1. How many countries use ID cards ?

Identity (ID) cards are in use, in one form or another in numerous countries around the world. The type of card, its function, and its integrity vary enormously. Around a hundred countries have official, compulsory, national IDs that are used for a variety of purposes. Many developed countries, however, do not have such a card. Amongst these are the United States, Canada, New Zealand, Australia, Ireland, the Nordic countries and Sweden. Those that do have such a card include Germany, France, Belgium, Greece, Luxembourg, Portugal and Spain.
The use of sectoral (specific purpose) cards for health or social security is widespread, and most countries that do not have a national universal card, have a health or social security card (in Australia, the Medicare Card, in the United States, the Social Security number), or traditional paper documents of identity. The reverse is also true. In Sweden, while there exists a ubiquitous national number, there is no single official identity card. 1

Generally speaking, particularly in advanced societies, the key element of the card is its number. The number is used as an administrative mechanism for a variety of purposes. In many countries the number is used as a general reference to link the card holders activities in many areas.

An analysis of identity cards around the world reveals a number of interesting patterns. The most significant of these is that virtually no common law country has a card. Nor does the economic or political development of a country necessarily determine whether it has a card. Neither Mexico nor Bangladesh have an ID card. And, until this year, India had no card (even now, the card, strictly speaking, is a voter registration card rather than a national ID card). Generally speaking, however, the vast majority of developing countries have either an ID card system or a document system,often based on regional rather than national authorization. 2

In many countries, identification documents are being replaced by plastic cards, which are seen as more durable and harder to forge. Card technology companies are well organized to conduct effective promotion of their product, and companies have moved into the remotest regions of the world. Many Asian and African nations are replacing old documents with magnetic stripe or bar coded cards. The South African Passbook is being replaced by a card. The UK drivers license is also being replaced by a photo ID card from 1996. The change from one form of ID to another is invariably accompanied by a change to the nature and content of data on the document.


2. What are the main purposes of ID cards?

ID cards are established for a variety of reasons. Race, politics and religion were often at the heart of older ID systems. The threat of insurgents or political extremists, and the exercise of religious discrimination have been all too common as motivation for the establishment of ID systems which would force enemies of the State into registration, or make them vulnerable in the open without proper documents. In Pakistan, the cards are used to enforce a quota system, In China, they are used as a tool of social engineering.
In the United Kingdom, current proposals for a national ID card are fuelled by the need to develop a document which is acceptable to other European countries, as well as a belief that the scheme might help fight crime. In Australia, the purpose of the proposed card was to fight tax evasion, and, in New Zealand, to establish Social Welfare entitlement. The Dutch card has the dual purpose of helping to improve government administrative efficiency, while playing a key role in dismantling border controls. 3

At the heart of such plans is a parallel increase in police powers. Even in democratic nations, police retain the right to demand ID on pain of detention.

In recent years, ID cards have been linked to national registration systems, which in turn form the basis of government administration. In such systems - for example Spain, Portugal, Thailand and Singapore - the ID card becomes merely one visible component of a much larger system. With the advent of magnetic stripes and microprocessor technology, these cards can also become an interface for receipt of government services. Thus the cards become a fusion of a service technology, and a means of identification.

This dual function is expressed well by one Philippines Senator in the introduction to her 1991 ID card Bill as an integrated relationship between the citizen and his government. 4


3. What are the main types of ID systems in use?

Broadly expressed, there are three different forms of ID card systems :

1. Stand Alone documents
2. Registration systems

3. integrated systems


Stand Alone ID documents are issued in primitive conditions, or in environments which are subject to sudden economic or political change. Often, areas under military rule or emergency law will issue on the spot ID cards which are, essentially, internal passports. Their principle purpose is to establish that a person is authorized to live in a region.
The majority of ID systems have a support register which contains parallel information to that on the card. This register is often maintained by a regional or municipal authority. In a minority of countries, this is a national system. Even countries such as France and Germany have no national ID card register. Germany has constitutional limitations on the establishment of any national number.

Virtually all card systems established in the past ten years are Integrated systems. They have been desi gned to form the basis of general government administration. The card number is, in effect, a national registration number used as a common identifier for many government agencies.

It is interesting to note that residents of countries which have ID documents or papers, often refer to these in the English as ICs or Identity cards. The Afghan Tazkira is a 16 page booklet, but is often referred to as a card. Likewise, in Poland, where the form of ID is a passport-like booklet called 'Dowod osobisty' (or, literally, personal evidence it is translated universally as a card.


