There have been some clarifications ,from Des Browne, Minster for Citizenship and Immigration at the Home Office, during the first four sessions of the Standing Committee B debates on the Identity Cards Bill, which will have an enormous impact on the feasibility, complexity, privacy, security and cost of the National Identity Register and ID Card scheme. Thanks to the extra technical complexity which the Government is piling onto the scheme, Information Technology hardware, software and consultancy suppliers could potentially make a fortune.
Theses were not included in the Draft ID Cards Bill, and it was unclear if the Government meant Digital Signatures , Public / Private Keypairs, Public Key Infrastructure etc. which would have made some sense for internet or mobile phone use of Government or Commercial services.
However, despite the existance of the Electronic Communications Act 2000 it seems that the Government is "only" thinking of digitised and/or paper based signatures.
Those people with experience of, for example, the digitised Document Image Processing of Bank Account Mandates, will recognise the extra complexity, scale and cost which the Government have, obviously without much thought, just added to the centralised IT infrastructure which will be required to run this scheme. The champagne corks must be popping throughought the Document Image processing industry, was the late addition of "signature", of which there had been no previous mention in any of the previous "consultations" or the Draft ID Card Bill, the result of commercial lobbying ?
"Amendment No. 26 would remove the ability to store a signature on the register and would seriously reduce the benefits of the identity card scheme and harm its operation. Following publication of the draft Bill, signature was added explicitly to schedule 1, which deals with information that may be recorded in the register, to put beyond doubt the fact that we need to be able to record signature. There are three key reasons for that. First, most existing identity documents such as passports or driving licences incorporate a signature as standard. Secondly, the provision of a signature for ID cards also supports benefits in visual verification for organisations such as financial institutions that hold signatures in their own systems and use them as an identifier. In that sense, the signature is another identifier, in addition to biometrics. Thirdly, the provision of a signature provides a form of consent from the individual during the enrolment process, and it is appropriate that consent in that fashion be retained."
Or will more sophisticated "biometric digitised signatures" be used i.e. involving a pressure pad or PDA style touch screen and stylus, which measures the speed and or /pressure of the process of writing a signature , as well as the resultant ink on paper image ?
It is not clear if you will face a "civil penalty" if your signature changes for health reasons or out of choice.
How are digitised signatures to be checked by Government or Commercial service providers ?
If they are not going to be checked, then why bother to collect them in the first place ?
Or is the plan simply to print an image of the signature on the ID Card, which will add another 10 minutes or so to the enrolment process ?
If people rely on such a visual signtaure as evidence of identity, then why bother with the more expensive biometrics at all ?
Des Browne also claimed that any counter-signers of application forms for "designated documents" e.g. Passports would also have their signatures stored on the National Identity Register.
"Amendment No. 29 would remove the ability to hold details of counter-signatories on the register. In order to counter fraud, it will be important to be able to check whether there has been a fraudulent application. It will be possible to check all the circumstances surrounding the original application, including the details of the counter-signature, to determine whether the counter-signatory was complicit in a false application. Information about counter-signatories is currently held, for example, with passport application details."
By rejecting this amendment, which deals with data to be stored on the National identity register and/or the ID card, Des Browne presumably means this means that part or all of the application form is going to have to be digitised, exacyly as with Bank Account Mandates etc., and not something which the Passport Office does at the moment (they do digitise the phototgraphs which are submitted with Passport application forms)
Why it is necessary to clutter up the online National Identity register with paper application forms, potentially including those from other Government Agencies e.g. the Driver Vehicle Licensing Agency for alleged fraud investigation purposes is a mystery. Surely in such investigations it would be necessary to examine the original paper application forms forensically to see if they have been forged or altered ? Any such forensic evidence will have been lost if the forms are digitised and then destroyed. If they are not destroyed, then why bother digitising them for this purpose in the first place ?
There is no need to try to duplicate the data and procedures of each of the agencies which issue "designated documents" into the centralised national Identity register, but that is what this flawed Identity Cards Bill seeks to do. This is a classic example of bureacratic function creep and costly duplication of systems.
