Select Committee on European Union Minutes of Evidence


Examination of Witnesses (Questions 20-39)

DR GUS HOSEIN

28 FEBRUARY 2007

  Q20  Lord Jopling: You have talked about the items 26 and 27. I wonder if you would enlarge on that and, also, bring in 25, the No-show one, and just enlarge on the way those work, if you would be kind enough.

  Dr Hosein: If I could just clarify, on 25 (this is a note that I incorrectly raised with the clerk earlier), it is actually "Go-show" information. Upon research, I found that Go-show information is about the passengers who have purchased a ticket at the airport; they are the last-minute fliers.

  Q21  Chairman: We thought we had made a misprint in the questions.

  Dr Hosein: I had also noticed that, but field 23 is No-show information as well. So Go-show is specifically a walk-up passenger; someone who presents themselves without a ticket or reservation and buys a ticket to travel immediately. Not all airlines treat this individual as a Go-show. That is an important note as well. Every airline and every reservation system treats PNR in a very different way. So some carriers will say: "This person does not qualify for the Go-show field"; instead they will just say a one-way passenger. So there is disparity amongst airlines about how this information is dealt with.

  Q22  Lord Jopling: Would you like to expand a bit more and tell us a little more about the OSI and the SSI and SSR?

  Dr Hosein: As much as I can, which is based on conversations with airline officials. The answers are always very different because it is almost as if these are free fields; there is no conformed way of establishing the data in this field; it is where they put other related information. They may have different formats for putting what your food preferences are within the OSI, and special service requests as well—so if you request a wheelchair, and so on and so forth. Every carrier deals with this in different ways and has different codes for this type of data.

  Q23  Lord Marlesford: I am looking at this list of 34, and data element 33 is: "any collected APIS (Advanced Passenger Information System) information", and number 27, which is SSI/SSR information. Would you like to tell us a little about these? As I say, I find the whole of this list quite bizarre. Some are obvious. How is the list compiled, perhaps, should be the first question?

  Dr Hosein: The first question, the list was compiled through a process of negotiation where originally, as I stated earlier, the US Government interpreted its legal mandate, which was to gain access to PNR, as the right to log into the reservation databases of airlines and have free access, even for travellers who are not travelling to the United States. Eventually, this was curtailed slightly and the US Government said: "Okay, we're happy with 39 fields of data". That is when the EU and the US went to battle over how many fields of data. The EU Privacy Commissioner said there is no reason why they should use more than 19 fields of data, as the Australians and the Canadians have already requested only 19 fields of data. The Americans were adamant on their 39 and then somehow we ended up with 34. It was a long, tortuous process and I do not know how—is this magic with the 34 and not 32—but this is the list that we were left with. The difference between the APIS information that you are speaking about and the list of fields and, say, the SSI information is that the SSI information and the OSI information (also called SSR information) is behavioural data. It does not say anything about your identity, it says something about you. APIS information is, generally, the information collected about your nationality and the information that is on your passport and, possibly, the manifest data, such as seating, and so on and so forth. That is identity information. So it is important to recognise that the whole battle over PNR versus APIS is that PNR is all about your behaviour, and that is why the US Government wants it; it is not because they want to identify you, it is because they want to draw conclusions based on this data. Answering specifically on field 33, on any collected APIS data, APIS data is nearly 100 per cent of the time collected at the check-in point. That is when you hand over your passport to the check-in agent, they collect your personal information and that is when the manifest is created. It is not usually created before. The data in this field is for those situations where when you have spoken to your travel agent or when you bought your ticket online, if you happen to include this data in that process of purchase then it would reside in the passenger data record. Even still, that data is not highly reliable; it is not reliable upon because errors could have been entered in passport numbers. People are not really accustomed to handing over their passport number on the telephone or in the travel agency, and so on and so forth. So the APIS data is almost always collected at the check-in point, and that is the data that is considered highly secure and relevant data which is then transferred onwards.

  Q24  Lord Marlesford: A conclusion one could draw from your reply is that if the alternative to the PNR system is to go back to visas, the information which the diplomatic missions will get on visa application forms would be, obviously, much less than the PNR provides, because it could not have all this behavioural stuff, which the airline might be able to put in.