4. What information do the cards contain?

The majority of cards in use in developed nations have the holders name, sex, date of birth, and issuing coordinates printed on the card itself. An expiry date, and number is also embossed, along with a space for a signature. A minority of sectoral cards include a photograph.5 Official cards issued by police or Interior Ministries generally do include a photograph, and in many cases, a fingerprint.
In Brazil, for example, all residents are obliged to carry at all times a plasticated flexible card the size of a credit card bearing a photograph, thumb print, full name and parents' names, national status (Brazilian national or alien resident) and a serial number.

In Chile, it is a small plastic card with photograph, names, date and place of birth, signature, and personal number. The Korean 'National Registration Card' shows name, birth date, permanent address, current address, military record, issuing agency, issued date, photograph, national identification number, and prints of both thumbs. The Malaysian identity Card has the date of birth, parents name, religion, ethnicity, sex, physical characteristics, place of birth and any other identification mark on the reverse side. The front face carries the photograph, fingerprints, and IC number.

The Pakistan card carries a large amount of data, including photograph, signature, card serial number, government official's signature, Date of issue, DRO/Post office number, ID Card number, name, father's name, Temporary Address, Permanent Address, identification marks, and date of birth

The German "Personalausweis". is a plastic ID card which contains, on the front side, name, date and place of birth, nationality, date of expiration, signature and photo. The name, date of birth and number of the card are machine readable (ocr). On the back side are address, height, color of eyes, issuing authority and date of issue. Addresses are changed by putting a sticker on the old address.

The Italians have a larger format card (three by four inches) containing Identity number, name, photo, signature, fingerprint, date and place of birth, citizenship, residency, address, marital status, profession, and physical characteristics

In a small number of cases, notably Singapore and some Asian nations, cards contain a bar code, which is seen by authorities as more reliable and durable than a mag stripe. The French are also moving toward a machine readable card.


5. What is the financial cost of an ID card system?

In the Philippines, the United Kingdom and Australia, the cost of implementing an ID system has been at the forefront of political and public opposition to nationwide schemes. The Philippines proposal relied on government estimates that were drawn, as is often the case, from estimates calculated by computer industry consultants. These were found to under-estimate the true cost by eight billion pesos over seven years.6 The proposal lapsed because of this factor.
In Australia, the cost of the proposed ID card failed to take into account such factors as training costs, administrative supervision, staff turnover, holiday and sick leave, compliance costs, and overseas issue of cards.. Other costs that are seldom factored into the final figure (as was the case in Australia( are the cost of fraud, an underestimate of the cost of issuing and maintaining cards, and the cost to the private sector. As a consequence, the official figure for the Australia card almost doubled between 1986 and 1987.

Private sector costs for complying with an ID card are very high. The Australian Bankers Association estimated that the system would cost their members over one hundred million dollars over ten years. Total private sector compliance costs were estimated at around one billion dollars annually.

The official figure for the Australia card was $820 million over seven years. The revised estimate including private sector and compliance costs, together with other factors, would amount to several times this figure.

The UK Governments CCTA (Information Technology Center) advised that a national smart ID card would cost between five and eight pounds sterling per head 7, but this figure does not include administration, compliance etc. When he announced the introduction of a national ID card in August 1996, the Home Secretary, Michael Howard, advised that the cost as likely to be at least double the CCTA estimate (ten to fifteen pounds).8


6. Can ID cards assist law enforcement?

Although Law and Order is a key motivation for the establishment of ID cards in numerous countries, their usefulness to police has been marginal. In the UK. Home Secretary Michael Howard told the 1994 Tory Party conference that he believed an ID card could provide an invaluable tool in the fight against crime. This claim was toned down somewhat during the gestation of the proposal.
Howard's claim received little support or substantive backing by academic or law enforcement bodies. The Association of Chief Police Officers (ACPO) said that while it is in favor of a voluntary system, its members would be reluctant to administer a compulsory card that might erode relations with the public. Dutch police authorities were not generally in favor of similar proposals in that country, for much the same reason. 9

According to police in both countries, the major problem in combating crime is not lack of identification procedures, but difficulties in the gathering of evidence and the pursuit of a prosecution. Indeed, few police or criminologists have been able to advance any evidence whatever that the existence of a card would actually reduce the incidence of crime, or the success of prosecution. In a 1993 report, ACPO suggested that street crime, burglaries and crimes by bogus officials could be diminished through the use of an ID card, though this conflicted with its position that the card should be voluntary.

