TECH4GOOD
Monchito Ibrahim
I applaud the recent release of the guidelines on the provision of the mandatory statutory benefits and privileges for senior citizens and persons with disabilities on their purchases using online, mobile, or messaging apps. Online platforms may have provided a way for everyone to live through the lockdowns, but it was obvious that the application of the mandatory discounts for the affected beneficiaries was hardly being followed.
The guidelines are covered under Joint Memorandum Circular (JMC) 01 series of 2022 signed by the Department of Social Welfare and Development, the Department of Trade and Industry, the Department of Interior and Local Government, the National Commission of Senior Citizens, Bureau of Internal Revenue, National Council for Disability Affairs, and the Department of Health. It is about time that the government ensures that these benefits and privileges are also applied to online purchases.
JMC-01 provides information and guidance to enable related e-commerce and m-commerce players to strictly comply with existing policies and guidelines, particularly on the grant of discounts to senior citizens and persons with disabilities as mandated by law. This means that discounts usually extended to concerned beneficiaries in face-to-face transactions should be applied as well to the purchase of covered goods and services by digital means for the most part using the internet. This ensures that all these benefits and privileges can now be universally applied to both offline and online transactions.
Taking a close look at how the JMC-01 is currently worded, however, we see some areas that need to be re-examined to make sure it is properly implemented. We all know that new opportunities offered by access to products and services through all non-face-to-face means like the internet, phone, and other mobile devices bring with it associated challenges that would require mutually acceptable solutions to all parties involved. Such challenges may involve significant adjustments to the online platform systems, privacy risks, fraud prevention, and ensuring that independent service contractors such as riders and delivery people are not overburdened with additional tasks.
For example, in order to minimize the risk of fraudulent transactions, there is a need to verify the veracity of IDs that need to be presented in order to avail of the discounts, both at the initiation and fulfillment of the purchase transaction. The merchants, platforms, and most especially the riders do not have the ability to authenticate the IDs presented. Nor are they able to determine if the goods and services are for the exclusive use of the discount beneficiaries. Who will shoulder the costs incurred, like the services of riders, when the IDs presented are found to be fake at the point of delivery? Remember, these riders are paid only if the delivery is fulfilled. Pre-registration of SC/PWD buyers and having them go through the kind of Know-Your-Customer process practiced by e-wallets could be one way to minimize fraudulent transactions.
I also see possible privacy issues arising from the fact that, in practice, riders would usually take pictures of the IDs presented during the delivery. There is also the need to properly inform the buyer that their personal information will be used at the time of order as well as delivery, and when these will be deleted from their system and from the riders’ device. I also recommend that all data privacy complaints be funneled to the National Privacy Commission.
A major challenge I see is the ability of the merchants and the platforms to determine whether the buyer has exceeded the monthly ceiling for eligible purchases of basic necessities and prime commodities. This may be difficult to do considering it would involve consolidation of online and offline purchases. It would also be cumbersome for online merchants to monitor because they do not have access to purchases from other merchants even considering the fact that the buyer is required to send a copy of the first and last pages of their purchase booklet.
I am sure most of these issues can be addressed by the platforms by reworking their systems and processes. As an IT person myself, I foresee, however, that it will be a major overhaul. It will also involve coordination with their merchants and re-educating service contractors. I do not see the prescribed 30-day transitory period for compliance being realistic at all.
I strongly recommend that the players be given a much longer runway to make the necessary adjustments to comply with the guidelines. It may also involve doing a proof of concept to test drive the adjusted systems and processes. What about prescribing QR-enabled SC/PWD IDs and virtual purchase booklets? Referring to online platforms may also be very limiting. Why not just say “online transactions using the internet”?
Most e-commerce players today are built on business models that are much different from the typical businesses we used to know. Regulating them may have to be done differently. Treating them in the same way as any brick-and-mortar establishment may hinder further innovations to happen in the sector.
(The author is the lead convenor of the Alliance for Technology Innovators for the Nation (ATIN), vice president of the Analytics Association of the Philippines, and vice president, UP System Information Technology Foundation.)