7. Memorandum submitted by
Cubic Transportation Systems Limited
INTRODUCTION
1. Cubic Transportation Systems is part
of Cubic Corporation which is a global company that provides a
range of services to Government agencies across the world in the
defence and transport markets. One of Cubic Transportation Systems'
key skills is the design, build and management of smartcards and
smartcard systems. The proposed UK biometric Identity Card would
be one of the largest smartcard applications in the world.
2. As an engineering design, manufacture
and systems integration company in the UK, Cubic is the technology
partner in TranSys, the consortium that runs the Prestige contract
for Transport for London. This provides London with the largest
transit smartcard application in Europe, the Oystercard. This
is one of many smartcard applications that we have experience
in worldwide.
3. The following information is Cubic's
written submission on the terms of reference for the inquiry into
Identity Cards as set out by the Home Affairs Select Committee.
The response is based on the company's extensive technical expertise,
experience in smartcard delivery and concern over the commercial
competitiveness and high costing of the scheme.
Term of Reference:
"the practical issues involved in the ID
database and biometric identifiers;"
ID CARD INFRASTRUCTURE
4. Cubic support the Home Office's plans
to distribute the cards via a network of designated identifying
locations and a secure distribution network. From the company's
experience of providing and distributing cards two points are
paramount.
5. Cubic would like to highlight that for
the ID Card to be effective, a high level of security must be
enforced throughout the card allocation process to ensure accurate
information. An individual's identity must be proved beyond doubt
and all information handled must be done with respect to the individual.
Cubic feels that these issues are fundamental to making the system
operable, accepted and used.
6. The second key point Cubic would like
to highlight is that to secure card take up, the infrastructure,
both technical and administrative, should provide a simple and
relatively rapid process for the citizen. Current issue processes
for passports and driving licenses for example take only a matter
of minutes to complete.
7. Once issued, the citizen should perceive
the speed of the transaction when using the card as being unobtrusive.
Here the infrastructure will need to provide for rapid reading
and validation of the bearer. In the event that the card becomes
a multi-application platform the card and its architecture must
respond to the requirement for variable transaction times depending
on application. If the ID Card was also a travel ticket and was
being used to open gates, a rapid transaction time would be required.
If the ID Card were to be used as a passport, an acceptably slower
transaction time would be needed to confirm a right to travel.
Biometric readings must be unobtrusively, inoffensively and quickly
carried out to make the cards convenient and easy to use and thus
popular with the public.
ID CARD DATABASE
8. Cubic support the Home Office's plan
to use the National Identity Register as the one database to run
the ID card from. The benefit of having one uniform database structure
is the effective delivery of an identity card system reliant on
just one format of information. This enables the system to work
effectively and simply and not be congested with forms of identity
information that the card may find difficult and slow to process.
The adoption of a single structure across all Government databases
and across the infrastructure will significantly reduce cost.
ID CARD SERVICES
9. Cubic support the incremental approach
of the Home Office towards the services that the card will offer.
The first reason for this is a practical one. If an ID Card provider
were to enable the ID card to be a multi-purpose smart card with
the capability of being, for example, a combined biometric identity
card, driving license, passport, NHS Card, and enabler of e-voting,
it would take time to roll out such services effectively and to
a high standard due to principally three reasons.
10. First, for any card and system supplier,
a uniform and standardised form of information is the industry
best practice for the card to operate from. As a result of this,
each service the card will offer will mean that the information
that supports this will have to be in a compatible form for the
system. Whilst this is certainly possible, this will take time
to achieve and will lengthen lead times. Cubic is keen to make
the Home Affairs Select Committee aware of this practical time
restraint from the outset.
11. Cubic also support the incremental approach
of offering a smart ID Card on the grounds of securing citizen
user acceptability and userability. Whilst the current 10,000
participant pilot trial will provide some important feedback on
the operation and feasibility of the scheme, the implementation
of the ID Card in 2007-08 should also be carefully monitored to
reveal how people respond to the card and system nationally.
Term of Reference:
"the security and integrity of the proposed
system;"
BIOMETRIC INDICATORS
12. Cubic strongly supports the Home Office's
desire to use at least one biometric indicator to make the card
as tamper and fraud proof as possible. Furthermore Cubic recommend
that to make the card as secure as technology will allow and to
be cost effective, the ID Card could be made flexible so that
whilst all would carry a facial digital photograph, to provide
authorities with instant recognition, it could also give the issuer
the option of taking either a digital recording of a fingerprint
or an iris.
