The government issued a little-reported document this month on ID cards. It was quietly published when the home secretary Jacqui Smith announced that some volunteer members of the public in Greater Manchester would be the first to receive ID cards in November.
These are 10 things from the document, “Identity Cards Act Secondary Legislation – An Impact Assessment”, which might not be generally known:
- The ID Cards Act 2006 imposes on citizens a duty to update information held on them on the National Identity Register (NIR). Cardholders can receive civil penalty fines if they fail to update information held about them on the NIR or notify the Identity and Passport Service if their card is lost or stolen. Citizens may also be in breach of legislation if they fail to notify a change of address within three months. It is open to the government to charge a fee for updating the register.
- An individual’s entry on the NIR can be given to “government departments or other public sector organisations without the consent of the individual provided they [departments and agencies] have been approved to do so by parliament under secondary legislation”. Secondary legislation does not need any specific parliament approval. The power to enact it has already been given under primary legislation.
- The Home Office will allow ID cardholders to check the information held on them on the NIR. “Right from the beginning, individuals will be able to obtain a copy of what is held on their record in line with subject access rights under the Data Protection Act.” Much information about individuals will not be on the register itself but brought together from various databases when needed.
- The NIR will keep a record of which organisations have checked an individual’s record and when, though not the reason or the outcome. The NIR audit trail will show the “specific branch” of a bank which had made a check, for example. The Home Office says this is necessary to “help ensure that inappropriate checks are not made against the NIR”. The NIR audit may be given to HM Revenue & Customs and other government departments “only where it is necessary for the prevention or detection of serious crime”.
- The NIR will not hold a vast amount of “new kinds of data”, but the document does not explain what this phrase means.
- Private sector organisations may be given information from the NIR with the individual’s consent. Insurance companies may make a condition of taking out a policy that you give your consent.
- The ID cards scheme has not been subjected to a formal privacy impact assessment (PIA), as set out by the information commissioner. The PIA would have set out the scheme’s potential privacy issues and risks, as perceived by all stakeholders. The Home Office says that there has been no full PIA because the decision to roll out ID cards “was taken before these developments” – that is the introduction of the PIA. However, the information commissioner says that a PIA can be undertaken after a project has started.
- 8) The initial £30 fee for an ID card will be reviewed “before the high volume roll-out of identity cards begins in 2012”. The review will take into account the fact that the Identity and Passport Service must cover its costs. The costs of ID cards and passports have been combined so it is possible that fee rises for new and replacement passports will subsidise the cost of ID cards.
- The document says recent research “shows that 71% of those interviewed trust the Identity and Passport Service to look after their personal information”. This suggests that nearly a third do not trust the government with their ID data or do not know whether to trust it – a sizeable minority.
- The cost to the public sector and businesses of equipment to read ID cards, integrate systems with the NIR, or obtain information from the register is put at £7bn. The figure is not broken down and, as it is over 30 years, it is unlikely those in the current administration will be in government in 2039 to be accountable for the figure.