  Dr Hosein: That is entirely correct. It is an astute observation because the PNR would contain, perhaps, religious information, as we have discussed before, and it would contain our financial information—who paid for your flight. That type of information is never requested in a visa process. I could not agree more. It is within the negotiations that become PNR or visa waiver, and that is what the next round of negotiations are going to focus on even more so, which is can the EU somehow give up more PNR, perhaps, in favour of visa waiver access to all EU countries. That is when the level of politics goes up a notch, because this is really about the flow of people and goods without visa, and that is a highly sensitive issue. I can predict that the Americans will make a number of promises about consideration of the visa waiver programme for the EU Member States who are not already in the programme, but I can say from my reviews of the way US Congress refers to the visa waiver programme they would love to shut it down if they could; they do not like the idea of anybody coming to the United States without having to get a visa. It is the civil servants in the United States Government who are adamant about maintaining the visa waiver programme because they understand it is good for trade, and so on and so forth, but there are other civil servants who also realise that this can be used as a negotiation tool.

  Q25  Chairman: Are visa application forms for those nationalities that still require visas being amended and added to take into account the information that comes under the PNR?

  Dr Hosein: I do not believe that is the case. There have been a number of changes to the visas over the years from the US Government, and they have expanded the data collection; they have gone so far as to include biometrics, as is happening in the United Kingdom as well. It is important to note that the visa programme is actually run by the State Department, the equivalent to the Foreign Office, and while PNR is being accessed by the Customs and Border Police in the Department of Homeland Security they have two very different missions and two very different views of the world. I would be surprised if they were a signatory in this area.

  Q26  Lord Marlesford: In the negotiations between the EU and the United States on PNR it would not be unreasonable for the EU to say: "As these are alternatives and as you would have the right to re-impose visa requirements, if we do not accept your PNR, equally we could say that we will give you, through PNR, all the information that you could get on visa applications but no more. Or indeed if there were to be some more that would be part of the negotiations".

  Dr Hosein: I believe that would be a very useful strategy. The reluctance would emerge from the airline industry who have already faced a number of burdens since September 11 2001, but they are reluctant to take on new data collection. So if the carriers were not responsible for collecting, say, the biometrics that now go into visas and additional personal information that go into visas they would be highly reluctant to do so. They already do not enjoy having to hand over this information to the United States, especially because they have to pay for these transfers themselves; they would be even more reluctant to take on new duties.

  Q27  Baroness D'Souza: Does your research show that passengers are, on the whole, aware of the information that is supplied about them to the US authorities, and the use to which it is put?

  Dr Hosein: We have seen our research of general holiday travellers, and they are not very aware of the practices. I have seen research and polling done of travel executives and they are very aware of the fact that transfers are going on and they do have a number—

  Q28  Baroness D'Souza: "Travel executives" meaning?

  Dr Hosein: Corporate travel. It is research emerging from the Association of Corporate Travel Executives, and I always shorten their name the wrong way. It is only recently, on February 15 of this year, that the Article 29 working party, which was the committee of the Privacy Commissioners of Europe, came out with draft language for a short notice that they expect that the EU airlines will present to passengers in the future, describing to them what is happening with their data and how it is being used, to the level of knowledge that they have. The Article 29 working party also released on February 15 a Frequently Asked Questions. I presume they hope that this will go on the websites of the carriers so that people who are concerned can get access to that information. Generally, we have found that the awareness of the practice and the use of that information is very low. I would say that this is also true within the US Congress.

  Q29  Baroness D'Souza: As a supplementary, you have already said something about complaints and that there is no duty to actually report these complaints, but can you say something more about the complaints received from passengers and how they are treated?

  Dr Hosein: There is no duty to report on the number of complaints received from foreign passengers. The Department of Homeland Security, which only recently opened up what is called a Trips Office—I am afraid I cannot remember what the acronym stands for, but it is now a front page item on the Department of Homeland Security website so it is a brand new initiative. That is the interface for people to complain about the use of their information and this was again a very recent phenomenon. The interesting thing about this trips office and the way it deals with complaints, there are two interesting things that emerge. First, they say that your complaints data may also be used for other purposes, so the fact that you complain might be used against you at some point, and any safeguards against the data emerging from the complaint is protected by the US Privacy Act 1974 which again only applies to US persons. We have not seen any reporting on the number of complaints received from, say, EU citizens and we have not received any reporting from the various privacy commissioners across Europe regarding how many complaints they have received from their citizens as well. Unfortunately, therefore, we cannot count; it is impossible to know how many complaints there have been and it is also near impossible to know how many errors have emerged because again this entire process takes place behind closed doors, within closed computer systems, to the point where even the Government of the United States is not aware of what is going on.

