Memorandum by Dr David Moss, Director,
Business Consultancy Services Ltd (BCSL)
1. We prefer, in the UK, to be able to respect
the government even if we do not always agree with them. In the
evidence below, several examples are given of illogical behaviour
by the government in connection with ID cards and ePassports.
It is hard to respect an illogical government. And if respect
goes, what will be next? Obedience? The government have set out,
quite unnecessarily, on a dangerous path. This is a plea for them
to turn back. For their own good and ours and as an example to
other countries embarked on a similar course.
2. David Moss of BCSL has nearly 30 years
experience in IT and has spent over four years researching ID
card schemes, with the following findings. Crime prevention, crime
detection and counter-terrorism can best be assisted by making
more use of the global mobile phone system, which we already have.
ID cards and the unreliable biometrics which go with them would
be of little assistance and even that would be delayed for years
while we get the infrastructure installed.
3. According to an April 2004 booklet1 issued
to UK employers by the Home Office, it is our responsibility to
ensure that we offer jobs only to people who are legally entitled
to work. The booklet includes a list of 18 documents we can use
to establish that entitlement.
4. According to the Home Office's October
2006 cost report2 on the ID cards scheme: "Currently, employers
do not have a reliable means of establishing whether a job applicant
has the right to work here or not" (p 5).
5. Logically, the Home Office could simultaneously
believe neither of these statements, or just one of them, but
6. The October 2006 report is at pains to
say how hard it can be to identify people, not just for employers,
but also for the criminal justice system: "It is difficult
and resource intensive to ascertain the identity of prisoners
suspected of being foreign nationals and those arrested by the
police" (p 5).
7. And the problem does not end there. The
Criminal Records Bureau Registered Bodies (CRBRBs) are no better
off: "It is currently very difficult for [CRBRBs] to establish
an applicant's identity efficiently ... It is already known that
on some occasions, individuals are matched against the wrong criminal
record ... this can lead to delays in processing their applications.
In a small number of cases, people known to the police have been
able to proceed through the system undiscovered" (p 5).
8. The solution to the identification problem
proposed by the Home Office is biometrics (mentioned 41 times
in their brief report): "Biometric checks and reduced reliance
on paper documentation will help ensure that claimed identities
are real, not fabricated or stolen. Each person registered will
have a quick and secure way of proving who they are whenever needed,
for example via a quick online match of their ID Card and biometrics
or unique reference number. Individuals can only register once
as their biometrics will be linked to a single identity, which
will prevent the creation and use of multiple identities"
9. Three biometrics have been considered
by the Home Officebiometrics based on facial geometry,
irisprints and fingerprints.
10. As far as facial geometry is concerned,
the Home Office were warned four years ago3 by the National Physical
Laboratory that: "Face recognition on its own is a long way
from achieving the accuracy required for identifying one person
in 50 million" (p 11), "even under relatively good conditions,
face recognition fails to approach the required performance"
(p 15) and "facial recognition is not a feasible option"
(also p 15).
11. Why, in that case, do the Home Office
continue to give credence to biometrics based on facial geometry?
Has something changed in the meanwhile?
12. It seems not. The Commissioner of the
Metropolitan Police is quoted4 in June 2005 as saying: "Identity
cards are only going to work if we have a biometric answerthat
may be iris recognition but it is unlikely to be facial recognition".
And the National Audit Office (NAO) say in their February 2007
report on ePassports,5 which incorporate biometrics based on facial
geometry, that: "Facial recognition software is not reliable
enough to use with large databases" (para 3.4).
13. As far as irisprints are concerned,
the Identity and Passport Service of the Home Office have decided
not to proceed with them6 for the moment, citing "cost and
technical uncertainties". At the same time, the Border and
Immigration Agency of the Home Office are proceeding with irisprints
for their eBorders programme7: "IRIS (Iris Recognition Immigration
System) is a quick, convenient and secure way to clear immigration
controls, open to British citizens, and foreign nationals with
permission to enter the UK" (para 5.12).
14. How can the same technology be too unreliable
for one bit of the Home Office while it is simultaneously acceptable
to another bit of the Home Office?
15. Which leaves us with fingerprints. Most
people are confident that traditional fingerprints are reliable.
