FIPR response to the UK Entitlement Card consultation
Risk of increased fraud and identity theft
- Reducing the incidence of identity theft has been claimed as a major
benefit of an entitlement card. In announcing the consultation, the Home
Secretary told the House of Commons that "in France, the level of credit
card fraud is one sixth the level in this country, as a result of the
technology used there."
- In fact, credit card fraud is lower in countries such as France and
Spain for reasons entirely unconnected with identity cards, such as more
secure cards (which are already being introduced in the UK) and more
frequent verification of transactions with card issuers.
- Nor are identity cards useful for the fast-growing online financial
sector. Internet Bank Smile told The Guardian on 30 January 2003 that
"When it comes to internet banking, I don't think identity cards could
help. We couldn't expect [a customer] to bring it in to us" . Indeed,
if new customers had to present a physical object as the only
satisfactory means of identifying themselves, this could be expected to
place online banks at a disadvantage and thus decrease competition in
the retail banking sector.
- Entitlement cards would certainly increase the risk of identity
theft. The very large databases of personal data required would provide
a highly tempting target for corrupt insiders and/or external attackers.
They would contain precisely the information required to imitate those
in the database. The credit card details, addresses and social security
numbers of several million customers of the Russian mobile phone
operator Mobile Telesystems were stolen from such a database last year
- Forged cards would also be very valuable to fraudsters. If Government
and private sector organisations became reliant on a single card as a
highly trusted means of identification, they would allow identity
thieves to impersonate their victims all the more effectively. This
could leave a stain on a victim's credit and criminal records that might
prove difficult to remove.
- It is extremely unlikely that a card that was eventually issued to
around 60 million people would be secure against highly-skilled forgers.
Current smartcards are still nowhere near tamper-proof, as the
widespread forgery of pay-TV smartcards has made abundantly clear. A
national ID smartcard scheme might simply collapse in the face of
widespread forgery, as some pay-TV stations have.
- The "biometric" security measures (such as fingerprint scans or
facial recognition) that the Home Office suggested might improve card
security are even easier to break. One Japanese research team found that
they could produce fake "fingers" using gelatine from prints left on
glass that would fool all 11 sensors they tested 80% of the time . A
study by the United States National Institute of Standards and
Technology found a false positive rate of 43% when trying to match
people to a database of photographs just 18 months old, even in perfect
camera conditions .
- Even humans have difficulty matching faces to photographs. A
randomised controlled trial done by the University of Westminster
concluded that supermarket checkout staff could not tell effectively
whether photographs on credit cards corresponded to cardholders in front
of them . The use of photo-ID has a largely deterrent effect, which
is declining over time as its ineffectiveness becomes known. It also
raises issues for ethnic minorities -- of identification accuracy as
well as of the frequency with which identification is demanded.
- For all these reasons, we are deeply sceptical of the proposition
that identity cards will reduce identify theft. Given that some
countries have cards and some do not, such a proposition would be
supported by ample evidence if true. The absence of such evidence is
significant and highly damaging to the case.
Future function creep
- If an entitlement card system was to be rolled out, experience shows
that it would quickly become used for a variety of unforeseen purposes.
It would certainly allow much greater linkage between government
databases, as was suggested by the "Privacy and Data Sharing" report
from the Performance and Innovation Unit. The government has suggested
several times that such linkages could be made on the basis of secondary
legislation, which provides limited opportunity for parliamentary
- But even if primary legislation were required, the political climate
— and indeed government — can change quickly. The Dutch data
protection commissioner told the UK Information Commissioner's
conference on this subject that a Dutch population register was
completed just in time to be used by invading Nazi forces. Events such
as terrorist atrocities can lead to sometimes hasty significant changes
in legislation. It would be ironic if a Labour government was to proceed
with a scheme rejected by a Conservative administration they had claimed
in Opposition to be extremely right-wing.
- The private sector would also be likely to quickly make use of an
entitlement card — particularly as they would not have to bear any of
the cost of doing so. Socially excluded groups such as the homeless or
mentally ill might find it even more difficult in future to access
services without a card they would be less likely to possess.
