Prioritize Privacy In the Design and Operation of the National Identification Card

Restrict identifiable information that can be added to the card and increase transparency on the technical design and operation of the card

The Authority is currently authorized to add any biometric or biographical information it sees fit to the national identification card through new regulations. This provision should not have unlimited applicability to private identity information that increases the risk of privacy and security breaches. The Authority should be transparent about the operation of the card and publish technical specifications on how it will interact with the identity verification process

What This Could Look Like in Real Life

01. Everton Loses His NIDS Card
02. Nora’s Fear of Big Corporations

Everton registered for NIDS when the card first became available. A year after his enrollment, the Authority changed the requirements of what biometric information is to be displayed on the card and added a full fingerprint, photograph, and thanks to recent technological developments, the card will now store facial geometry and DNA information on a chip.

Everton would not have enrolled in NIDS if he had known this information would be on the face of the card or stored in it and accessible by third parties, because he has previously been a victim to identity theft and fears this may happen again.

Two weeks after Everton was forced to update his card, he loses the NIDS card and it falls into the hands of Julian, who is now more easily able to use James’ private information to gain access to his accounts.

[Based on NIRA 2020, Section 19]

Nora recently moved to Jamaica, having previously worked for a large international tech company. She wants to enrol in NIDS but through her old job is aware that private companies will oftentimes store, process, and even sell people’s private information to other private actors or government agencies for statistical analysis, research and development, or security and surveillance measures.

Nora is keen to know how her data will be used and processed once she enrols for NIDS and wants to know specifically how the information on her NIDS card will be interacting with the central database at a technical level.

The authority has not published this information and Nora therefore refuses to enrol for NIDS, making it more difficult for her to settle in the country and do things such as open a bank account or register for health services.

Details

Under section 19, the Authority is able to add any information it sees fit to the national identity card through additional regulations. While this discretion is not unreasonable for various kinds of information such as information about the card itself (e.g. date of issue; place of enrolment), it is not appropriate for the Authority to have unlimited discretion to expand what biometric identity information is displayed on the card beyond what the Bill specifies.

Biometric technology is developing fast and people enrolling in NIDS now cannot foresee what further information may be required. Yet, biometric personal information is highly sensitive and once it is accessed by strangers may make it easier to commit identity fraud and privacy harms that are difficult to remedy.

These technological developments also mean that there must be increased transparency about how the card will work; how it will interact with the identity verification process and what technologies are envisioned to be embedded in the proposed card options. Currently this is all left to regulations or determined during system implementation. Privacy and inclusion must reign supreme with regards to people’s personal identity information and individuals registering in NIDS should be able to view and understand not only what their data is used for but also how it is used.

Recommendations

Remove the ability of the Authority to require the display of other identity information not presently listed in the Act on the NIDS card through future regulations
Publish the technical specification and design options for the national identification card and detail how the card will work, how it will interact with the identity verification process, and the card’s proposed technologies

Status: Pending

Watch this space! We will provide an update once the Joint Select Committee has made a decision on this issue.

Last updated 2021-05-27

Talk Up!

If this issue matters to you, talk about it. Share this page (and your questions or suggestions) with friends or government representatives.

Comments, Questions?

Is there something we overlooked with this issue?
Have questions? Let us know!