with visual, motor, cognitive, or other disabilities. Screen readers must be able to navigate applications. Motor-impaired users must be able to complete verification without fine motor control. Cognitively diverse users must be able to understand interfaces and instructions.
Accessibility is not an edge case. It affects a substantial portion of the population. According to Statistics Canada’s 2022 Canadian Survey on Disability, 8 million Canadians (27% of the population aged 15 and over) have one or more disabilities that limit them in their daily activities.[3] Designing for accessibility means designing for a significant segment of users.
Rural and Remote Communities
Many digital trust and identity systems assume reliable internet connectivity. Rural and remote communities may lack the bandwidth or consistency that urban users take for granted. Systems that require real-time network connections may be unusable in areas with poor connectivity.
This challenge is particularly acute in northern communities and Indigenous territories, where connectivity infrastructure may be limited. Digital trust and identity that require connectivity exclude these communities from their benefits.
Indigenous Communities
Beyond connectivity challenges, Indigenous communities may face specific barriers related to documentation, naming conventions, and data governance. Many Indigenous people have had negative experiences with government identification systems. Digital trust and identity systems designed without Indigenous input may repeat historical harms.
Indigenous data sovereignty, the principle that Indigenous peoples should control data about their communities and members, must inform digital trust and identity design. The OCAP principles (Ownership, Control, Access, Possession) established by the First Nations Information Governance Centre provide a framework for respectful engagement.[4]
Where Inclusive Design Is Working
Canada has examples of inclusive digital trust and identity design that demonstrate accessibility and digital innovation can coexist.
BC Wallet’s Accessibility Commitment
BC Wallet is designed to be as simple and easy to use as possible, with accessibility features including screen reader compatibility, voice control, zoom and text enlargement, and support for multiple languages.[5] The design prioritizes clarity and simplicity over feature density. Users who struggle with complex interfaces can still complete basic verification tasks.
BC has also maintained non-digital alternatives. Digital wallet adoption is encouraged but not required. Citizens who prefer or require physical credentials can continue using them without penalty.
Quebec’s In-Person Infrastructure
Quebec maintains Espace SAAQclic helpdesks where staff assist citizens with account creation and access to digital services.[6] This human infrastructure demonstrates that digital transformation and in-person support can coexist.
The helpdesk model addresses multiple accessibility barriers simultaneously. Seniors uncertain about digital processes can receive guidance. Those without devices can access digital services through shared infrastructure. Those with disabilities can receive accommodations tailored to their needs. The human element fills gaps that technology alone cannot address.
Private Sector Multi-Channel Approaches
Some identity verification providers, including DIACC members, have developed solutions that support multiple authentication methods. Users can verify identity through document scan, knowledge-based verification, in-person confirmation, video-based verification, or other methods, depending on their capabilities and preferences.
This multi-channel approach recognizes that no single verification method works for everyone. Organizations that offer multiple pathways serve more users while maintaining security standards. Accessibility becomes a competitive advantage rather than a compliance burden.
Financial institutions that have reduced in-person services have sometimes faced questions about accessibility. Multi-channel approaches, where digital options complement rather than replace physical and phone-based access, tend to serve broader customer bases. This reflects both regulatory expectations and practical customer-service considerations.
Some identity verification providers have also developed assisted-verification options that allow customers who struggle with self-service to receive help from trained agents. These hybrid approaches combine digital efficiency with human flexibility, serving customers who fall between fully digital and entirely in-person preferences.
Indigenous Data Sovereignty
Indigenous data sovereignty requires particular attention in digital trust and identity contexts. The history of Indigenous peoples’ relationships with government identification systems includes residential schools, forced relocation, and loss of status, traumas directly connected to identity documentation.
OCAP Principles
The OCAP principles establish that First Nations have inherent rights over their data.[4] Ownership means the community collectively owns cultural knowledge and data. Control means the community controls all aspects of data management. Access means the community has access to data about itself. Possession means the community physically controls data.
Digital trust and identity systems that do not engage with these principles risk perpetuating colonial approaches to Indigenous identity. Systems designed without Indigenous input may impose inappropriate identity frameworks, collect data without appropriate consent, or fail to recognize Indigenous governance structures.
Meaningful Engagement
Genuine engagement with Indigenous communities requires partnership. Indigenous peoples should be involved in design decisions, not merely asked to react to finished designs. Their perspectives must shape fundamental architecture, not just surface features.
This engagement takes time and resources. It cannot be rushed or treated as a checkbox. Organizations genuinely committed to inclusion should invest in building relationships with Indigenous communities before finalizing design decisions. DIACC recognizes the importance of these principles and encourages all participants in the digital trust and identity ecosystem to engage meaningfully with Indigenous communities and governance structures.
