Select Committee on Home Affairs Written Evidence


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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