  Chairman: That probably negates Baroness Henig's question, but are you going to ask it nevertheless?

  Q30  Baroness Henig: I will ask it anyway. I was just wondering what remedies were available to EU citizens who believe their personal data has been misused or the undertakings have been breached.

  Dr Hosein: The advice from the Article 29 Working Party in their February 15 document is somewhat amusing because ironically foreigners, although they have no protection in the United States under privacy law, foreign institutions and foreigners generally can apply under freedom of information laws in the United States. Actually the US has one of the strongest, most powerful and expansive regimes of freedom of information so if you want to get answers as to how your data has been used you can go through the freedom of information.

  Q31  Earl of Caithness: Is there another way that one could use PNR, for instance under an electronic travel authorisation, which would be simpler and easier?

  Dr Hosein: Yes, it is possible. This is an idea that the European Parliament recently emerged with in their declaration last month. It is a process that has been going on in Australia, for instance, where instead of having to apply for a visa if you are travelling to Australia—I have never done this so if somebody who has travelled to Australia recently can correct me I would appreciate it—apparently as a British passport-holder or a Canadian passport-holder, which is what I am, I would fill out a form on a website that would then be accessible to the immigration official in Australia where they would get the necessary information. This is a much more effective process for transferring information. I have spoken to a number of airline officials who would love it if this was the process instead of the transfer of passenger name records because they want to be outside this process, they do not want to have to do anything in this entire transaction. They do not want to be immigration checkpoints and carriers definitely do not want to be liable for information that is sent onwards, so they have been calling for a number of years for a similar situation because people can fill out website forms on the US Government's website just the way they have done on the Australian Government website. As a privacy expert and advocate I would say I do not believe it is necessary to transfer this information to begin with. I believe that what has happened is that there has been a drive around the existing source of data which is passenger name records, and that is what the focus of the debate has been on. It has not been about we need to know more information about the people travelling to the United States, it is more we want to tap into this information on people travelling to the United States. If the Americans limited the information merely to identity information then it would almost be acceptable, it would be a mini-visa as you would say for the electronic travel authorisation, but it is clear that what the Americans are after is behavioural data, and that is why they have been going after the passenger name records.

  Q32  Earl of Caithness: Could you just remind us in terms of the PNR agreement between the EU and America and also the similar one between Canada and America, how much of that is push and how much of it is pull?

  Dr Hosein: The first agreement in 2004 was all about the Americans went into it asking for pull, and then as it emerged in the more recent agreement it was mostly about push. In the Canadian situation, the Canadian access to foreign carriers airline data is push. Every country apart from the United States that requires passenger name records it is all about push; generally countries do not want to log into BA's database to start trawling around, nor does BA normally want that to happen. The Americans are the exception because the Americans have the power they have to refuse airlines to travel.

  Q33  Lord Foulkes of Cumnock: Dr Hosein, we have a copy of your joint letter to Vice-President Frattini and in paragraph 2 you say "ATS then generates a risk assessment score for all passengers." Could you amplify how that risk assessment score is calculated?

  Dr Hosein: It is impossible to know; that is again the problem. ATS has not been openly reviewed by any Government agency; the Government Accountability Office of the US Government which is the most powerful investigatory body within the US Government in all of its reporting on ATS never noticed that it was actually being used for passenger data, so there has to this date not been any review of ATS. What we have made use of in order to draw these conclusions are all the public statements and regulatory statements made by the Department of Homeland Security on ATS and, as well, the statements made about the ATS background applied just to cargo instead of passengers. In their regulatory statements the term used by the US Government is "risk assessment score". They have previously also used the term "algorithm" which hints data mining because you are trying to make sense of vast amounts of data. From discussions I have had with officials and experts in this area, my understanding is that based on the data they have come up with a number score between zero and a hundred, and based on the number score a flag is then raised and that flag is then seen by the customs official, immigration official at the border.