In reality, only a national DNA database (such as has just been opened in Britain) or a biometric database (such as is being proposed in Ontario) might assist the police in linking crimes to perpetrators.

Support along these lines for the introduction of cards is also predicated on the assumption that they will establish a means of improving public order by making people aware that they are being in some way observed. Sometimes, cards are proposed as a means of reducing the opportunity of crime. In 1989, the UK government moved to introduce machine readable ID cards to combat problems of violence and hooliganism at football grounds. The general idea was that cards would authorize the bearer to enter certain grounds and certain locations, but not others. They could also be canceled if the bearer was involved in any trouble at a ground or related area. The idea was scrapped after a report by the Lord Chief Justice claimed that such a scheme could increase the danger of disorder and loss of life in the event of a catastrophe at a ground.

One unintended repercussion of ID card systems is that they can entrench widescale cr iminal false identity. By providing a one stop form of identity, criminals can easily use cards in several identities. Even the highest integrity bank cards are available as blanks in such countries as Singapore for several pounds. Within two months of the new Commonwealth Bank high security hologram cards being issued in Australia, near perfect forgeries were already in circulation.

This conundrum has been debated in Australia, the UK and the Netherlands. It relies on the simple logic that the higher an ID cards value, the more it will be used. The more an ID card is used, the greater the value placed on it, and consequently, the higher is its value to criminal elements.

There appears to be a powerful retributive thread running along the law and order argument. Some people are frustrated by what they see as the failure of the justice system to deal with offenders, and the ID card is seen, at the very least, as having an irritant value.


7. What impact do ID cards have on tax evasion and welfare fraud?

The need to develop measures to combat fraud have prompted the introduction of widescale, integrated, information technology in most developed countries. These strategies have sometimes involved the use of cards.
The cost of fraud can be significant, but the causes are often rooted deeply in human and organizational issues that technology may not be entirely capable of solving.

Benefits agencies around the world have identified key precursors to fraud. Three levels of fraud are often expressed, in order of significance, as:

False declaration, or non declaration, of income and assets (problems which are also components of non-declaration of income for tax)

Criminal acquisition of multiple benefits using false identification

More conventional fraud and theft of benefit payments


These conditions should be considered alongside numerous other factors which contribute to benefit overpayment, including clerical error and genuine misunderstanding about the terms of payment.
One of the central problems in responding to the question of fraud has been the general difficulty in assessing its nature and magnitude. Virtually no ethnographic research exists, and the data that do exist are drawn principally from internal and external audits, management reviews, and retrospective studies.10 Many methodologies have the effect of assessing risk, rather than quantifying actual fraud. No standard guidelines have yet been developed to assess the sort of information technology used in fraud control and identification.11 Additional problems are found with the definition of fraud, and the terms of audit, which often do not parallel the parameters of internal departmental cost/benefit analyses.12

Estimates of the extent of fraud on benefits agencies varies widely. The Toronto Social Services Department, for example, officially estimates fraud by way of false identity at less than one tenth of one percent of benefits paid13, whereas the Australian Department of Social Security estimates the figure at ten times that amount.14 Estimates of fraud vary widely between one tenth on one per cent of total benefits, to as high as four percent.15 Britain's popular estimate of one to two billion pounds is, in international terms, at the high end of the spectrum.

The Parliamentary Select Committee on the Australia Card warned that the revenue promises of the card scheme were little better than "Qualitative assessment" - in other words, guesswork. The Department of Finance refused to support the Health Insurance Commission's (HIC) cost benefit estimates (the HIC was the principle agency behind the scheme). Revenue was constantly revised downward, while the costs continued to rise. The Department of Social Security insisted that the ID card would have done little or nothing to diminish welfare fraud. In evidence to the parliamentary committee investigating the proposal, the Department said that much less than one per cent of benefit overpayments resulted from false identity. The Department decided that it would pursue other means of tackling fraud. The DSS in the UK argued against ID cards on the same grounds.

