Comments should be sent to:
Stephen Harrison
Entitlement Cards Unit
Home Office
50 Queen Anne's Gate
LONDON
SW1H 9AT
Or they can be sent via email to:
entitlementcardsunit@homeoffice.gsi.gov.uk

Executive summary.

Such a card will either be too powerful, and hence too restrictive of use - becoming a mandatory ID card and encouraging organised crime - or too weak and thus overly expensive for the benefits it would bring.

Rationale

1. The invasion of privacy is untenably high. A single national database would present data mining opportunities such as those currently being explored by the US 'Home Security Agency'. It would, on a more mundane level, present a huge temptation to sell the data for marketing purposes - and a single target for criminal activity.
2. Although initially limited in scope, the plans presented here all aim to extend over time. This extension is being presented as limited - however there appears to be nothing to limit this trend. What would prevent such cards being used to clock in and out at your workplace and home (to enable the electricity, to stop the theft from your meter, would doubtless be the explanation given) - thus creating a single database of where everyone in the country purports to be at all times.
3. The cost burden is being estimated. Every government IT project has overrun both its time constraints and its budget. Should such a system be successful, it would risk a great many jobs - and this will lead to a great resistence to its implementation.
4. The problems it is intending to fix are, in my opinion, being overstated:
   1. The number of cards being carried. Most people only need to carry a single banking card and a drivers licence. They may need to be able to locate a store card and a passport. The burden is in no way huge - a wallet is needed even if you reduce the number.
   2. Illegal immigrant workers. There are plenty of laws already in place - proof of non payment of taxes should be sufficient. In addition, simply legalising free immigration and encouraging the creation of more jobs should be advantageous to the country.
   3. The difficulty in multiple sign on's when interacting with the government. I do not believe that most people interact with many government services at once very often. If officials within a single building are unable to recognise each others authority then this is a problem with the organisation of agencies within that building - not with the authentication of that person.
   4. Availability of services. The only situation I see that this applies is if someone from one area finds themselves in another and in need of a service. The ability for one office to check the details of a person at another would be simpler to implement - and in any case, the remaining portion of the document suggest that for (mostly good) security reasons, people would have to notify agencies when their details changed.
5. With respect to that last point - I would suggest that this card would serve to prevent free movement within the country. And, perhaps more importantly in this age, within the EU. A native german is supposed to be able to take a job here with no barriers, and vice versa. The waiting time for a card would limit this movement. Attempts to rectify this would open up a new set of loopholes.
6. The expense would amount to a poll tax - albeit a small one. Attempts to make this scheme pay for itself, by cost savings or private enterprise buy in open up job losses, privacy concerns and a great chance for criminal abuse.
7. A single system means a single point of failure. Currently a stolen identity has a chance to be uncovered every time they make a transaction. With a single card they would be able to exploit a great many systems within a very short time. The risk of this offsets the potential cost savings by an order of magnitude in my opinion.
8. The elderly (who would require this card in order to draw their pensions) would seem to be unfairly targetted for the cost burden. Many elderly persons do not hold driving licences or valid passports.

Point by point objections to comments:

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(ii) establish for official purposes a person's identity so that there is one definitive record of an identity which all Government departments can use if they wish.

What possible public benefit does this carry? How would it serve beyond both departments knowing the name and social security number?

Why, in short, must such information be carried by the individual concerned - rather than by the governmental departments in question?

(iii) help people gain entitlement to products and services provided by both the public and private sectors, particularly those who might find it difficult to so do at present.

In what way does a small rectangle of laminated card make it easier for a disabled person to travel to the social security office?

If you mean that it would aim them in convincing officials that they are due for those benefits - it is my experience that the difficulties there lie in convincing the officials that you are entitled to those beenfits, not convincing them that you are the person that you say you are.

Also, such a card (and associated databases) would seem to me to be a positive barrier - since changed circumstances would doubtless take time to filter through the system.

(iv) help public and private sector organisations to validate a person's identity, entitlement to products and services and eligibility to work in the UK.

Private Sector? I don't think I need to point out the many potential abuses here.

2. The Government does not wish to consult on the introduction of a compulsory scheme, by which it means a card which everyone would have and be required to carry at all times.

This scheme appears to be voluntary only in that you do not have to carry the card if you do not wish to be able to take advantage of any service offerred by the government or the private sector. I think we can ignore this claim from here on.

Potential Uses of a Card 3. By giving a clear indication that the holder of an entitlement card is lawfully resident in the UK, a card scheme could be a powerful weapon in combating illegal immigration.

