My response sent to the DIGITAL ID public consultation undertaken under the SUNAK Tory government. Sent via email on 28th January 2023

I am sending you my comments in the form of an email, rather than answering the multiple choice questions in your survey. This is because I find your survey to be rather opaque and confusing to say the least. Many of the questions are either loaded or exceedingly tricky to interpret. The scope of the survey also seems to be extremely limited. I can only conclude that no meaningful survey was ever intended. A digital ID raises serious human rights issues. These must be seriously addressed when Government desires one single digital identity used for authentication in multiple contexts, which can lead to excessive and all pervasive profiles on individuals. From a privacy angle there are serious concerns about the centralisation of such large amounts of personal information. This would be an attractive target for cybercriminals. Governments might well promise protection against data breaches, but prove to be all too fallible in this regard. Not long ago the world’s largest digital ID framework in India was shown to be compromised. Consequently, it should be basic common sense that for a digital ID system to work effectively without becoming prey to hacking that it should be decentralised as well as also observing sound digital security policies. A digital ID should not be mandatory. Any individual should have the right to opt out of the digital ID, without prejudice or negative repercussions. Whilst the UK Government document does say that it will not be mandatory, this is not necessarily reassuring. The UK as well as other governments around the world has demonstrated all too clearly in the last few years just how willing they are to break promises. Trust in government has collapsed for many people. The digital ID must not become compulsory in all but name, in which people increasingly find it difficult to access services if they do not actively consent to it. A much wiser approach in regard to any role-out of any digital ID technology would be to observe the following four core principles. Firstly, ensure decentralisation. Secondly, ensure data minimisation. Thirdly, ensure consent at all times, not merely during the onset of the program. Fourthly, ensure limited access to the data. I can see no obvious signs at the moment that the UK government is at all capable of grasping any of these core principles. We should not be in any rush to follow the example of the Australian government’s myGov mobile app launch, with integrated biometric facial recognition log-in capabilities and a digital wallet. The app is designed to become a single ‘digital wallet’ to manage identity and provide mobile access to both government and private sector services. Biometric checks such as fingerprint verification, QR codes and six-digit pins are also involved here. Where do we go next (in the UK as well as other countries) in the fast march to a centralised digital ID? Some might fear, with some justification, that the digital ID would before too long be linked to a Chinese-style social credit system, determining who would have full participation in society and those who would have restricted participation. In conclusion, I am emphatically opposed to the digital ID system that the UK government seems to want to bring in.

Paul Cardin


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About Wirral In It Together

Campaigner for open government. Wants senior public servants to be honest and courageous. It IS possible!
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