Rolled prints, taken by police experts using ink, are admissible
as evidence in court. But this is not the technology being offered
by the Home Office. Instead, they are offering flat prints, taken
by putting your fingers on a photo-copier. This technology is
different from traditional fingerprinting and is not admissible
as evidence in court. It is something of a confidence trick to
give the same name, "fingerprinting", to two such different
16. In the Home Office's evidence to the
House of Commons Science and Technology Committee, reported in
July 2006,8 they acknowledged that flat print fingerprinting is
not 100% reliable and stated that the maximum acceptable false
non-match rate is 0.01 (para 18). By which they imply that if
up to 1% of people find that the technology falsely reports that
they are not themselves, that will be acceptable, but anything
above would not be acceptable.
17. In fact, when the flat print technology
was tested in the UKPS biometrics enrolment trial,9 the false
non-match rate was 19% (para 22.214.171.124). 19 is greater than 1. By
the Home Office's own criteria, the technology is therefore unacceptable.
18. Instead of acknowledging this fact,
the Home Office argued that the biometrics enrolment trial was
not really a test of reliability: "When questioned in an
oral evidence session about the false non-match rates that resulted
from the Atos Origin trial, Katherine Courtney said that `I think
it is important to reiterate that the enrolment trial was a trial
of process and customer experience. It was not designed as a trial
to look at performance of the technology per se' ..."
(para 88). In that case, why do Atos Origin list these performance
figures in the Management Summary under Key Findings?
19. Given that this flat print fingerprinting
is so unreliable, it is a consolation to discover that the UK,
Ireland and Denmark are exempted from EC 2252/2004, a directive
which instructs other EU countries to incorporate flat prints
in their ePassports. That consolation is short-lived. According
to the NAO's February 2007 report: "The UK is not obliged
to comply with the EU regulations as it is not a signatory of
the Schengen Agreement but has decided to do so voluntarily"
(para 1.7). Why has the Home Office volunteered without debate
to spend taxpayers' money deploying a technology which is known
not to work?
20. Further, according to the NAO report:
"... although there is spare capacity on the chip [in the
ePassport] to store two fingerprints, the current model of chip
has insufficient capability to accommodate the enhanced operating
system and electronic key infrastructure required to protect fingerprint
data" (para 3.14). So, in order to comply with this directive,
which we do not need to comply with, to deploy identification
technology, which does not identify people, at great expense to
the taxpayer, we will have to recall the 2.2 million ePassports
issued by September 2006 (para 2.1), and all the ePassports issued
subsequently, and reissue them with bigger chips.
21. In his foreword to the November 2005
Cabinet Office paper on transformational government,10 the Rt
Hon Tony Blair MP, then Prime Minister, said: "But most of
all we have to have the right people with the right professional
skills to plan, deliver and manage technology based change".
The examples above of illogical planning, delivery and management,
suggest that we do not have the right people and that we should
therefore abandon the ID cards scheme and the plans for transformational
government based on them before any more taxpayers' money is wasted
and before it becomes impossible to respect the government.
1 Documents employers should use to check
the right to workChanges to the law on preventing illegal
working: short guidance for United Kingdom employers, April
2004, Home Office: IND Corporate Communications
2 Identity Cards Act 2006first section
37 report to Parliament about the likely costs of the ID cards
3 Feasibility Study on the Use of Biometrics
in an Entitlement Scheme, Tony Mansfield and Marek Rejman-Greene,
Version 3, February 2003, http://dematerialisedid.com/PDFs/feasibility_study031111_v2.pdf
4 ID technology "must be foolproof",
5 Identity and Passport Service: Introduction
of ePassports, National Audit Office, 7 February 2007, http://dematerialisedid.com/PDFs/0607152.pdf
6 Iris use dropped in ID card plans, http://www.itweek.co.uk/computing/news/2171789/iris-dropped-id-card-plans
7 Securing the UK Border Our vision
and strategy for the future, Home Office, March 2007, http://www.ind.homeoffice.gov.uk/6353/aboutus/Securing_the_UK_Border_final.pdf
8 Identity Card Technologies: Scientific Advice,
Risk and Evidence, House of Commons Science and Technology
Committee, 20 July 2006, http://dematerialisedid.com/PDFs/1032.pdf
9 UK Passport Service Biometrics Enrolment
Trial, Atos Origin, May 2005, http://dematerialisedid.com/PDFs/UKPSBiometrics_Enrolment_Trial_Report.pdf
10 Transformational GovernmentEnabled
by Technology, Cabinet Office, November 2005, http://www.cio.gov.uk/documents/pdf/transgov/transgov-strategy.pdf
4 June 2007