1. Memorandum submitted by
the Association of Chief Police Officers
BACKGROUND
1. The Association of Police Officers (ACPO)
aims to assist chief officers in providing excellence in leadership
of the police service; to ensure a professional and ethical service
is delivered to all communities; and to provide professional advice
to Government, Police Authorities, other organisations and individuals
with an interest in policing issues.
2. ACPO's 292 members are police officers
of Assistant Chief Constable rank (Commanders in the Metropolitan
Police and City of London Police) and above, and senior non-police
managers, in the 44 forces in England, Wales and Northern Ireland,
plus national agencies such as the National Criminal Intelligence
Service and the National Crime Squad, and other forces such as
British Transport Police and States of Jersey Police.
3. ACPO has held four seminars for its members
to seek views on the development of the identity cards scheme
initiative (ID cards). Two of these seminars were held in the
autumn of 2003 and a further two were held in January 2004.
INTRODUCTION
4. Throughout the consultation process,
ACPO has supported the proposal to introduce identity cards scheme.
We support the Government's decision to introduce a draft bill.
Whilst we recognise that there is a need to build the ID card
scheme incrementally there is a view within ACPO that this matter
needs to be progressed with some urgency.
5. In principle ACPO believes that the
introduction of a national ID card scheme could deliver considerable
benefits. Many areas of policing would benefit, not least the
ability of the police to better protect and serve the public.
As with many of our partners we have never seen ID cards as a
panacea—but we do believe they could be a key part of broader
strategic solutions to a range of community safety issues.
TERRORISM
6. National and international security is
understandably high on the ACPO agenda. Whilst we have never proposed
that ID cards are the sole answer to combating the threat of terrorism
there is now agreement within ACPO that ID cards will assist in
countering terrorism. A card scheme would certainly place an additional
hurdle in the path of those who aid and support terrorism by
providing funding, false identities and "safe locations".
7. The ID card scheme could be an effective
counter terrorism measure as part of a broader strategy. With
the changing nature of international terrorism it is essential
that there is proper means of personal identification. As for
all the potential benefits that could be derived from ID cards
it is essential that the personal details provided on the "foundation
document" are bona fide. ACPO supports the need for stringent
"checks and balances" designed to ensure that fraudulent
applications for ID cards are identified and robustly dealt with.
ORGANISED AND
VOLUME CRIME
8. ACPO is pleased to see the publication
of the Government's White Paper on organised crime. Estimates
of the financial harm caused by professional criminal gangs in
the UK is up to £40 billion per year.
9. As with counter terrorism ID cards will
undoubtedly present a further obstacle to those engaged in organised
crime. This type of criminality by its very nature is complex
and law enforcement needs the right tools to frustrate organised
criminals.
10. ID cards could be beneficial in combating
criminality in areas such as people trafficking, the "sex
trade" and money laundering.
11. In the area of volume crime it is accepted
that there are a number of areas relating to both the public and
private sectors, where a requirement to present an ID card might
deter deceptions relating to identity and, therefore, entitlement
in connection with obtaining goods and services. This is clearly
desirable and we believe will contribute to crime reduction and
community safety.
IDENTITY FRAUD
12. The proposed scheme has the potential
to reduce identity fraud. ACPO acknowledges that the proposed
scheme provides further barriers for those seeking to fraudulently
create a false identity. This is clearly beneficial in the prevention
and detection of crime.
13. ACPO is currently working with partners
in both the public and private sectors to develop policies, practices
and procedures to combat identity fraud.
14. It should be recognised that whatever
scheme is introduced a criminal somewhere will try to find a way
around, or through, it. Therefore there will have to be a system
of continual monitoring and review to adapt and change procedures
where necessary.
BIOMETRIC IDENTIFICATION
15. There is a unanimous view within ACPO
that biometric information has to be included on ID cards.
16. Technological developments provides
opportunities for the exploration of new uses for biometric identification.
ACPO sees benefit in the use of fingerprint, iris or DNA identification.
These areas have to varying degrees been "tried and tested".
We take the view that more than one of these biometric identifiers
should be used on an individual's card, thereby providing biometric
triangulation. It is recognised that photographic identification,
on its own, is not sufficient to provide reliable identification.
Whilst the proposed size of the biometric database will be testing
ACPO hopes that such logistical challenges will not unduly delay
the implementation of the scheme.
17. As ACPO highlighted in the submission
during the consultation stage, the personal and biometric data
stored on the ID card should be:
— Of reliable provenance and yet easy
to provide.
— Absolutely secure from unauthorised
access to prevent identity theft.
— Variable to reflect an individuals
change of circumstances.
— Create minimal bureaucracy for the
applicant and for the authorities managing and having access to
the data.
— Be readily, quickly, accurately available
to the authorities requiring access to the information—this
element is particularly important to operational police officers.
18. We fully support the "pilot"
work that is currently being undertaken by the U.K. Passport Agency
in the area of iris pattern photography and recognition. We await
the results of this "pilot"—particularly how acceptable
this form of biometric identification is to the public and our
international law enforcement partners.