  Q34  Lord Foulkes of Cumnock: I wonder, My Lord Chairman, if I could jump to what is the central question. You describe yourself as a privacy expert and advocate and everything you have said has been in relation to protecting the interests of individuals, but we are living in a very dangerous world. You spoke about serious crime; there is a lot of that around and there are people travelling around the world who are involved in serious crime, organised crime which you spoke about, not to mention of course terrorism and the multiple threats—not just one threat, not just potential Islamic threats—of terrorism. Do you not think that in seeking to protect the privacy of individuals you are undermining the security of nations and people generally?

  Dr Hosein: Every day. Every day I wonder whether what we are defending is worth defending. Every time I come back to the passenger name records issue I ask myself why am I focusing so much on this, what is so important, and then when you get beneath the veneer, once you get beneath the surface of it you see that this is mostly just politics. We would call for effective security. This is in a sense security theatre and every parliamentary process in the United States, every congressional process that has looked at data mining has concluded that data mining is not a price worth paying. They have concluded that data mining is not effective enough and despite the age of terrorism we are not allowed to open up the records of all people to run algorithms through them to identify the few. Every time that there has been a data mining programme before the US Congress regarding the use of personal information of American citizens it has been decided that this cannot go forward. That is why I am amazed that the EU is going to give the US so much latitude over this automated targeting system when the American Congress, when they do encounter this in the coming months, when they do debate the ATS, will—I know they will—think that this is a step too far. Then there is the issue of watch lists. Again, we have this image that there is one list of bad people around the world and it is properly administered by the UN and will prevent these bad people from getting on aeroplanes and shopping across borders: one such list does not exist, there are actually thousands of lists of this nature and they apply to various levels of crime and various levels of terrorism and some people who are just merely related to terrorism and so on and so forth. We are in the process of creating a mass infrastructure of surveillance presuming that it will actually work, presuming that the data is actually valuable. Again, I will go back to the example of the no fly list in the United States: thousands of people complain that they have been unable to get an aeroplane, and let us recall that it is not just people with last names such as mine, it is people with Irish last names who still cannot get on aeroplanes. There is the classic case of Senator Edward Kennedy, the brother of the former president, who was prohibited from getting on an aeroplane or had to be searched multiple times every time he wanted to get on an aeroplane because of a similar terrorist on the former IRA list that was sent to the US Government named Ted Kennedy. Fortunately, Senator Kennedy knew the head of Homeland Security so he could get the situation rectified, but not everybody else is in an equal position. Going back to the original statement, in the war on terrorism everybody understands that effective security is needed and you need to reconsider some of your original presumptions about civil liberties. You need to reconsider them, not necessarily re-evaluate them, and it does not mean that we should just take as a given everything that is said about a scheme, everything that is said about a system, as we can count on with ID cards, as we can count on with communication surveillance and as we are carrying out data mining, every time difficult questions are asked the argument offered by the Government starts to falter and you realise that truly the emperor has very few clothes.

  Q35  Lord Foulkes of Cumnock: You said theatre but, with respect, you were being a little theatrical earlier on when you said there were 80 million people who had been surveyed and they had only caught 2000, and then you said this is 0.00025 per cent, rather theatrically. If 2000 have been caught, those are 2000 people who might otherwise have been going on to commit terrorist acts, serious crime or take part in organised crime, so we are better off that 2000 people have been caught then not caught; is that not right?

  Dr Hosein: It is not right to almost reverse the burden of proof where everybody has got to present information in a way that is not actually safeguarded and then hope to not be identified wrongly, and there have been wrongful identifications that have taken place such as for every extraordinary rendition that has taken place in the United States there have been a number of errors where the wrong person was sent abroad. Is that too high a price to pay in the name of the war on terrorism? What I was saying was 80 million people have travelled to the United States border and had their biometric data collected. This data is actually collected for 100 years; this data is not safeguarded, it is not prevented from being used by other government departments, in fact it can be used by any state or local or even tribal authority across the United States. These are not clear and effective safeguards. If they really want to fight the war on terror, if they want to truly manage this information, they would introduce proper safeguards. There are not the proper safeguards in place. The 2000 people—this type of debate emerges every time we look at the DNA database in this country; ministers are always very proud of saying we have caught this rapist and this paedophile and so on and so forth—we are not given the details of who these 2000 people were; we are given the details of four of them who happened to be four rapists, there has not been one case of a terrorist being caught by this scheme. Yet they are fingerprinting everybody over the age of 18 travelling to the United States and they are moving to ten fingerprints in the foreseeable future. Is this a case of taking too large a measure against too small a problem?

