32. Memorandum submitted by
the Local Government Association
INTRODUCTION AND
SUMMARY
1. The Local Government Association (LGA)
represents local councils in England and Wales. We work with and
for our member authorities to realise a shared vision of local
government that aims to put local councils at the heart of the
drive to improve public services. Local government has a particular
interest in the proposals to introduce identity cards, as councils
are not only key public service providers but also community leaders.
We welcome this opportunity to make comments to the Inquiry, which
are based on our response to the Home Office consultation paper
on entitlement cards in January 2003. Our key points are as follows:
— We think that there would be advantages
to local authorities in a well-managed unique citizen reference
scheme and the LGA would support this in principle.
— It is important that other government
initiatives concerning information to identify individuals and
local populations should be coordinated, including: the development
of an electronic electoral register; the future development of
the Census; the allocation of unique identifiers to children.
— The proposals should be developed
in full consultation with local government. The bulk of people's
transactions with the public sector are with local government
and councils already have experience of the operation of smart
card schemes for accessing local services.
— It is important that any entitlement
card scheme should not compound discrimination against particular
sections of the community.
— If cards are to be required for access
to council services such as benefits and social housing, councils
would need to be able to access the national identity register
and be able to validate cards to check biometric data stored on
them. As far as we are aware there are no current estimates for
those costs for councils.
THE PRACTICAL
ISSUES INVOLVED
IN THE
ID DATABASE AND
BIOMETRIC IDENTIFIERS
2. The Government is proposing to proceed
towards introducing a national identity cards scheme in two stages.
The first stage will include the establishment of a National Identity
Register which will hold basic identity information—such
as name, address, date of birth, gender, immigration status and
a confirmed biometric—which will be set out in statute.
3. It is not clear at this stage whether
or not local authorities would have access to the Register in
order to verify the identity of individuals. We think that there
would be advantages to local authorities in a well-managed unique
citizen reference scheme and the LGA would support this in principle.
A resolution of the discrepancies between all the existing referencing
systems would be very helpful to local government, though we do
not underestimate the administrative challenge that would be presented
by maintaining the integrity of the register.
4. A population register could help in the
design of local security systems, projects and access methods.
It could also provide more consistent demographic data and complete
and accurate population statistics which underpin government allocation
of resources. A population register could help to ensure people
did not get lost in the system when they cross local authority
boundaries and lose out on support and benefits. Local authority
experience of maintaining council tax databases as well as the
electoral roll has shown that there can be as many as 40% of people
changing address in London boroughs each year and around 25% in
other large cities. Where applications for services are made by
post, telephone or on-line, it would potentially be very useful
for service providers to be able to check the applicants' data
against the central register holding the personal identification
information.
5. The Government believes a more integrated
approach to citizen databases is required. A locally based approach,
managed by local government not central government, might be more
acceptable to the public, although we would want to see national
standards and guidance for implementation.
6. The experience of other government activity
concerned with the compilation of information about individuals
and of local populations should help to inform the discussion
on the development of the national identity register. It is very
important that that these initiatives are coordinated and the
potential role of local authorities is fully addressed, for example:
— The Electoral Commission recently
reviewed the law and practice in relation to electoral registration
in the UK and made a number of recommendations, including a move
to individual voter registration and voter identifiers and a unique
registration number. It also recommended that electoral registers
should continue to be compiled and managed locally, but should
form part of a national register maintained according to mandatory
national data standards. There is currently a project underway,
which is being coordinated by the ODPM, aimed at developing a
nationally accessible electronic version of the electoral register.
— The LGA is actively involved in
the development of the Census Strategic Development Programme
to co-ordinate the future development of the Census. There were
a number of concerns about specific areas of the population estimates
based on the 2001 census which are being addressed, including
areas of transient populations, armed forces, seasonal labour,
recent immigration and inner city multiple-occupied dwellings,
areas with low response rates and the need to disentangle estimates
of emigration and estimates of non-response.
— Although the identity card scheme
proposals concern individuals aged 16 and over, there is a clear
need for coordination with the separate Government proposals on
the identification, referral and tracking of children at risk
(IRT) We understand that allocating unique identifiers to all
children is being considered, based either on the pupil identifier
or on the NHS number. Clear identification of children across
the spectrum who are in need of service provision is crucial to
ensure that children receive an appropriate service. Local authorities
have a vital role to play in the operation of the information
hubs for IRT at local level and in encouraging cultural and behavioural
change amongst professionals. The identity of parents and carers
and family members as well as young people in their transition
to adulthood will have significant implications for councils in
protecting children's interests.
7. At a local level councils have to be
able to see the whole picture and it will not be helpful if these
various initiatives are developed in isolation from each other.
THE SECURITY
AND INTEGRITY
OF THE
PROPOSED SYSTEM
8. To combat fraud, there is a strong argument
for the use of biometric data to reduce the ability of organised
crime producing fake cards and assigning a unique number to the
identity of the individual with reference to the biometric data.
But the use of an identity card to replace the current range of
documents used to establish identity would only reduce fraud if
the processes to obtain such a card were much more secure than
current systems which are open to abuse.