19. ACPO is currently contributing to the
interdepartmental work on the development of reliable and robust
biometric identifiers. The police are involved in the trailing
of portable identification technology through Project Lantern.
ACPO is aware that the issue of the numbers and cost of portable
readers required to ensure that the scheme is efficient and effective
is significant.
POLICE WORKING
PRACTICES
20. The introduction of ID cards could bring
significant benefits to the public through improvements to police
working practices. These benefits include:
Driver Identification: The current arrangement
requiring the driver of a motor vehicle to produce their driving
licence at a police station within seven days is undoubtedly inconvenient
to members of the public and the police. The intention to build
the card scheme on the existing driving licence scheme and the
inclusion of reliable biometric information could enable driver
identification in real time. The saving in time and expense to
the public and the police would be considerable.
Vehicle crime and illegal driving is endemic
in the UK. Making the carrying of the driving licence compulsory
would save £220 million per year and the equivalent of 1,630
police officers. Speedier driver identification through the production
of an ID card would assist with the fight against vehicle crime
and better protect the public.
It is noted that there is no proposed changes
to the current powers on production of driving licences.
Stop and Search: Considerable improvements in
stop and search procedures could accrue from the introduction
of the ID Card scheme. This now has greater significance with
the publication of the Home Office "Recording of Stops Implementation
Guide".
Repeat stops of individuals could become a thing
of the past if "mobile readers" were able to identify
individuals who had been stopped previously.
On-street identification would also assist with
engaging in anti-social behaviour. For example, immediate identification
of individuals in breach of Anti-Social Behaviour Orders (ASBOs),
or Football Banning Orders, would accelerate the administration
of justice and support legislation in this area. Similarly the
ability to immediately identify and help those suffering from
mental illness or medical problems would be of great benefit to
the individual and the emergency services.
ACPO is pleased to see that where non-arrestable
offences are involved Section 25 of the Police and Criminal Evidence
Act procedures will still apply. We have also noted that there
are no proposals to significantly change police powers in connection
with the introduction of ID cards.
Street Bail: As highlighted in the written evidence
provided by the Police Federation of England and Wales the ability
to verify bona fide details on the street would negate the need
to arrest those who currently will not, or can not , provide timely
identification.
Public Disorder: The ability to quickly verify
personal identity at public order or critical incidents would
be invaluable. Quick validation of the details of witnesses and
suspects would again lead to significant service improvements
to those involved in police enquiries and those carrying out investigations.
Proof of Age: With the changes to licensing
legislation and such issues as the sale of alcohol and tobacco
to those under-age the introduction of ID cards could serve to
remove ambiguity for retailers and enforcement agencies.
Bureaucracy: As can be seen from the above examples
the potential for reducing policing bureaucracy are significant.
"Portable readers" of the biometric information contained
on ID cards would undoubtedly save time and cost for the public
and police officers.
CENTRAL REGISTER/DATABASE
21. A central register/database is to be
created once the ID card scheme is introduced. Powers to access
the National Identity Register record of a person without the
individual's consent is proposed.
22. ACPO recognises that access to the register
needs to be controlled. We agree that the information on the register/database
should be limited to core personal information and that links
should be provided to other databases holding specific service
entitlement information enabling the sharing of core personal
information. We also agree that access to information on other
service providers' databases should remain under the control of
the other service providers.
23. ACPO hopes that such a register will
be able to provide "yes/no" authentication service for
identity checks in real time. There are already protocols and
practices for the police to access sensitive personal information
on warrant and through independent Commissioners. We anticipate
that similar "gateways" will be introduced.
COMPULSION TO
CARRY
24. Our views on compulsion to carry ID
cards remain unchanged. The overwhelming view within ACPO is that
the ID card scheme should operate on a "compulsory"
and "universal" basis. Whilst we understand the rationale
behind the proposed incremental approach we believe there are
benefits to be accrued if individuals were required to carry or
produce the card upon request to an appropriate authority. Those
engaged in criminal activity will not be deterred if the scheme
is not robust.
OTHER ISSUES
25. Many other issues have been raised during
the current work on introducing an ID card scheme. During the
initial stages of consultation the proposals were focused on the
proposed introduction of "Entitlement Cards". ACPO has
previously commented upon the introduction of a card scheme and
the impact on combating illegal immigration and illegal working.
ACPO takes the view that the ID card scheme will reduce the "pull
factor" of those seeking to enter the UK for unlawful purposes.
26. Of particular note with more countries
joining the European Union and the limits of Schengen being broadened,
the difficulty in combating illegal immigration is not assisted
by the European Intelligence System. The existing nominal system
is woefully inadequate and needs developing at the international
level.
CONCLUSION
27. ACPO have been fully engaged in all
stages of the recent work concerning the introduction of an ID
Card scheme. We are grateful for the time and assistance provided
by the Entitlement Cards Unit at the Home Office throughout the
consultation work within ACPO.
28.Public acceptability for ID cards is clearly
crucial. ACPO fully supports the introduction of ID cards as the
potential benefits of the scheme far outweigh the logistical and
marketing challenges presented by this initiative. The draft bill
is an important step. We hope the introduction of the card scheme
can now progress with some urgency.
April 2004
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