But such a card is voluntary, so such an illegal... ok, sorry.

An illegal immigrant is not able to claim many government benefits anyway. If you do not intend to randomly stop people on the streets and ask to see their cards, then this will add no benefit.

The perception that once people manage to enter the country illegally they can work and obtain benefits and public services with impunity adds to the 'pull factor' which draws people into organised networks of people trafficking. A universal entitlement card scheme would give greater credibility to legal migration routes into the country. It would reduce the burden on legitimate employers who already check the immigration status of their employees by giving them a single, easily understood card to check. It would also help to prosecute unscrupulous employers who employ illegal workers for less than the minimum wage and undercut legitimate companies.

First, I do not believe that the illegal immigration problem is as large as the media makes itout to be. However - any workplace already requires a social security number, in order to handle PAYE. Adding a second thing to check would surely increase the burden, not decrease it.

4. The potential benefits of an entitlement card scheme go much wider than an immigration control measure. It could provide a more efficient basis for administering public services by avoiding the need for people to provide the same personal information time and again to a range of public services. There would also be savings for service providers as there would be a single definitive source of information about people's identity and possibly a unique personal number for everyone registered on the system.

Single sign-on authentication is a worthy goal. But it is a fairly rare circumstance that a person has to authenticate themselves to several different agencies at once. Typically, the authentication would take place over a period of days - and each instance would require production of the card, confirmation of certain details etc. etc. Which would be the situation as it is now, with the disadvantage that loss of the card would prevent a person being able to continue the exchange until they acquired a new one - whereas the individual details only require (say) six out of eight pieces of paper to be present for an agency to accept your identity.

5. A card scheme could help prevent people becoming victims of identity theft and identity fraud, for example preventing parents suffering the distress caused when a criminal assumes the identity of their deceased child. A card could allow people to travel around Europe without the need to carry a passport book and might be useful to young people to help prove their age when purchasing age-restricted goods and services.

Whatever mechanisms exist to create a legitimate card could be used to create an identity fraud. The harder this was made, the harder it would be to correct errors. Imagine the pain of a couple being told that their daughter was legally dead and thus could not attend school.

6. The arguments for and against entitlement or identity cards have been made many times since the wartime scheme was abolished in 1952. The benefits of improving the provision of public services and reducing illegal immigration and identity fraud need to be considered alongside the arguments against a scheme. People might be concerned that a card scheme might allow the Government to link together all of the information it held on individuals. If a card scheme was not secure, it could itself become the source of increased levels of fraud if cards could be forged. The Government recognises that there are strongly held views on both sides of the argument and wishes to see these explored fully during the consultation period.

This is a valid point. Consider it carefully, and realise that NO large system has EVER been made both easy to access AND totally secure.

9. In order to ensure that a card scheme would provide a greater level of protection against identity fraud, it is proposed that the checks currently undertaken for driving licence and passport applications should be strengthened. One of the most difficult parts of a person's identity to counterfeit is their historical background which can only be built up over time for example as they pass their driving test, apply for a passport and open bank accounts. The method of issuing entitlement cards would make greater use of checks on this type of information.

This is worrying. In what way is announcing the presence of my bank accounts a valid invasion of privacy?

You also remove from the scheme people who have never opened a bank account, driven a car or applied for a passport. Which would include everyone under voting age for a start - they would presumably need some mechanism to gain their 'first card'. This would doubtless be an open invitation to identity fraud.

10. Another option which the Government would like to explore is the recording of biometric information as part of a card scheme. This would take the form of recording a fingerprint scan or the image of a person's iris (the coloured ring around the eye) as well as a digital photograph which is already taken for passports and driving licences. There would be strict controls on how this information was used. If it proved feasible and cost-effective, recording this information would greatly reduce the ability of fraudsters to create multiple false identities and provide a powerful way for people to prevent their own identities from being stolen. However it is also important that the introduction of this technology should be acceptable to the general public and the Government would like to use this consultation exercise to seek people's views. This means whether it would be acceptable in principle for this information to be recorded and also whether it would be acceptable in practice as people would need to go somewhere where the appropriate recording equipment was installed when they applied for a card.

No no no no NO!

Please - take a short look at the proven flaws in retina monitoring systems (their high failure rates) for example. Not to mention the high costs of such equipment.

Also, the inability of such a system to authenticate anyone whilst the central systems are down, or innaccessible (which other governmental networks can attest happens 1-3 times a year at best) should leave you understanding that the best authenticator of a person is another person.