The Australian DSS estimates that benefit overpayment by way of false identity accounts for 0.6 per cent of overpayments, whereas non-reporting of income variation accounts for 61 per cent. The key area of interest, from the perspective of benefit agencies, lies in creating a single numbering system which would be used as a basis for employment eligibility, and which would reduce the size of the black market economy.


8. Can ID cards help to control illegal immigration?
Yes and no. Although the immigration issue is a principle motivation behind ID card proposals in continental Europe, the United States and some smaller developing nations, the impact of cards on illegal immigration has been patchy

The abolition of internal borders has become a primary concern of the new European Union. The development of the Schengen agreement between the Benelux countries, France, Spain and Germany calls for the dismantling of all border checks, in return for a strengthening of internal procedures for vetting of the population. France and the Netherlands have already passed legislation allowing for identity checks on a much broader basis, and other countries are likely to follow.

The establishment of personal identity in the new borderless Europe is a contentious issue, but is one which appears (to many people) to be a broadly acceptable trade-off for the convenience of greater freedom of movement within the union.

The use of a card for purposes of checking resident status depends on the police and other officials being given very broad powers to check identity. More important from the perspective of civil rights, its success will depend on the exercise of one of two processes : either a vastly increased level of constant checking of the entire population, or, a discriminatory checking procedure which will target minorities.

The two arguments most often put forward to justify the quest to catch illegal immigrants in any country are (1) that these people are taking jobs that should belong to citizens and permanent residents, and (2) that these people are often illegally collecting unemployment and other government benefits.

The image of the illegal immigrant living off the welfare of the State is a powerful one, and it is used to maximum effect by proponents of ID cards. When, however, the evidence is weighed scientifically, it does not bear any resemblance to the claim. When the Joint Parliamentary Committee on the Australia Card considered the issue, it found that the real extent of illegal immigrants collecting government benefits was extremely low. The report described a mass data matching episode to determine the exact number. Of more than 57,000 overstayers in New South Wales, only 22 were found in the match against Social Security files to be receiving government unemployment benefits. That is, 22 out of a state population of five million. The Department of Immigration and Ethnic Affairs (DIEA) had earlier claimed that the figure was thirty times this amount (12.4 per cent as opposed to 0.4 per cent of overstayers).

Indeed most immigration authorities worldwide base their estimates on qualitative assessment. Again quoting from the Australia Card inquiry It became clear that the estimates for illegal immigrants were based on guesswork, the percentage of illegal immigrants who worked was based on guesswork, the percentage of visitors who worked illegally came from a Departmental report that was based on guesswork....The Committee has little difficulty in rejecting DIEA evidence as being grossly exaggerated.



9. Do ID cards facilitate an increase in police powers ?

Generally speaking, yes. A Privacy International survey of ID cards found claims of police abuse by way of the cards in virtually all countries. Most involved people being arbitrarily detained after failure to produce their card. Others involved beatings of juveniles or minorities. There were even instances of wholesale discrimination on the basis of data set out on the cards.
While it is true that cards containing non-sensitive data are less likely to be used against the individual, cards are often alleged to be the vehicle for discriminatory practices. Police who are given powers to demand ID invariably have consequent powers to detain people who do not have the card, or who cannot prove their identity. Even in such advanced countries as Germany, the power to hold such people for up to 24 hours is enshrined in law. The question of who is targeted for ID checks is left largely to the discretion of police.

The wartime ID card used in the UK outlived the war, and found its way into general use until the early 1950s. Police became used to the idea of routinely demanding the card, until in 1953 the High Court ruled that the practice was unlawful. In a landmark ruling that led to the repealing of the National Registration Act, and the abandonment of the ID card, the Lord Chief Justice remarked :

... although the police may have powers, it does not follow that they should exercise them on all is obvious that the police now, as a matter of routine, demand the production of national registration identity cards whenever they stop or interrogate a motorist for any cause....This Act was passed for security purposes and not for the purposes for which, apparently it is now sought to be used.... in this country we have always prided ourselves on the good feeling that exists between the police and the public, and such action tends to make the public resentful of the acts of police and inclines them to obstruct them rather than assist them. 16

10. Do ID cards facilitate discrimination?

Yes. The success of ID cards as a means of fighting crime or illegal immigration will depend on a discriminatory checking procedure which will target minorities.
The irony of the ID card option is that it invites discrimination by definition. Discriminatory practices are an inherent part of the function of an ID card. Without this discrimination, police would be required to conduct random checks, which in turn, would be politically unacceptable.

