To: CBDC@HMTreasury.gov.uk

Subject line: Response to the consultation on a UK digital pound

I am a [member of the public/profession] writing to respond to the Bank of England and HM Treasury’s joint consultation on the development of a UK digital pound. The proposal outlines a new way for members of the public and businesses to make payments. Privacy, security, and autonomy are crucial to the way in which I spend money, so it is important that any digital pound is privacy-preserving and optional. As such, I believe that:

The Government have not demonstrated why we need a Central Bank Digital Currency in the UK. I do not understand why the Government is pursuing the introduction of a CBDC and do not think the case has been made to justify its creation. These plans would fundamentally change British society and come with a number of risks. Yet it is unclear for what purpose the Government is pursuing this policy and unclear whether it would be of real benefit to the Great British public.

The proposal for a new UK CBDC does not preserve my privacy and is not fit for purpose. The current proposals would mean that every transaction I make will be recorded and that anyone with access to the records – from public authority to hacker – could potentially see this information. I am incredibly concerned that the proposal permits third party providers to exploit my data for marketing purposes without my consent. CBDC systems and records would also offer hostile actors a massive platform to focus cyber attacks on. Any successful breach would put myself, and others, at risk. The new opportunities for surveillance from such a wide variety of actors is incredibly concerning.

Any future proposals for a digital pound should reject programmability functions. Neither the government nor third party providers should have control over how I spend my money. Financial programmability is an invasion of my privacy and could breach my human rights, such as freedom of expression, assembly, and protection from discrimination.

CBDCs risk exacerbating financial inclusion, not promoting it. Despite the consultation’s suggested aim to increase financial inclusion, I am not convinced that a UK CBDC is the appropriate method for doing so. The consultation sits against the backdrop of the increasing digitalisation of society and general decline in cash use. Introducing a new digital pound could push the UK further towards a cashless society, which would exacerbate financial exclusion for many who do not want or cannot use a CBDC. A digital pound would be spent through a smartphone, which would exclude people already impacted by the digital divide even further (e.g. people who cannot afford a smartphone, elderly people who do not own or cannot operate one, or people living in remote locations with lower levels of connectivity and access). It is important that I am able to choose how I engage with the economy, and that the development of a UK CBDC does not undermine or crowd out physical cash infrastructure.

CBDCs would mean the introduction of digital ID via the back door. Despite the inevitability that digital ID will be integral to the development of a UK CBDC, the consultation barely mentions it. Everyone should have the right to access the economy with or without digital currency, and with or without digital ID. It worries me that, as it is virtually impossible to develop a CBDC without a comprehensive digital identity system, my transactional data would likely be tied to my identity. The government must provide more information regarding how digital identification methods would be used in a UK CBDC, and provide reassurances that I will not have to trade my identity information in return for access to the economy (such as in the proposed “tiered wallet”).

I completely oppose the proposal, as it does not reassure me that my privacy would be protected to the degree that physical cash provides.

Further, it fails to offer any convincing reason as to why a CBDC is needed; especially when it would come at such a major cost to privacy, financial freedom, and equality.

Regards,

[Your name].