  Q36  Lord Foulkes of Cumnock: If we take the United Kingdom, at the moment there are some opposition politicians who criticise the Government, as you are doing, for invasion of privacy. The same people are also critical because the Government cannot say how many illegal immigrants there are in the United Kingdom. They cannot have it both ways and you cannot have it both ways and you have criticised and you have put up very effective criticism of what the Americans are doing, but what you have not said is what they should be doing alternatively to deal with what you admit is a real problem.

  Dr Hosein: I will start with the second bit first. We have always called for safeguards, we have not said you must stop all transfers of all sorts, but we have identified where sometimes people are not entirely sure what PNR is and how it is actually used, and perhaps a piece of paper would be sufficient. We have advocated for strong safeguards and these measures can go forward. We are not lobbying against the transfer of data to Australia because the Australians are only asking for 19 fields of information, they are only keeping it for 48 hours. The Americans want to keep this information for 40 years so there is a lack of proportion that is going on and that is what we go after. You raised the issue of illegal immigration. The American Government is spending close to $15 billion on the US-VISIT system and there was just news this week and a Government Accountability Office report last month that said that the system was highly complex and unlikely to ever work, and they have noticed that they cannot actually check the biometrics of people leaving the United States so while they can check people coming in, there is no ability to monitor the exit process so how do you get around the illegal immigration problem at that point when you may have let the people in the country and you cannot manage to get them out. I am not going around saying all surveillance is bad, I am not going around saying the US Government is awful or the choices made by this Government are awful, I am trying to penetrate below the politics and show where there are serious problems and serious concerns and we need to debate these serious problems and serious concerns and not reside at this top level of fear.

  Chairman: Can we have some quick questions relating to this from Lord Harrison, then Lord Jopling and then Lord Listowel?

  Q37  Lord Harrison: Like Lord Foulkes I too hesitated when you gave the figures which were 80 million, of which there were a quarter of a million who were identified of which 2000 were then convicted or caught of whatever. Actually, a quarter of a million is many fewer people than 80 million so if it is in the right ballpark I would have thought it was of advantage to the security services. Granting what you say about the diciness of some of the data and the grounds upon which it is put, it would still be interesting, would it not, to look at that 2000 against another representative sample of quarter of a million? In other words, that may then in turn give you some indication of whether indeed the sift through the 80 million fingerprints was putting you in the ballpark of those who should fall under suspicion.

  Dr Hosein: The quarter of a million I was referring to was through data mining of private sector data and government data after 9/11 to identify terrorists based on a profile. The US-VISIT system does not work on a profiling basis, it works on collecting the personal information of this individual and the biometrics of this individual, does this match any databases of concern, and then a flag will go up and say this person is a wanted rapist so stop this person, or this person has previously been convicted, send this person back home. I would be careful not to confuse the 80 million, the quarter of a million and the 2000. When the US-VISIT system came in the US Government said do not worry about this, we are only taking two fingerprints, we are not treating you like criminals. We warned the US Government at that time that two fingerprints were ineffective and if you were really going to take the fingerprints of individuals you had to take all ten fingerprints, and the US Government said no, no, there is no such worry. What is happening in June this year? They are moving to ten fingerprints. The other concern is if you really want to verify people against the list of fingerprints held in the FBI database—and we warned the US Government of this—the fingerprints taken at the border are just simple fingerprints and not the sophisticated type of fingerprints you need to take at police stations in order to verify criminals against the fingerprint database. The US Government said that is just proof we are not actually treating people like criminals, we are just taking simple biometrics to verify people against their visas and the next time they return and so on and so forth. Now the US Government is saying the new fingerprints are going to be taken in a format that will be interchangeable with the FBI database of fingerprints. My point behind all of this is that at first the system was introduced as a nice people management system and now we are finally understanding that it is actually a criminal management system, treating all foreigners as if they were criminals. It would almost be acceptable—and I would never advocate this—if this practice was applied to American citizens, but it is not being applied to American citizens because that is considered unpalatable. Why is it palatable to apply it to foreigners? It is because we do not care about foreigners, it is because—and this happens in the politics of every country—you do not worry about the other; meanwhile the other, these foreigners coming in, they are at their least powerful status in the entire world as they are when they are right outside of a border. That is when we know that we can treat them the way we have been treating them, we know we can take any information we want from them because they do not have the right to say no. This might be the state of affairs that everybody is happy with, that is absolutely fine and I am willing to settle with that, but let us also admit that we are taking advantage of the situation, we are treating people like criminals for no reason or for a reason we would not treat our own citizens as criminals.