All discrimination is based on one of two conditions : situational or sectoral. Situational discrimination targets people in unusual circumstances. i.e. walking at night, visiting certain areas, attending certain functions or activities, or behaving in an abnormal fashion. Sectoral discrimination targets people having certain characteristics i.e. blacks, youths, skinheads, motor cycle riders or the homeless. ID cards containing religious or ethnic information make it possible to carry this discrimination a step further.

Several developed nations have been accused of conducting discriminatory practices using ID cards. The Government of Japan recently came under fire from the United Nations Human Rights Committee for this practice. The Committee had expressed concern that Japan had passed a law requiring that foreign residents must carry identification cards at all times. The 18-member panel examined human rights issues in Japan in accordance with the 1966 International Covenant on Civil and Political Rights. Japan ratified the covenant in 1979. The Alien Registration Law, ``the Committee complained in its report, is not consistent with the covenant''.

Ironically, the Parliaments of several European nations, including France and Holland, have accepted a law introducing the obligation to identify oneself in numerous situations including, for instance, at work, at football stadiums, on public transport an in banks. While the card is voluntary in name, it is in effect a compulsory instrument that will be carried at all times by Dutch citizens. Moreover, foreigners can always be asked to identify themselves to authorities at any moment and in any circumstance.

French police have been accused of overzealous use of the ID card against blacks, and particularly against Algerians. Greek authorities have been accused of using data on religious affiliation on its national card to discriminate against people who are not Greek Orthodox.


11. To what extent will an ID card become an internal passport?

An ID card, by definition, is a form of internal passport. Virtually all ID cards worldwide develop a broader usage over time, than was originally envisioned for them. This development of new and unintended purposes is becoming known as function creep.
All ID cards - whether voluntary or compulsory - develop into an internal passport of sorts. Without care, the card becomes an icon. Its use is enforced through mindless regulation or policy, disregarding other means of identification, and in the process causing significant problems for those who are without the card. The card becomes more important than the individual.

The use of cards in most countries has become universal. All government benefits, dealings with financial institutions, securing employment or rental accommodation, renting cars or equipment and obtaining documents requires the card. It is also used in myriad small ways, such as entry to official buildings (where security will invariably confiscate and hold the card).

Ironically, many card subjects come to interpret this state of affairs in a contra view (the card helps streamline my dealings with authority, rather than the card is my license to deal with authorities). The Australia Card campaign referred to the card as a license to live.

It is clear that any official ID system will ultimately extend into more and more functions. Any claim that an official card is voluntary should not imply that a card will be any less of an internal passport than would a compulsory card. Indeed a voluntary card may suffer the shortcoming of limited protections in law.

During the campaign against the Australia Card, talk back radio hosts had become fond of quoting a paragraph of an HIC planning document on the Australia Card:

It will be important to minimize any adverse public reaction to implementation of the system. One possibility would be to use a staged approach for implementation, whereby only less sensitive data are held in the system initially with the facility to input additional data at a later stage when public acceptance may be forthcoming more readily. 17

The campaign organizers stressed the pseudo-voluntary nature of the card. Whilst it was not technically compulsory for a person to actually obtain a card, it would have been extremely difficult to live in society without it.


12. What happens if an ID card is lost or stolen?

Virtually all countries with ID cards report that their loss or damage causes immense problems. Up to five per cent of cards are lost, stolen or damaged each year, and the result can be denial of service ad benefits, and - in the broadest sense - loss of identity.
There exists a paradox in the replacement of cards. The replacement of a high security, high integrity card involves significant administrative involvement. Documents must be presented in person to an official. Cards must be processed centrally. This process can take some weeks. However, a low value card can be replaced in a lesser time, but its loss p oses security threats because of the risk of fraud and misuse.

People who lose a wallet full of cards quickly understand the misfortune and inconvenience that can result. A single ID card when lost or stolen can have precisely the same impact in a persons life.


13. What are the privacy implications of an ID card?

In short, the implications are profound. The existence of a persons life story in a hundred unrelated databases is one important condition that protects privacy. The bringing together of these separate information centers creates a major privacy vulnerability. Any multi-purpose national ID card has this effect.
Some privacy advocates in the UK argue against ID cards on the basis of evidence from various security threat models in use throughout the private sector. In these models, it is generally assumed that at any one time, one per cent of staff will be willing to sell or trade confidential information for personal gain. In many European countries, up to one per cent of bank staff are dismissed each year, often because of theft.