- It is unfortunate that a consultation over an issue so closely
associated with "Big Brother" has itself been filled with Newspeak. A
card whose main effect would be to deny access to many services to many
individuals has been continually promoted as an "entitlement" card. The
government claims the card is "universal" and not "compulsory" since it
would not be an offence to be stopped by police without a card —
although everyone over the age of 16 would be required to obtain one.
The Home Secretary has labelled those who disagree with his proposals as
- This may be one reason why public engagement on the issue has been
more limited than the Home Office claimed to want. We are pleased to
have been able, along with Privacy International and Stand, to encourage
around three times more submissions to the consultation in its last
three weeks than had been received by the Home Office in the previous
five months, simply through the mechanism of a web site and telephone
lines publicised via the Internet.
- Conservative and Labour governments alike have seen the failure of a
significant number of large-scale IT projects. Research by Computing
magazine in 2001 found that over £1bn had been wasted on large
government IT project failures since 1997.
- The government appears to have greatly underestimated the costs of a
deployed system. Research done for the Information Commissioner
suggested the figure given for even a relatively simple card of £1.3bn
may be a factor of ten or more too low. This is even before the
potential cost overruns likely on such a complex project.
- Once the massive infrastructure necessary for a national scheme was
in place, it would be extremely difficult to install new management
companies through competitive tender. The information advantage of the
incumbent would be an almost insurmountable hurdle for competitors to
overcome. And the scale of the system would limit competition to only
the largest global IT companies. The government would risk becoming a
hostage to a monopoly supplier.
- In general, governments that consolidate a number of disparate
systems into a single centralised one usually find that promised savings
fail to materialise, precisely because of such lock-in effects.
Little impact on illegal working
- We simply cannot understand how an entitlement card would reduce the
illegal employment of workers without work permits. Employers are
already required to verify employees' right to work in the UK, and
obtain a National Insurance number which can be checked by the
government. If they are illegally flouting this system, it seems
unlikely that they would demand and verify an entitlement card from such
- German experience has shown that better enforcement and high
penalties for employers are the most effective ways to reduce illegal
- Entitlement cards seem to be a solution desperately searching for a
problem. They would have little positive effect on identity theft,
illegal working or (as even the Home Office admits) crime. They would
certainly encourage increased data sharing within government, but this
is a "benefit" the public may not be as impressed by.
- A card scheme would carry significant technical, financial and
privacy risks. It could cost well over £10bn. Without a far clearer idea
of its benefits, these risks and costs seem foolish to assume.
- Every few years, vested interests in the card and computer
industries raise the issue of identity cards in one guise or another.
This consumes the time and energy of ministers and officials, and
undermines public confidence in the Home Office, until the arguments we
have reiterated here cause the matter to be shelved. We recommend that
this time, the Home Secretary should not simply let the matter die
quietly, but should take a positive policy decision that the Government
will not introduce identity cards. Given that the last Conservative
government also took such a decision, officials should then receive
clear and unequivocal instructions to take no actions that might tend to
make administration less convenient in the absence of identity cards.
- T. Baldwin, "State turns blind eye to workers in the shadows," The
Times, 31 January 2003.
- N. Farrell, "Thieves pirate Russian telco data,"
- S.A. Mathieson, "A born identity," The Guardian, 30 January 2003.
- T. Matsumoto, H. Matsumoto, K. Yamada, S. Hoshino, "Impact of
Artificial Gummy Fingers on Fingerprint Systems," Proceedings of SPIE
Vol. #4677, Optical Security and Counterfeit Deterrence Techniques IV,
- P.J. Phillips, A. Martin, C.L. Wilson, M. Przybocki, "An
Introduction to Evaluating Biometric Systems," IEEE Computer, 2000.
- R. Kemp, N. Towell, G. Pike, "When seeing should not be believing:
Photographs, credit cards and fraud," Applied Cognitive Psychology Vol
11(3) (1997) pp 211-222.