  Lord Harrison: I will leave it there, it is an important point.

  Q38  Lord Jopling: Leaving aside how you take fingerprints, I would like to allow you to put on the record your basic approach to all this. Do you regard the taking of fingerprints in a mass way like this as an invasion of privacy and, if you do, would you accept that the huge majority of us are perfectly happy to have our fingerprints taken and kept on the record for as long as anybody wants?

  Dr Hosein: First, do I consider it invasive? Yes, absolutely. Maybe this is a generational thing, but I come from a generation where you were fingerprinted if you are a criminal. In today's modern society you might be fingerprinted in other ways such as gaining access to a building, but that is a very proportionate fingerprinting scheme that is actually effective. It raises a larger question, is it effective to add more fingerprints to a database to try to identify people? We watch too much crime drama on television and we presume that a fingerprint match is a simple process; in fact it is a very sophisticated process and when you actually run a fingerprint match against a database, what is being given back to you are the nearest results, but that is acceptable when the nearest results are people who are criminals because that is why their fingerprints are on the database. When the nearest results are innocent people who have never been a criminal, but their fingerprints are part of that database, problems emerge. Let me give you the example of Brandon Mayfield. Brandon Mayfield is a Portland, Oregon-based lawyer who converted to Islam a few years ago. His fingerprints were on the US Government databases because he served in the first war in Iraq, he served within the Army. After the Madrid bombings, one of the bags had not exploded and the Spanish police were able to lift a fingerprint of the bag; the Spanish police looked through their database of criminals and terrorists and could not identify the fingerprint, so they made the call out to all other police agencies around the world, does this fingerprint match yours. Both the US Government and the Algerian Government stood up and said, yes, actually we have a match, and the Americans took Brandon Mayfield, as I said, a lawyer, put him in the jail for two weeks without access to a lawyer and told the Spaniards we are willing to send this guy to Spain to face trial. Brandon Mayfield did not have a passport, he had not left the United States for a number of years, and there was a massive investigation afterwards because three FBI experts on fingerprints confirmed that it was his fingerprint, even though it was later discovered that it was not his fingerprint, and so he was kept in jail illegally, he has now sued the US Government and they recently came to a settlement, I believe somewhere in the millions of dollars. There was an investigation in the US Government that asked was this done because Brandon Mayfield converted to Islam and was actually a lawyer defending terrorists in Oregon, or was this merely because of a biometric check against a database? It is never as simple as we imagine it is, it is never as simple as 100 per cent match of one fingerprint against a massive database, it is far more complex. So the argument that we present is that fingerprinting is not by its nature problematic, it is when you start increasing the pool of data for fingerprints that things start. Fingerprinting becomes more and more unreliable and that is why I go back to the original example, fingerprinting to get into a building is not problematic because it is just one fingerprint against a very small database and the error rate tends to be relatively small. When you talk about 80 million people, such as under the VISIT programme, or 60 million people as it would be under the fingerprinting programme in this country—which will be applied to citizens—that is when the errors actually emerge. Finally, on the issue of do I accept that the majority accepts it as reasonable, I do not accept that. I do not accept that the majority would necessarily find fingerprinting acceptable and I would note that support for the ID programme, for instance, particularly in the biometrics component, is as low as 50 per cent.

  Q39  Lord Foulkes of Cumnock: You are quoting the LSE study, are you not?

  Dr Hosein: No, I am not. The LSE has done no polling on this, I am quoting ICM and YouGov polls that originally showed—and this is the case with all the policies I have dealt with over the years. When a policy emerges at first, particularly when it is to do with the war on terrorism, support is 80 per cent because who would not support a measure against terrorists? The more people learn about these policies, the more they understand about these policies, the support for them actually goes down. Meanwhile, the United States support for US-VISIT is very high; there are very few people who would oppose fingerprinting Mexicans and Canadians who, ironically, are not fingerprinted on the US VISIT programme, but if it is Germans, British and French nationals they have no problems about it, but the Americans would not accept being fingerprinted by their own Government.


 
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