Though national identity card is supposed to foster feelings of unity, belongingness and inclusion, in reality it has divided people more than anything else with groups for identity and privacy slugging it out in almost every other country where the identity project has ever been taken up. In many countries the fight has been sporadic with ID card project rearing its head every now and then. United Kingdom and United States of America have in particular witnessed so many flip-flops on the issue that their governments and political parties may not even remember how many about-turns they have done on the subject.

A debate has been raging in India since Manmohan Singh government broadened the sphere of MNIC (Multi-purpose National Identity Cards) to National Population Register (NPR) appending into it a biometrics-based Unique Identification (UID) number. The opponents of the scheme have accused the central government of snooping into privacy of residents. They fear that the project would prove to be the death of right to privacy implicit in Article 21, which guarantees protection of life and personal liberty. They apprehend that the governmental agencies would misuse the information collected under the project to harass individuals.

The UID-Aadhaar detractors frequently quote the examples of UK, USA and Netherlands, Greece, France and Turkey, which recently scrapped either their identity projects, or use of biometrics on the grounds that they intruded into residents’ privacy. Their argument is that once a person hacks into the UID database, he can gain access to any other database as the UID will be linked with banks, phone companies, Public Distribution System (PDS), ministries, departments, Public Sector Units (PSUs) etc. They fear since many US companies are involved in the project, there is a possibility that Washington will have access to the database. They also fear that the unique identity would encourage identity thefts and misuse.

The project backers on the other hand hope that the linkages of UID with social sector schemes would improve targeting and delivery of services, reduce their cost and provide online cost-effective, ubiquitous authentication services. Denying that the unique number was a guarantee to rights, citizenship and entitlements, they add that the project would promote financial inclusion as the UID number facilitates opening of bank accounts.

There seems to be a major rich-poor, developed-developing and big economy-small economy divide among the countries when it comes to implementation of the national ID project with people in upper western hemisphere and parts of Europe rejecting their government’s efforts to introduce and store biometrics in a central system. Countries like United Kingdom, France, Hungary, Netherland, Greece, Norway, Turkey and Ireland in Europe have either not incorporated biometrics in the ID or stopped scanning biometric information.

Similarly in North America and Australia continents, countries like USA, Canada, Australia and New Zealand have kept off the biometrics. In Asia, China, Japan, Sri Lanka are yet to join the clamour for biometric identity. Russia and Turkey, the two majors of Eurasia, have also not signed up for the biometrics till now.

Here is a List of International Experiments that have Taken Place in Various Countries Around the Globe:

Europe

Ironically Europe, which is extremely paranoid about terrorism, is also the one, which leads the campaign against use of biometrics in National ID Cards with Britain, Norway, Netherlands and Ireland having witnessed major opposition to the concept in the past.

Britain in fact seems to have done so many somersaults on the issue that it is never clear whether the ID card is in or out. The project made its first appearance in UK during World War II when then British government decided to use national ID cards to facilitate identification of foreigners around the same time when Greece and France also introduced the cards.

Persons were required to carry the card at all times and show it on demand to police and members of the armed forces. And this is what brought its downfall. In 1951 Acting Chief Justice Lord Rayner Goddard ruled that police demanding ID card “from all and sundry” was unlawful leading to repealing of National Registration Act, the law which facilitated issuance of the ID card.

In 1984 and 1998, the UK government put in place a Data Protection Act, which authorised storage of lot of personal information in databases.

The UK Parliament passed Identity Cards Act in 2006 providing linkages of National Identity Cards, a personal identification document and European Union travel document with a database known as National Identity Register (NIR).

Another two years later, then UK Home Secretary Jacqui Smith proposed that web communication be stored by the ISPs and MSPs in a giant database for 12 months. “Our ability to intercept communications and obtain communications data is vital to fighting terrorism and combating serious crime, including child sex abuse, murder and drugs trafficking. Communications data – that is, data about calls, such as the location and identity of the caller, not the content of the calls themselves – is used as important evidence in 95% of serious crime cases and in almost all security service operations since 2004,” she said.ⁱ

These anti-civil liberties measures proved to be the undoing of Labour government as two years later Conservatives rode back into power on the same issue. In February this year, the government finally scrapped the identity card scheme, terminated Identity Commissioner and destroyed all information held in the National Identity Register. UK Home Secretary Theresa May declared invalidation of existing cards saying they were ‘intrusive, bullying and ineffective’.

