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

These are examples of what the NIDS Bill allows. These examples may not necessarily reflect the intention of the Bill, but are possible based on how the Bill was worded when it was tabled in 2020.


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.


  • 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

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