The evidence for this potential corruption is compelling. Recent inquiries in Australia, 18 Canada 19 and the United States 20 indicate that widespread abuse of computerized information is occurring. Corruption amongst information users inside and outside the government in New South Wales had become endemic and epidemic. Virtually all instances of privacy violation related to computer records.

Data Protection law is wholly inadequate to deal with the use of ID cards. Indeed legislation in most countries facilitates the use of ID cards, while doing little or nothing to limit the spectrum of its uses or the accumulation of data on the card or its related systems.


14. Has any country rejected proposals for ID cards?

Yes, several. France's ID card, for example, was stalled for many years because of public and political opposition. Until the late 1970s, French residents were required to possess a national identity document. This was made of paper, and was subject to the risk of forgery. In 1979, however, the Ministry of the Interior announced plans for a higher integrity automated card encased in plastic. The card was to be used for anti terrorism and law enforcement purposes. The card, to be issued to all 50 million residents of France, was to be phased in over a ten year period. New laser technology was to be used to produce the cards. 21
At first, there appeared to be little resistance to the proposal, but in a fashion similar to Australian experience (see below), political and public resistance grew as details of the plan emerged. Although no identity numbers were to be used (only card numbers) there was some concern over the possible impact of such cards. Frances information watchdog, CNIL, managed to suppress the machine readable function of the proposed cards, though optical scanning made magnetic stripes somewhat redundant. Publications such as Le Figaro expressed concern that the cards and related information could be linked with other police and administrative systems.

Public debate intensified in 1980, with the Union of Magistrates expressing concern that an ID card had the potential of limiting the right of free movement. In response to these and other criticisms, the ruling of CNIL was that no number relating to an individual could be used, but that each card would carry a number. If the card had to be replaced, a new number would apply to that particular document.

In 1981, the Socialists were elected, and the fate of the ID card was reversed. In an election statement on informatics, Francois Mitterrand expressed the view that the creation of computerized identity cards contains a real danger for the liberty of individuals. His concern was echoed by the minister for the Justice, Robert Badinter, explained that ID cards presented a real danger to the individual liberties and private life of citizens, and the new Minister for Interior then announced the demise of ID cards in France.22 The plan was re-introduced under a later conservative government.

In the United States, issues of individual autonomy and national sovereignty appear to have dominated the Identity card issue. Despite a high level of anxiety over fraud, tax evasion and illegal immigrants, successive administrations have refused to propose an ID card. Extension of the Social Security Number to the status of an ID card has been rejected in 1971 by the Social Security Administration task force on the SSN. In 1973 the Health, Education and Welfare (HEW) Secretary's Advisory Committee on Automated Personal Data Systems concluded that a national identifier was not desirable. In 1976 the Federal Advisory Committee on false Identification rejected the idea of a national identifier. In 1977 the Carter administration reiterated that the SSN was not to become a national identifier, and in 1981 the Reagan Administration stated that it was explicitly opposed to the creation of an ID card. Throughout the debates over health care reform, the Clinton Administration has also constantly stressed that it is opposed to a national identifier. 23

It remains the case that the SSN continues to be a de facto national identifier, despite constant rulings and legislation to the contrary. With an estimated four to ten million false or redundant numbers, there is concern that the SSN might in fact help to entrench illegal immigration or fraud, nevertheless, there is no plan to upgrade the number.

Some of the federal agencies mandated to use the SSN are the Social Security Administration, Civil Service Commission, Internal Revenue Service, Department of Defence, food stamp program, Department of Justice, Department of energy, Department of Treasury, Department of State, Department of Interior, Department of Labor, Department of Veterans Affairs, and to all federal agencies for use as an identifier for record keeping purposes. State agencies can also use the number for welfare, health and revenue purposes, and third parties are mandated to request the SSN for verification for products or services.

In recent months, proposals by the Clinton administration to reform the US health sector have involved plans to streamline the administration and information flow amongst all health insurers and providers. This proposal involves a national card system, though the federal administration has insisted that the card would not be general in nature. A recent scheme for employment verification also provoked an outcry when concerns were raised that it would lead to the creation of a national ID scheme.