Earlier this month, however, the UK government once again revealed plans for an identity assurance scheme, which will help people access services, related to the Department for Work and Pensions. Under the scheme, private companies will run the accreditation services that verify a person’s identity when they log in to a service online. But this may still not be the last word on the subject.

The current French government has proposed a compulsory biometric card system, which is being opposed by human rights groups.

In Greece, fields included in previous ID card formats, such as vocation or profession, religious denomination, domiciliary address, name and surname of spouse, fingerprint, eye and hair color, citizenship and ethnicity were removed permanently as being intrusive of personal data or superfluous for the sole purpose of personal identification.

The plastic card in Hungary does not have any information about the owner’s residential address, nor his Personal ID. This sensitive information is contained on a separate card, called Authority ID.

Ireland and Norway have felt that ‘very serious privacy issues’ are involved in the biometric identity scheme. Austria has also restricted use of Social Security Number (SSN) to areas of social security, taxes, education and other administrative areas.

Yet many European countries – Belgium, Bulgaria, Denmark, Estonia, Finland, Iceland, Italy, Latvia, Lithuania, Poland, Portugal, Romania, Slovakia, Slovenia, Sweden, Switzerland and Ukraine have introduced a National Identification Number for their citizens.

North America

Like Europe, North America too has serious issues with the use of fingerprints, iris scan for national identity cards with America and Canada, the two major countries of the continent having failed to convince their citizens on the subject.

Americans have resisted quite a few attempts of their government to upgrade Social Security Card to a National ID Card. In 1971 and 1973, the American government was forced to say that National ID card was not desirable. Ronald Reagan and Bill Clinton administrations too preferred not to touch the controversial biometrics.

The 9/11, however, did tamper the opposition to identity card as US Congress legislated Real ID Act of 2005 calling for national digital identification system. The Act amended US federal law pertaining to security, authentication and issuance procedures standards for the state driver’s licenses and identification cards, as well as various immigration issues pertaining to terrorism. Since United States has no national identification card, driver’s licenses have been used as a de-facto standard form of identification within the country.

Real ID Act set 11th May 2008 as compliance deadline for all states. But majority of the states have either applied for extensions of the original compliance deadline or received unsolicited extension. Over half of the states have approved either resolutions or binding legislation not to participate in the programme.

Yet Obama Administration has not quite given up. It hopes to fund pilot projects on adoption of Internet IDs next year. The administration’s idea is to have multiple identity providers that are part of an ‘identity ecosystem’.

Although every now and then one hears voices for attaching biometrics to Social Security Card to bring about immigration reforms, so far, the American administration has not succeeded in convincing citizens who back civil liberties and privacy.

Earlier Canadians rejected a proposal for a National ID Card that would require fingerprints and an iris (eye) scan. The Canadians estimated that this system would cost Rs 226 billion for their 32 million citizens and offered no security for the country from terrorists as some experts suspected that even with eye scan the cards could be duplicated.

Mexico, however, is on way to introduce iris scan for all its citizens for identification. It has made a beginning with the city of Leon and Guanajuato.

South America

In South America, the saying ‘what is good for goose is good for gander’ stands on its head, as unlike their counterparts in North America, the countries in down South, appear to have no issues with biometrics. Recently UID honchos from India visited Brazil to learn from that country’s ‘innovative targeting and identification mechanisms for social programmes’.

The government of Brazil is engaged in a nation-wide effort to replace its traditional ID card with a Registery of Civil Identity (RCI) card enhanced with biometric data. The new chip-based identity card stores information about the cardholder’s name, gender, date of birth, photograph, affiliation, place of birth, signature, fingerprint, place and date of issuance and expiration. It uses state-of-the-art technology and is designed to avoid repeated identity registration in different states as well as confusion caused by different people with the same name.

Last year Brazil used biometrics in Presidential election to prevent voter fraud and ballot stuffing.

Brazil’s neighbour and second largest country of South America, Argentina, recently signed up with Cross Match Technologies, a global provider of biometric identity solutions, for deployment of identity management systems throughout the country. Cross Match will provide guidance and expertise in the areas of forensic-quality fingerprint and palm print capture devices, multi-model biometric capture systems, document readers, software and associated professional services. The Argentine government uses biometric identity solutions to enhance safety, security and promote welfare programmes for its citizens.

DNI (Documento Nacional de Identidad) is the official form of identification for citizens in Peru, another country in South America. The electronic DNA has facial image and print of right index finger of the cardholder besides other general details like name, date of birth etc.