What Genuine Inclusion Requires
Inclusive digital trust and identity requires deliberate effort from all stakeholders. Inclusion must be designed, funded, and maintained.
Multiple Pathways
Inclusion requires multiple ways to access services. Paper alternatives for those who cannot use digital credentials. In-person options for those who need human assistance, phone-based verification for those without smartphones. No single pathway serves everyone; multiple pathways are necessary.
Device-Agnostic Design
Systems should work on older devices and browsers, not just the latest hardware. Applications should minimize data usage for users with limited data plans. Verification should be possible on basic smartphones, not just flagship models.
Accessibility Standards
WCAG 2.1 AA compliance should be the floor, not the ceiling. Applications should be tested with screen readers, voice control, and other assistive technologies. Users with disabilities should be involved in testing, not just accessibility consultants. Compliance attestation alone is insufficient; service providers should be expected to demonstrate that people with disabilities can complete the most common and important tasks using assistive technologies. Published video demonstrations of real users completing real tasks provide accountability that audit reports cannot. Governments can reinforce this expectation through procurement requirements.
Digital Literacy Support
Technology without education creates barriers. Digital trust and identity deployment should include digital literacy programs that help people understand and use new systems. These programs should be designed for diverse learning styles and available in multiple languages.
Non-Digital Maintenance
Digital transformation should not mean eliminating the non-digital. In-person services, paper documents, and phone support should remain available. Investment in digital channels should not come at the expense of non-digital alternatives.
The Vision: Digital Trust and Identity That Serves Everyone
The goal is digital trust and identity that expands access rather than restricting it, systems that make services more accessible to everyone, including those who face barriers under current approaches.
This vision is achievable. It requires deliberate design, sustained investment, and ongoing attention. It requires recognizing that exclusion is not an acceptable cost of digital progress. It requires measuring success by whether people can actually complete the task they came to complete, and not just whether they reached the front door of a digital service, but whether they got through it.
Inclusive design often proves to be a better design for everyone. Features developed for accessibility (clear interfaces, multiple pathways, robust error handling) improve the experience for all users. Curb cuts designed for wheelchair users help parents with strollers and travellers with luggage. Closed captions designed for deaf users help those watching in noisy environments. The investment in inclusion pays dividends beyond the populations it directly serves.
DIACC shares this vision and believes that digital trust and identity should serve all Canadians, not just those already well served by digital systems. We encourage our members and partners to prioritize inclusive design as a shared goal.
Next Week
Article 9 examines Who Watches the Watchers? Strengthening Accountability Together
The value and limits of self-regulation and why industry should support independent oversight.
Footnotes
[1] Federal, Provincial and Territorial Privacy Commissioners and Ombuds with Responsibility for Privacy, Joint Resolution on Digital Identity, September 20-21, 2022, St. John’s, Newfoundland and Labrador. The resolution states: “Digital identity systems should provide options and alternatives to ensure fair and equitable access to government services for all.”
[2] Office of the Privacy Commissioner of Canada, Guidance for Processing Biometrics, August 11, 2025. The OPC’s guidance notes that biometric systems may have uneven effects on certain individuals or groups and that privacy risks for particular groups should be noted in privacy impact assessments, along with strategies for mitigating those risks. https://www.priv.gc.ca/en/privacy-topics/health-genetic-and-other-body-information/biometrics/gd_bio_org-final/
[3] Statistics Canada, Canadian Survey on Disability, 2017 to 2022, The Daily, December 1, 2023. The report states: “27% of Canadians aged 15 years and older, or 8.0 million people, had one or more disabilities that limited them in their daily activities. The rate of disability in Canada has increased by 5 percentage points since 2017, when 22% of Canadians, or 6.2 million people, had one or more disabilities.”
[4] First Nations Information Governance Centre, The First Nations Principles of OCAP. OCAP stands for Ownership, Control, Access, and Possession, principles established in 1998 to support First Nations data sovereignty. The FNIGC states that ownership “refers to the relationship of First Nations to their cultural knowledge, data, and information.”
[5] Province of British Columbia, BC Wallet. The website states: “BC Wallet is committed to ensuring that everyone is able to use the app with a smartphone or tablet. It is designed to be as simple and easy to use as possible.” Accessibility features include screen reader compatibility, voice control, zoom and enlarged text, and support for multiple languages.
[6] Société de l’assurance automobile du Québec, Espace SAAQclic helpdesks. The SAAQ created Espace SAAQclic help desks at its service centres to assist people who need help using SAAQclic online services, including those who have trouble creating an account.
The Privacy Scorecard
A practical tool for measuring digital identity services against the FPT privacy principles. Assess your organization’s implementation across architecture, policy, user experience, and ecosystem coverage. It is not a compliance checklist or legal advice. Use it to spark conversation, explore unfamiliar concepts, and identify areas worth digging into further.