View Des Browne's digitised signature - how do you know if this is genuine or is a copy ?
One of our complaints over the last 3 years or so has been that talk of "fingerprints" is a deliberately evasive if you do not specify whether you mean a single thumbprint, or all fingers and thumbs and palm prints, which is what the current criminal record fingerprint legislation allows for.
"Amendment No. 152 would mean that an individual might be required, for the purposes of renewing a card under clause 9, to allow not just fingerprints and other biometric information about himself to be taken and recorded, but all his fingerprints. The hon. Member for Woking and those who support him should be satisfied that the amendment is not necessary, as we could already require any biometric that the Secretary of State thinks fit for the purposes of verifying the information placed in the register. It is our intention to use not eight but all 10 fingerprints for that purpose. That is how the biometric trial was configured, and that is what we intend for the future, for the obvious reason that that increases security."
You simply cannot fit
- The digitised image of a "head and shoulders" photograph, to comply with the ICAO machine readable travel document standards (N.B. take a look at the size of a typical digital photgraph file from a typical digital camera - it could easily be 300 - 500 Kb on its own !)
- The facial recognition reference point "minutiae" maps of such a "head and shoulders" photograph,
- The digitised fingerprint reference point "minutiae" maps of 10 fingers/thumbs
- The two iris scan codes
- The digitised image of a pen and ink handwritten signature
- The speed/pressure reference point "minutiae" maps of digtal pressure pad and stylus signature
- The digitised counter-signatures on the application forms for "designated documents" e.g. Passport applications
- Any necessary smart card internal cryptographic checksums, digital signatures, certificate revocation lists etc.
- The as yet unspecified user submitted "free text" information which can be submitted on a voluntary basis e.g. blood group, organ donor status which will be useless in an emergency, and in theory should be available via the new National Health Service "data spine" anyway, but which many people will wish to include anyway.
- Any or all of the other 51 Registerable Facts categories and/or transaction history (e.g. all previous names, addresses, dates of residence) which may be on the centralised National Identity Register and/or in the Smart Card electronic chip, and/or printed on the face of the Smart ID Card. Even if not all of these categories of data are rolled out initially, precious tamper resistant Smart card memory space has to be allocated to the possability of them being added in the future during the lifetime of a particular card, otherwise the costs and inconvenience of having to re-Register and re-Enrol millions of people will have to be borne - who pays for such a "technology re-fresh" ?
into the standard 16Kb or 32Kb of tamper resistant memory of standard Smart Cards which are on the market from the likes of the market leaders such as Schlumberger/Ataxo or GEMPlus or Giesecke and Devrient (none of which are British companies).
It may not even be possible to do this with 64Kb or 128Kb Smart Cards.
N.B. it does seem to be strange that Flash Memory for multimedia purposes is available cheaply in tens of Megabyte capacities, but somehow the Smart Card industry is still stuck with Kilobytes of memory, presumably this is entirely a commercial marketing decision rather than a technological one.
None of the more modern, higher capacity Smart Cards have been on the market long enough to determine their real 5 or 10 year failure rates due to "wear and tear" e.g. we have witnessed credit card Chip & PIN cards where the chip has debonded from the plastic after a few weeks of use. Astonishingly, any such failure of a UK ID Cards, under Clause 13 of the Identity Cards Bill, is your fault, not the manufacturer's, or the Government's fault, and you face a fine or prison even if you are not aware that the device is faulty (no defence of "reasonableness" or "ignorance").
This is for a single UK Passport type application. If the ID Card/Passport has to incorporate other digital "designated documents",
e.g. electronic visas or residence permits etc from other countries, then it will run into the same problems as the European Union Biometric Visa plans.
This all has huge unit cost implications, which the Government have still refused to spell out.
Questions for fellow cypherpunks:
- Is it desirable to demand that the voluntary user submitted additional information field contains user encrypted data ?
- Will any user free text/notes fields or operator free text/notes on the NIR or the Smart Card be used as a secret flag or subliminal channel for racial or political discrimination purposes etc.