Crosby’s 50-page plus document titled ‘Challenges and Opportunities in Identity Assurance’, meant to comment on the then proposed national security project in UK, touches upon almost every other domain the UID is directly or indirectly expected to impact on
Minus the name of the author and the country, Sir James Crosby’s report on United Kingdom’s now-scrapped Universal Identity Assurance System reads like a treatise on Unique Identity system hitherto rechristened Aadhaar.
Released in March 2008, the report was supposed to pave the way for national identity system in Britain. But it ended up queering the pitch for then Labour government as its opponents – the Liberal Democrats and the Conservatives – highlighted how the report had argued against keeping full biometric images in the ID cards and advocated protection of all data and systems through state-of-the-art encryption. At the same time they focused on obtrusive and anti-privacy nature of the project. The ID project contributed to the Conservatives and the Liberal Democrats ascent into power and the first thing they did after assuming power last year was to announce a timeline for its nullification calling it ‘intrusive, bullying, ineffective, un-British’ and one that represented ‘worst of the government’.
Ironically, the Crosby document often quoted in our media to indict UID on one or the other score seems to build a strong case for what it calls ‘ID assurance’ a consumer-led concept, a process that meets an important consumer need without necessarily providing any spin-off benefits to the owner of any database. It claimed that due to haphazard proliferation of ID assurance systems and growth of silos, local authorities and welfare departments need a universal identity assurance.
The report felt that the universal identity would not only help individuals to assert their identity with ease and confidence without delay but also make optimum use of public services, banking transportation, e-commerce and other welfare schemes. It would cut down government cost, build up trust among different departments and enable ‘joined up government’. At the same time, it would allow public and private sectors in enforcing their policy objectives. Moreover, it would improve efficiency for business and ensure that suspect individuals leave trails of transactions that are ultimately traceable back to unique identity records for the purposes of national security.
Inclusion brings you the do’s (positives) and don’ts (pitfalls), the six chapters in the Crosby report prescribe for the identity project:
All elements of the scheme should be designed with the customers’ interests at the core.
Once enrolled in the scheme, a customer may wish to enable “joined-up” government services and government should, using robust solutions to protect this data, give customers the option to do so.
The scheme should be operated independently of government (for example, accountable directly to Parliament) and its processes and security arrangements should be subject to the approval of the Information Commissioner, who should have the power periodically to review delivery.
To protect consumer privacy and engender trust, the amount of data stored should be minimised. Only non-unique digital representations of biometric images should be stored.
Citizens should own their entry on any register in the sense that it should not be possible for any such data (including digital representations of biometrics) to be shared without their informed consent.
Verification of identity should be performed without the release of data.
The system, from enrolment to point of use, needs to be simple, convenient, and cost effective for the consumer.
Enrolment processes should vary between individuals and over time so as to minimise costs, strengthen the focus on high-risk customers, and give citizens the simplest and most hassle-free experience consistent with the achievement of the published assurance targets.
Fast roll out is important in order to be able to respond to consumer demand and achieve early realisation of economic and social benefits.
Private and public sector organisations are unlikely to depend on the system until a critical mass of customers have registered, and so the benefits of a universal ID scheme largely come once it is widely adopted.
No technology provides total assurance nor is any one technology totally future proof, but a modular roll out will capture the benefits of technology change and allow the system to be kept up to date.
The scheme’s systems should be closely aligned to those of the banks.
Citizens should be able to rely on their cards being replaced and their identity being repaired quickly and efficiently.
Enrolment and any tokens will have to be provided free of charge.
The market should provide a key role in delivering a universal ID assurance.
Technology-neutral standards should be adopted.
In countries where there has been a lack of consultation (Finland), good technical solutions have remained under-used due to a lack of public unity. In spite of the many services on offer, the Finnish card has failed to attract customers and many organizations are taking a ‘wait and see’ attitude about adopting the ID card authentication standard.
Malaysian card (MyKad) have had little take up. Of ten million drivers, only 1.3 million have added their driving license information to their MyKad. The police don’t carry MyKad readers and still insist on drivers producing conventional driving licenses.
Biometric data is not impregnable; fingerprints can be replicated from prints left on certain surfaces.
Biometric technologies do not work precisely 100 per cent of the time and biometric characteristics will adjust due to age and environmental changes.
While some ID cards schemes deliver a high level of assurance, relatively few have any links into core banking systems and taken together they embrace a wide variety of processes and technologies with no near term likelihood of any common standards being established.
The Government should avoid picking a technology and building a strategy to match.
ID assurance is not ID management, in which an organisation keeps a close track of people and their movement. While ID management is designed to benefit the holder of the information, ID assurance is focused on bringing benefits to the consumer.
Biometrics is not the silver bullet and cannot be a substitute for biographical data.
If citizens don’t use a system regularly, it will be capable of providing very limited data for national security agencies. Thus, even the achievement of security objectives relies on consumers’ active participation.
(Though) the market forces are presenting citizens and consumers with an ever increasing array of ID systems of unknown quality, market place is not about to deliver the best outcome for consumers.
Full biometric images (other than photographs) should not be kept. Only non-opaque digital representations of biometric images should be stored. Additional data accessed during enrolment and records of verification enquiries should not be retained.