13. This would enable costs to be significantly
reduced and would mean that for those individuals with unclear
fingerprints, such as manual building labourers, the iris scan
would be available, and for the one in every 10,000 people whom
iris recognition is not suitable, the fingerprint biometric could
be applied. This methodology significantly increases the flexibility
of the card for practical use and would link level of security
to selection of the appropriate biometric in a multi-application
environment. Where the check being made is in a low security environment,
such as transport, the visual identification by use of the photograph
is likely to be acceptable, rapid and would require no technology.
Where a higher level of security is required then the fingerprint
or iris biometric can be accessed, such as for voting or medical
needs.
14. A consideration at this point is also
the cost of reader technology. Deployment of fingerprint readers
would, in Cubic's experience, deliver a lower cost of implementation
than a full iris scan network.
CARD MANAGEMENT
AND FRAUD
DETECTION
15. Cubic would like to suggest that the
Home Office consider improving the security and integrity of the
system by monitoring uses of the cards via its transactions to
identify anomalies. These would indicate potential fraudulent
use and make the system more secure. By managing the cards, the
system is strengthened against unauthorised use and impostors.
If this were conducted in a random way across a changing sample,
system security and integrity is improved and costs are kept to
a minimum.
Term of Reference:
"the operational use of ID cards in establishing
identity, accessing public services, and tackling illegal migration,
crime, and terrorism;"
PUBLIC EDUCATION
PROGRAMME
16. Cubic would like to suggest that the
Home Office considers running a country-wide education programme
on the benefits the ID Card will bring to each citizen, what it
will enable a citizen to do, what the process is to receive a
card and other similar operational issues. Cubic suggest that
this be carried out before the cards can be purchased so that
UK citizen's are aware of the system, what it entails and the
availability of the voluntary card offer. This will help the system
to work effectively once it is running together with helping manage
individual's expectations about how the ID Card can improve people's
lives.
Term of Reference:
"issues to be addressed in the longer-term,
including compulsion;"
LONG TERM
ISSUES
17. Whilst Cubic does nor perceive that
its role is to comment on issues such as compulsion it does believe
that there are practical and technical issues that the Government
must address in the long term.
18. In respect of the technology deployed,
Cubic would suggest that the Government adopt a strategy that
will deliver a convergence into a single platform of all the database
and card schemes that it operates into a single standardised platform
over the initial life of the ID card scheme, thus delivering significant
cost benefits in the longer term.
19. Cubic would also suggest that the scheme
requires its suppliers to provide a monitoring and consultancy
role to ensure that the Home Office system is kept abreast of
technology developments, to make recommendations for future improvements
and to provide on-going services such as system maintenance as
necessary.
Term of Reference:
"the estimated cost of the system."
DEFINITION OF
CARD SUPPLY
REQUIREMENT
20. In order to define costs effectively,
Cubic feels that the more information about the ID Card scheme
the better. With this in mind, Cubic is interested in:
— How quickly will the Home Office
expect to be able to replace ID Cards if lost?
— How many ID Cards are expected to
be lost on a percentage basis?
— What is the expected life of the
cards?
— With continuing technological developments,
how regularly does the Home Office expect to refresh the ID Card's
smartcard ability?
— What personal details does the Home
Office wish the card to convey?
— What personal details will be printed
on the external face of the card?
— What personal details will be contained
within the microchip and what details are expected to be held
centrally?
— What is the Home Office view on the
cost of having to reissue cards every time the information on
the card face changes?
— When personal details change, does
the Home Office favour updating the card against updating the
central database?
— How will the cost of card supply
be balanced against infrastructure and card database costs?
— What timescale expectations does
the Home Office have of delivering the card from design phase
through to the initialisation stage?
The answers to these questions will help save
money and minimise excessive costs as they will nullify the cost
inflation of unspecified contingency arrangements.
TYPE OF
CARD SUPPLY
REQUIREMENT
21. Together with the considerations highlighted
above that will help reduce costs, Cubic strongly urge the Home
Affairs Select Committee to call for a carefully defined requirement
that enables open and fair commercial competition and that delivers
value for money.
22. From industry experience, Cubic prefers
a requirement that specifies the project outcome and key performance
deliverables. This is based on the company's successful implementation
of the largest European smartcard system under the Prestige contract
for Transport for London.
23. A key lesson learned from this was that
the requirement is best delivered if it is specific and unchanging
in its objectives whilst providing bidding companies the opportunity
to demonstrate their ability to provide the most competitive offer.
This enabled Cubic, as part of the TranSys consortium, to deliver
the OysterCard successfully. In this sense, so that companies,
including Cubic, can respond to the OJEC effectively, Cubic would
like to warn the Home Affairs Select Committee of the dangers
of a prescriptive system requirement that stipulates a lengthy
list of targets and one that is heavy in bureaucracy.
January 2004
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