Memorandum submitted by Professor Patrick Dunleavy, London School of Economics and Political Science (ID02)

 

 

What impact will the introduction of Identity Cards have on public services in general?

 

1. One of the reasons why a national identity card often appears attractive to policy-makers is that it may appear to hold out the prospect of uniquely identifying people in the same way across many different policy fields. National ID numbers are certainly used in this way in some European countries, notably Finland. Here a past tradition of authoritarian government meant that the ID card concept was introduced early on and acquired historical acceptance. But in addition modern Finnish citizens have a great deal of trust that their government will use information about them in ways that respect their human rights, civil liberties and personal freedoms, and strong and comprehensive enforcement mechanisms backing up these protections.

 

2. The UK in common with the United States and some other large liberal countries in the Anglo-American tradition has previously lacked any such foundation for a national ID number to be used pervasively by government to conduct its relations with citizens. In these countries there has been a concern to keep citizens' relations with governments compartmentalized and to prevent information submitted for one purpose becoming available to other departments or agencies for other purposes. Not having a national ID number has been seen in the past as a key support of civil liberties by making it less easy for personnel within government agencies to bring together many different information pots relating to the same citizen.

 

3. The main consequence of this approach has been that across UK central government there has been a complex set of identifiers in use by different departments and agencies for tracking their relations with citizens. LSE Public Policy Group researched this picture for a National Audit Office 'value for money' study called Difficult Forms, published in October 2002. Our researchers accessed a wide range of forms (519 in all) used by central government organizations for dealings with individual citizens (that is, excluding all forms dealing with businesses or other civil society organizations). The data set was also confined to 'first contact' forms, those sent in by citizens as the first stage of making a claim on or securing an authentication from government, and hence covers all the most important and general forms submitted by millions of citizens annually. There are in addition many thousands of follow-on or further information forms that are sent out by departments and agencies to selected citizens in order to clarify or supplement information gathered by the first-contact forms - we have not covered these follow-on forms in our data here. The survey was conducted in early 2002, but we have no reason to believe that the picture involved will have changed very substantially since then.

 

Figure 1 overleaf shows the identifiers asked for across the citizen forms we surveyed. The most common identifiers used are name, address, telephone number and date of birth. The only identity number commonly used across more than one department or agency at present is the National Insurance number, but it is included in only 19 per cent of government forms used by citizens.

 

4. Figure 2 below also shows that use of the National Insurance number is highly concentrated in the social welfare field, where it is asked for on four fifths (81 per cent) of citizen-facing forms. The second most popular field is for taxation where it is asked for on just over a quarter of forms. In education somewhat over a sixth of forms include the NI number and in health just over a tenth of forms. In other policy areas it is rarely used, even in immigration.

 

5. Taken together Figures 1 and 2 show the existence of a complex ecology of identifiers currently asked for by government agencies (the demand side for identifiers) and supplied by citizens (the supply-side). In thinking about the impact that the introduction of a National Identity card may have on this situation it will be important to look at both demand-side and supply-side factors. I give below two lists of factors that may stimulate or inhibit use of an ID number.

 

6. On the demand side, the following factors are likely to influence whether government organizations are likely to ask for a national ID number on forms and in their other dealings with citizens:

 

- Whether legislation or government policy has required them to use ID numbers generally.

- Whether legislation or court judgements have made it clear that it is legitimate for a national ID number to be requested in the specific context of an individual form or service.

- How much it would cost agencies to have their IT systems adapted to incorporate reference to ID numbers. Inherently it may be likely that central government organizations will wait for a major redesign of their IT systems to happen anyway before incorporating ID card numbers in complex systems. This may reduce (or blur) their costs but it will also delay implementation and postpone the point where any 'critical mass' of agencies or services is using ID cards numbers or biometric identifiers.

- How much departments or agencies have to pay to the Home Office or its component agencies in order to consult the National Data Register. Agencies often dislike paying for access to identifiers. For instance, Inland Revenue (now Her Majesty's Revenue and Customs) encouraged taxpayers to use an IR-specific taxpayer number rather than National Insurance numbers, which they had to pay to look up.

- How much it will cost to equip the organization's field offices or citizen-contact offices or facilities with equipment for testing biometrics and contacting the National Data Register and to train staff to operate them.

