The UK's Information Commissioner believes the government's proposals for a national entitlement card are so widely drawn that "it is impossible to conclude that the necessary privacy and data protection safeguards will be in place."
Responding to the government's consultation document, Richard Thomas said: "The government's efforts to consult widely on its proposals are welcome, as is its recognition that for any scheme to proceed, data protection and privacy concerns must be addressed. However, the present proposals raise a number of serious concerns that must be remedied if the scheme is to meet the requirements of data protection law."
Specifically, his concerns include:
- The need to guard against 'function creep' - especially the risk that greater state monitoring of individual's activities will be helped by recording these in a central register
- The problems of relying on existing databases of questionable quality
- Keeping personal details accurate and up to date
- Stopping the card itself becoming the target for identity fraudsters
- The difficulties in restricting the wider use of the card and the unique personal ID number in situations where these are not really needed
- Excessive amounts of information displayed on the card and the dangers of misuse by others who see this.
Thomas said: "We must be under no illusion. We are dealing with matters touching on the very nature of the society in which we live. There must be greater clarity about the main purposes behind an effectively mandatory entitlement card. Why do we need the massive infrastructure which will require the highest level of identity validation for the most mundane of services? How can we be sure that the unique personal number and a central register will never be used to track all our various interactions with the state and others?"
He added: "If the government intends to pursue the matter, then it should bring forward another set of more narrowly focused proposals together with a draft bill making clear the safeguards that will be put in place."