9. Local authorities already play a significant
role through the Registration Service in the provision of birth
certificates which are currently used as one of the documents
for identifying individuals. However it is recognised that the
procedure for obtaining birth certificates is open to abuse by
fraudsters despite the considerable efforts made by the Registration
Service and others to help in the detection, investigation and
prevention of identity fraud.
10. The Registration Service has a network
of local offices which might be well placed to provide "front
office" access points to capture biometric information, associate
it with other data and then process it in a secure way. In view
of the likely volume of applications to be processed there would
be significant resource issues to be considered and any new responsibility
would need to be in the context of civil registration reform.
11. In our comments on the Home Office consultation
paper we noted that from a fraud perspective, the integrity of
the Identity Register would rely on keeping it up to date with
change of address details. It is not clear how the Government
will ensure that a new Identity Register would be more accurate
than the current multiplicity of databases of UK residents currently
in place, as some inaccuracies must result from the public failing
to provide information about change of address, for example. We
do not know at this stage if it is proposed to make it mandatory
for individuals to register or if it will be an offence to fail
to notify the central register of a change of address or giving
an incorrect address. Any legislation would need to be specific
about what is considered as the principal home.
THE OPERATIONAL
USE OF
ID CARDS IN
ESTABLISHING IDENTITY,
AND ACCESSING
PUBLIC SERVICES
12. It is proposed that in the second stage
of the scheme, if conditions were right, people would be required
to produce a card to access public services. The Home Office
Next Steps paper notes that in the case of those services
for which the devolved administrations have responsibility, decisions
on production of a card to access those services would be a matter
for them. We have not been involved in any discussions as yet
about services provided by councils , for example housing or council
tax and other benefits, applying for social housing or voting.
We would expect that the legal implications and liability would
have to be clarified.
13. Access to many council services requires
the identity of the service user to be authenticated before the
individual is given access to services, whether provided face-to-face
or electronically. The government's "Authentication Framework"
drawn up by the Office of the e-Envoy recognises three authentication
levels, depending on the degree of trust required in the asserted
identity. In practice, renewing a library book online would not
require the same level of authentication of identity as a claim
for benefit.
14. A number of local authority smart card
schemes are already in place. A national project funded by ODPM
as part of the national strategy for local e-government aims to
create a model smart card scheme. Examples of the way local authority
smartcards are being used include access to library, leisure,
school meals and transport on one card.
15. From a local authority viewpoint it will
be very important to ensure that the experience of the operation
of smart card schemes for accessing local services and the implications
of the introduction of an identity card, including the interoperability
of cards are addressed at an early stage. Councils are unlikely
to want to see their local cards replaced by a national ID card.
ISSUES TO
BE ADDRESSED
IN THE
LONGER TERM,
INCLUDING COMPULSION
16. The Government has set out the conditions
that would have to be met before a move to a compulsory card scheme
in which it would be compulsory to have a card and to produce
a card to access public services. These conditions include clear
public acceptance for the principle of a compulsory ID card. Any
proposal to introduce ID cards will depend significantly on the
perception of the general public, and the confidence people place
in the privacy of information and personal identity. Whilst the
intention is to reduce the incidence of stolen identities, with
a central database and use of technology, many may consider the
risks to be heightened rather than reduced.
17. Local areas are becoming more diverse
and local councils have a significant role to play in ensuring
that all voices are heard. Councils have to assess the problems
faced by different groups and tackle discrimination and disadvantage,
develop positive community relations and promote inclusiveness.
18. It is important that any ID card scheme
should not compound discrimination against particular sections
of the community. There is recent evidence from stop and search
figures that ethnic minorities are disproportionately affected
by such checks. There will be a risk of increasing tension in
communities if it does become common practice, (despite the intention
that it should not), for people to be asked to produce their cards
on demand. Similarly if young people are required to prove their
age on a frequent basis they will in effect be required to carry
the cards.
19. For people with relatively stable lives
the requirements to provide the documents required to apply for
a passport, driving licence or a bank account would not usually
be considered onerous. But for people who are homeless, who suffer
mental health problems, those who move frequently or live less
stable lives for whatever reason may find it more difficult to
provide such documents. Any scheme would have to overcome the
reluctance of those who may be suspicious of authority to apply
for ID cards and to ensure that they are not excluded from services
on the loss of a card.
THE ESTIMATED
COST OF
THE SYSTEM
20. The Government has said that it intends
to work with "the NHS and other public services" to
maximise the benefits of a card and minimise the compliance costs.
If cards are to be required in time for access to council services
such as benefits and social housing, councils would need to be
able to access the national identity register to verify identity
and be able to validate the card by using card readers to check
the biometric data stored on them. As far as we are aware there
are no current estimates for those costs but they are likely to
be considerable.
21. Even though it will potentially be some
years before a full ID scheme is implemented, local authorities
will need to make informed decisions in the meantime about investments
in technology and it will be vital that local authorities are
involved at the outset in the technical and operational plans
for implementation.
January 2004
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