The most celebrated campaign against a national ID card occurred a decade ago in Australia. In 1986, the Australian Government introduced legislation for a national ID card called the Australia Card. Its purpose was to form the basis of the administration of major government agencies, to link the finance and government sector, and to perform the standard identification functions necessary in the commercial and Social Security sectors.

The card became the focus of the single biggest civil campaign in recent Australian history, and certainly the most notable campaign of its type anywhere in the world. Tens of thousands of people took to the streets, and the government was dangerously split over the issue. The proposal caused such hostility that the card was abandoned in 1987.24

In 1991, the government of New Zealand drew up a strategy to reform its health care and social welfare system through the development of a data matching program, and the introduction of a sectoral national identity card. The card would link major Government departments and would have the capacity to track all financial dealings and even geographical movements. The plan was known as "social bank", and th e card was to be known as a Kiwi Card.

The proposal for a national card had angered civil libertarians and law reform groups, partly because the card would be used to enforce a part payment health system, partly because it was to be established without protections in law, and partly because it would create significant problems for certain minority groups. Under the leadership of the Auckland Council for Civil Liberties, a campaign of opposition was formed in August 1991. Unlike the Australian campaigners four years earlier, the New Zealand campaigners had a precedent from which to develop a strategy.

Although the fight to destroy the Kiwi Card was not anywhere near as spectacular as the Australia Card campaign, the controversy resulted in the abandonment of the card, and the adoption of a low integrity entitlement card (issued in two forms) for the purpose of health benefits. 25




1 S.Davies, A case of mistaken Identity, report to the Ontario Privacy and Information Commissioner, 1996
2 ibid

3 S.Davies, Big Brother, Pan Books, London, 1996, p. 124

4 Senator Shahani, explanatory note to Bill 1685 establishing a national registration card system

5 Privacy International : International survey of identity cards, London, 1994

6 Privacy International submission to the Senate of the Philippines, Manila, 8 May, 1991.

7 David Hencke, Howards ID smart card plans found in junk shop, The Guardian, January 16, 1995, p. 1

8 Theyve all got something on you, The Independent, London, 23 August 1996, p. 3

9 S.Davies, Big Brother, p. 124

10 Commonwealth of Australia, Attorney Generals Department, submission to the Parliamentary inquiry into fraud on the Commonwealth 30 May 1992, p5

11 Authors interview with Professor Michael Norton, chairman, United Kingdom Parliamentary Office of Science and Technology and advice from Professor Herbert Paschen, chairman of Buro fur Technikfolgen Abschatzung des Deutschen Bundetstag (Technology Advisory Bureau to the German Parliament)

12 Perhaps the most obvious of these is the element of deterrence, which is rarely considered in a full audit, but which often counts aas a major factor in informal estimates.

13 Authors interview with the Project Manager of Metro Community Services, Toronto Ontario, January 20, 1994. This figure is viewed within the agency as an underestimate. The internal figure is ten times the official government estimate.

14 Submission of the Australian Department of Social Security to the Joint Select Committee on an Australia Card, and interview with Peter Roberts, head of fraud prevention, Commonwealth Attorney Generals Department

15 New Zealand estimates in 1991 were 30- 100 billion NZ dollars out of a total budget of 10.4 billion NZ dollars, higher than some Canadian estimates, but lower than Britains.

16 Wilcock v. Muckle (1952) 1 KB 367, at page 369

17 Health Insurance Commission, Planning Report of the Health Insurance Commission, Feb 26, 1986

18 The Independent Commission Against Corruption concluded an investigation in 1993, and concluded that abuse of personal information amongst government information users was endemic and epidemic. ICAC, Report on unauthorized release of government information, Vol 1 3, 1992 Sydney

19 The Krever Commission in 1980 investigated the abuse of patient health record confidentiality by private investigators, and concluded that the practice was widespread. For an explanation of the methods adopted by the Commission to uncover these practices, see the Federal Privacy of Medical Information Act , S Rept96-832Part 1, 96th Congress, March 19th 1980, pp 24-26

20 Investigation by the Office of the Inspector General of corruption involving computerized files held by the US Social Security Administration. cited in United States Congress, Office of Technology Assessment, Protecting Privacy in Computerized Medical Information US Government Printing Office, Washington DC, 1993

21 Flaherty, ibid, p.226

22 ibid p227

23 Briefing notes provided by the US Social Security Administration

24 S.Davies, Big Brother, pp 130-136

25 ibid 136-139

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