- How effectively biometrics and the National Data Register work in practice. If these systems do not succeed, or prove more costly in operation than current Home Office estimates suggest, other organizations will hold back in adopting

Figures 1 and 2

 

 

Source: Web survey of 519 central government forms carried out by LSE Pubic Policy Group for the National Audit Office report Difficult Forms: How Government Agencies Interact with Citizens (London: The Stationery Office, 2003), HC 1145 Session 2002-3. Also Web published at www.nao.gov.uk and www.GovernmentOnTheWeb.org

them. Similarly if biometrics do not work well in practice, generating many exceptions or false negatives that are troublesome and expensive to handle administratively, or if citizens need to have extensive reassurance before offering biometrics, then their use may be inhibited.

- How far ID cards and biometrics prove resistant to forgery and other forms of misuse. The more 'gold standard' and reliable the ID card proves the more its use may spread to other departments and agencies.

- How securely the National Data Register proves to operate. In the past there has been a high level of leakage of information from UK government databases to unauthorized users, principally via private detectives, credit checking and other professionals having contacts amongst and paying bribes to public service workers (for instance, police officers or civil servants). If this pattern turns out to be replicated with the joined-up information held on the National Data Register then there could be legal liability implications for agencies sufficient to discourage them from using it.

- How far administrative processes have moved to phone-based processes rather than personal contacts, since biometrics require personal contact with citizens to work and cannot currently be given by phone. (For instance, in order to gather biometrics for the new passport the Passports Agency has reintroduced personal interviews with all applicants, a provision that has not applied hitherto. This adds substantially to administrative costs).

 

8. On the supply side, the following factors will influence the behaviour of government organizations (beyond the Home Office):

 

- How many citizens always or regularly carry the ID card with them and feel happy to offer the card and biometrics when asked to do so. If citizens commonly leave their ID cards at home in a drawer for fear of losing it or having it stolen, then in many single-contact contexts agencies will have difficulties in requesting to see the ID card. If large numbers of people turn up to offices or facilities without their cards it will be difficult to process them or to ask that they all return home to fetch the card.

- One key influence on whether people will carry ID cards or not will be how hard it becomes to establish your identity if you have lost it or had it stolen, especially if someone else is using it (in non-biometric contexts). There is a danger that if ID cards become widely used as identifiers then the existing 'slime trail' methods of establishing who you are will progressively atrophy, considerably increasing the costs and difficulties of re-establishing your identity without an ID card. The more these costs rise the more reluctant citizens may be to carry their cards with them. High costs may also people off replacing their ID cards when lost, unless compelled to do so.

- So it will be crucial whether it becomes compulsory for citizens to show their cards for access to all or some public services or to carry their cards when they are out and about.

- Even if some general legal compulsion to carry cards is introduced, the impact may depend upon the extent to which the police enforce such provisions - it is as yet unclear that they would have the personnel resources to do so and there might be practical difficulties in enforcement (for instance, in souring police relations with black or minority ethnic groups).

- If a significant group of citizens resist carrying or using ID cards or biometrics then the costs involved for all public agencies will tend to increase appreciably - for instance, in terms of many appeals or exceptions-based cases clogging up administrative processes. There tend to be very high 'gearing ratios' in such processes - that is to say, the withdrawal of 'quasi-voluntary compliance' by only a small proportion of citizens has a severely adverse effect on administrative costs. A recent example of this phenomenon was the reaction to the poll tax in 1989-91 when over a million people removed themselves from electoral rolls and non-payments or delayed/disputed payments of poll tax imposed significant costs both on local authorities and on compliant taxpayers.

- Citizens' reactions to being asked to show an ID card, to checking of ID numbers with the National Data register, and to being asked for biometrics will all have a final pervasive impact on how the system operates in practice. If there is widespread resistance to any of these stages then there may be incentives for 'street level bureaucrats' to minimize their checks. For instance, if most police officers or other officials just ask to see an ID card and perhaps quickly check the photo ID to establish that someone is who they say they are, then the biometric protections which the card is supposed to offer may not be activated. Hence there will be some utility for criminals or others in having a fraudulent ID card that would not survive closer inspection or offering of biometrics. If implementation works out in this way then official trust and public trust in the ID card being offered will tend to decline.

 

In general we should expect that the more problems surround the public's acceptance of and ready use of the National ID card the slower and more partial will be any take-up process by other departments and agencies.

 

November 2005