UID backers feel the project will promote financial inclusion as the UID number facilitates opening of bank accounts

Chile on the other hand uses biometrics extensively for healthcare insurance, banks, pension funds and retailers as well as police and immigration services. Santiago airport in the country uses facial recognition technology for security.

Pablo Izquierdo, Director General of I-Med, a Santiago-based company explains the diametrically opposite views held on biometrics in North and South America. . “In the U.S. people don’t much like the idea of a database of digital fingerprints; Latin Americans – well – they couldn’t care less about it,” Izquierdo says.ⁱⁱ

Bolivia, which shares borders with Brazil, Peru, Argentina, Chile, registered more than 5 million voters by collecting their fingerprints, biometric photographs and electronic signatures within 75 days before the 2009 elections and is now advising Georgia on the same.

Australia (Oceania)

Both the major countries in the region – Australia and New Zealand – are opposed to national identity and biometrics so much so that the former has rejected proposals for the card twice. The first proposal to create a universal number for Australian citizens and permanent residents was jettisoned in 1987. The second proposal – floated in 2005 for an Access Card for health and welfare benefits – was abandoned two years later due to privacy concerns relating to identity theft and disclosure of information. The country protects its Medicare and tax file number identifiers with strict privacy laws.

A parliamentary committee in Australia recently rejected the use of biometrics as a form of identification technology for gamblers saying that the technology would be a privacy overreach.

In 2009 when New Zealand tried to introduce biometrics in immigration, it kicked up a furore with people fearing that technology will be extended to other arms of the law. No wonder the island country is among the few countries of the world, which do not have a national ID card.

Africa

The situation in poor African continent would bring a big smile on the faces of votaries of biometric-based national ID in India as an overwhelming majority of the countries there have either already introduced the cards or are in the process of doing it.

While South Africa, Mauritius, Gambia and Zimbabwe have brought in biometric identity cards, Tanzania, Sudan, Lesotho, Nigeria, Angola, are on course to get them.

In Gambia and Mauritius, citizens above 18 years of age are required to apply for a National Identity Card. The former has made it mandatory for its citizens to show the biometric card at the time of applying for a driving license.

In South Africa, it is necessary for the citizens to carry identity document, which resembles a passport, at the time of opening a bank account, registering at an educational institution, buying a mobile or applying for a driver’s license, passport, unemployment insurance and voting in elections.

Tanzania’s National Identification Authority (NIDA) recently awarded a deal for national ID system for 25 million cards.

NIMC has the mandate to establish, own, operate, maintain and manage the National Identity Database, register persons covered by the Act, assign a Unique National Identification Number and issue General Multi-Purpose Cards (GMPC) to those registered individuals, and to harmonise and integrate existing identification databases in Nigeria.

Sudan is launching a civil registry project that expects to have the fingerprints of 8 million of the 16 million citizens and foreign residents for the country’s national database.

The Angolan Government has officially approved the design of its new ID card for all its adult citizens. The cards will store personal data including personal and biometric identification.

Asia

When it comes to biometric national ID cards, Asian continent is divided among ayes and nays with China, Japan and Turkey yet to give assent to biometric identification. Pakistan, Bangladesh and Malaysia, on the other hand have already issued biometric identification for their citizens. Sri Lanka and Indonesia are all set to join the bandwagon.

In Pakistan, National Database & Registration Authority (NADRA) has captured 371 million fingerprints and 99 million faces and also facilitates mobile-to-mobile payment. The ID is tagged with Benazir Income Support Programme for poor. NADRA issued support to 500,000 Watan Card-holders during floods in Pakistan in last year.

Bangladesh has had biometric identification since 2008. Bangladeshis use NID card for obtaining passports, driving licenses, credit cards and for registering land ownership. MyKad or Government Multipurpose Card (GMPC), the official compulsory card in Malaysia, carries a microchip, which contains several items including biometrics.

In Israel, a move to have biometric database is being criticised for not using encryption method to minimise infringement to highly sensitive information. The database will be in the custody of Interior Ministry. Association for Civil Rights, an NGO headquartered in Jerusalem, fear the database will grossly infringe on Israeli citizens’ rights.ⁱⁱⁱ

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i. A report on BBC uploaded on October 15, 2008
ii. bUSiness Chile, a business magazine of the Chilean American Chamber of Commerce (AmCham Chile).
iii. Report on ynetnews.com