11. The Government would ensure that a scheme complied with the requirements of the Data Protection Act 1998 by setting out the purposes of the central register on which a card scheme would be based in legislation and drawing up regulations for the use of any unique personal number which might be given to every person who registered. Under the suggested scheme set out in this paper, the central register would not become the depository for a wide range of information held by different Government Departments or Agencies about individuals. The Government is clear that protection against intrusion or unauthorised access to personal information is crucial if any such scheme were to work.

This would allow, for example, any person to gain access to their own biometric data. Which they could then sell on - allowing organised crime to exploit whatever flaws might exist in the system.

12. An entitlement card would probably be issued in the form of a smartcard which incorporated a simple memory chip. This would allow other organisations to make more use of the card which in turn would help it become more useful to card-holders.

Um. Smartcards are not sufficient encryption mechanisms. Talk to the cambridge university laboratories.

14. Even if the net costs of a scheme were as high as £1.5 billion, these could be recouped by increasing passport and driving licence fees and by charging a fee for the non-driving licence/ entitlement card.

This is an obvious fact. No matter how high the costs are, they could be recouped by making money. Given that the card will end up being voluntary in name only - this amounts to a poll tax.

A card scheme would entail: * establishing a secure database which could potentially hold core personal information about everyone who is lawfully resident in the UK.

There is a single big problem here. Any people currently holding one or more illegal identities will be able to legitimse them. I suspect that in twenty years time, whole families of fake identities will exist. Also, this scheme includes no planning for disaster. What happens in the event of a war? A single database is fragile, and it would take a long time to recover rudimentary service in the event of a war, disaster or criminal or terrorist action.

* be more convenient for those using services, for example through not having to provide the same information many times over to different Government agencies and through not having to carry a number of cards to access a range of services.

Reducing the number of cards carried would be a minimal benefit at best. You would also need to convince the banks and other private organisations (my book club? the video rental shop?) to use it. Either a low barrier would be set, causing huge costs - or a high barrier, negating the small benefit. I have already objected to multiple authentication. It would be more beneficial for people in the same building to talk to one another and send on photocopied (or electronic) details of the conversation they have had so far, rather than put that burden on the person in question.

* ensure that people who might have difficulty in obtaining entitlement to services can do so more easily on production of a card.

The (much needed) improvements in clarity of "what I am entitled to" and "Yes, this person is entitled to this" are orthogonal to this discussion.

1.4 If a card was issued subject to stringent security checks such as those associated with passports and driving licences, public and private sector organisations might also use the card to help reduce levels of identity fraud. There are other measures to combat identity fraud which the Government could implement on a faster timescale and at lower cost than an entitlement card scheme. This consultation exercise also seeks views on some of these measures.

If the identity checks on passports and drivers licences are stringent, why is there a problem with identity fraud and illegal immigration?

For example a card scheme could be used to verify access to particular services or facilities where there is a need to establish identity to a high degree of confidence for example benefit claims

Ah. So this is to be a "You are a second class citizen"'s card.

i. e. there would always be a way to gain entitlement to a particular service without a card.

Emphasise that 'ALWAYS' and most of my objections vanish. Not all, but most.

But the tendency is for control to be extended, and not relaxed. Although it might not be made compulsory in this term of parliment, or the next - can you guarantee that it would not become so in twenty years time?

* penalties for failure to notify changes to personal details for example change of address or change of name.

Due to the nature of my work, I move house roughly once every nine months. I would have to obtain a form, and obtain proof of my new address, and send it off and hope that the royal mail doesn't lose it and end up unable to access services until my new address has cleared through the system? And such services might include all access to my bank, even my ability to rent a video?

2.18 As one of the primary suggested uses for an entitlement card scheme is as an immigration control measure to help combat illegal working, any legislation would be a matter for the Westminster Parliament. However the Westminster Parliament could not create specific criminal offences in Scots Law associated with an entitlement card scheme (for example making a fraudulent application for a card) without the consent of the Scottish Executive and Parliament.

I hate to seem naive - but would it not be more beneficial to create more jobs - rather than to fight immigration?

The Government believes that denial of service would be sufficient means to ensure that cards were widely held provided that a wide range of service providers adopted the card.

Thus making a 'voluntary' card 'universal'. Let us forget the pretense of 'Voluntary' - for a voluntary card to be of any benefit it must be 'Universal' And hence, in effect, mandatory. By all means, let us have a debate - however, please do not redefine terms in order to skew the balance of opinion in your favour.

It is already an offence to fail to inform DVLA of a change of name or address.

I hold a provisional driving license that I ordered many years ago and have never used (nor any wish to use) Should I turn myself in to the police for arrest because I forgot about it?