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Presented to Parliament by the Secretary of State for the Home Department by Command of Her Majesty July 2002

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© Crown Copyright 2002 The text in this document (excluding the Royal Arms and departmental logos) may be reproduced free of charge in any format or medium providing that it is reproduced accurately and not used in a misleading context. The material must be acknowledged as Crown copyright and the title of the document specified.

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Foreword by the Home Secretary, the Rt Hon David Blunkett MP After the terrorist atrocities in the United States on 11 September 2001, I was asked whether the Government was considering introducing identity cards. I said at the time that any debate about identity cards should not centre exclusively on issues of national security. Far more important are the issues of citizenship and entitlement to services and it is in this context that I would like to see the debate unfold.

In February we set out our policies on nationality, immigration and asylum in the White Paper Secure Borders, Safe Haven (CM 5387). In the Paper we announced that we would be publishing a consultation paper on entitlement cards later in the year. By giving advance notice of the publication, we have been able to take account of the views expressed in over 300 letters and emails sent by members of the public and to consult a wide range of organisations in the public and private sectors. I am very grateful for the contributions we have already received and look forward to a lively and informative debate over the next six months.

There are strongly held views on all sides of the debate on identity or entitlement cards. Although many people have settled views on the principle of whether or not they favour them, I think it is important to rehearse all the pros and cons of a scheme even if this is seen as going over old ground. I think there will be an even more informed debate if we also explain how a card scheme might operate in practice. Everyone can then relate the potential uses of a card scheme to how it might benefit them in their daily lives. Equally they will be more aware of how a card might cause some inconvenience for example in having to go through the process of applying for one. We have therefore provided an outline of a possible scheme in this Paper. Whether we go ahead with the scheme will be dependent on the assessed will of the people of the United Kingdom, which is why we are launching this consultation. It is essential that any card is practical and cost-effective in meeting the objects for which it is intended. The particular shape and nature of the entitlement card, and its development, will also be subject to the views put forward and the technical potential for the years ahead. It will by its very nature take some time, should the Government decide to legislate, to get the card into place. We will also need to take into account technical developments which will provide both for a greater range of potential uses and improved security, alongside the impact of such work on the timetable for the ongoing modernisation of the Government's core IT systems. 4
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One of the potential benefits of a card scheme which is most often quoted is in reducing identity theft and fraud which each year costs the economy at least £1.3 billion. There is a pressing need to tackle this problem now and an entitlement card scheme could only make a contribution in the long term when cards were widely held by the population. The Government is therefore also publishing a report on the extent of identity fraud and other possible measures to combat it. Some of the measures could involve increased co-operation between the public and private sectors and increased use of information sharing about individuals. This paper also seeks views on some of these projects as well as setting out actions the Government will take in the short term.

The consultation exercise will run for six months which I hope will give time for everyone to consider the issues in depth by holding discussions in their communities, with their Members of Parliament and local councillors and by participating in the debate in the media. The introduction of an entitlement card scheme would be a major step and the Government would not proceed without the most careful consideration of all the responses we hope to receive.

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Contents EXECUTIVE SUMMARY 7 CHAPTER 1: Introduction 12 CHAPTER 2: The options for an entitlement card scheme 16 CHAPTER 3: Possible uses for an entitlement card 27 CHAPTER 4: Combating identity fraud 39 CHAPTER 5: How a scheme might work in practice 45 CHAPTER 6: Data Protection and Privacy Issues 69 Annex 1: List of consultation points 79 Annex 2: Population registers and card schemes in the UK since the First World War 84 Annex 3: Card schemes in other countries 86 Annex 4: How a scheme might work in practice 94 Annex 5: Indicative cost assumptions 131 6
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Executive summary 1 The Government wishes to consult on whether it should introduce an entitlement card scheme. A universal entitlement card scheme would: (i) provide people who are lawfully resident in the UK with a means of confirming their identity to a high degree of assurance; (ii) establish for official purposes a person's identity so that there is one definitive record of an identity which all Government departments can use if they wish; (iii) help people gain entitlement to products and services provided by both the public and private sectors, particularly those who might find it difficult to so do at present; (iv) help public and private sector organisations to validate a person's identity, entitlement to products and services and eligibility to work in the UK.

The consultation will help the Government to weigh up the overall costs and benefits of introducing entitlement cards.

2. The Government does not wish to consult on the introduction of a compulsory scheme, by which it means a card which everyone would have and be required to carry at all times.

Potential Uses of a Card 3. By giving a clear indication that the holder of an entitlement card is lawfully resident in the UK, a card scheme could be a powerful weapon in combating illegal immigration. The perception that once people manage to enter the country illegally they can work and obtain benefits and public services with impunity adds to the 'pull factor' which draws people into organised networks of people trafficking. A universal entitlement card scheme would give greater credibility to legal migration routes into the country. It would reduce the burden on legitimate employers who already check the immigration status of their employees by giving them a single, easily understood card to check. It would also help to prosecute unscrupulous employers who employ illegal workers for less than the minimum wage and undercut legitimate companies.

4. The potential benefits of an entitlement card scheme go much wider than an immigration control measure. It could provide a more efficient basis for administering public services by

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avoiding the need for people to provide the same personal information time and again to a range of public services. There would also be savings for service providers as there would be a single definitive source of information about people's identity and possibly a unique personal number for everyone registered on the system.

5. A card scheme could help prevent people becoming victims of identity theft and identity fraud, for example preventing parents suffering the distress caused when a criminal assumes the identity of their deceased child. A card could allow people to travel around Europe without the need to carry a passport book and might be useful to young people to help prove their age when purchasing age-restricted goods and services.

6. The arguments for and against entitlement or identity cards have been made many times since the wartime scheme was abolished in 1952. The benefits of improving the provision of public services and reducing illegal immigration and identity fraud need to be considered alongside the arguments against a scheme. People might be concerned that a card scheme might allow the Government to link together all of the information it held on individuals. If a card scheme was not secure, it could itself become the source of increased levels of fraud if cards could be forged. The Government recognises that there are strongly held views on both sides of the argument and wishes to see these explored fully during the consultation period.

7. One of the arguments most often quoted against a card scheme is that the benefits would take many years to realise because of the time it would take for cards to be held widely. Because of the pressing need to tackle the increased threat of identity fraud which is estimated to cost the country at least £1.3 billion each year, the Government would also like to consult on a number of measures which could be implemented in advance of an entitlement card scheme or instead of one, if it was decided not to proceed after this consultation exercise. The Government is publishing a separate report on the extent of identity fraud and suggested ways of combating it which provides more detail than can be covered in this paper but the main points are summarised in Chapter 4.

How a card scheme might work in practice 8. The Government expects that there will be a vigorous debate on the general pros and cons of an entitlement card scheme. However it thinks that there will be a more informed debate if people also have an idea about how a scheme might work in practice. This paper therefore sets out a suggested scheme in which the photocard driving licence and the recently announced passport card would both be equally acceptable forms of entitlement card.

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It is not possible to combine the exact format of both cards into one because of the specific requirements of the respective EU and international standards with which each card must comply. However, as the format of the UK passport card is yet to be decided, it will be designed to accord as close as possible with the format and layout of a photocard driving licence. Both will therefore fulfil the functions of an entitlement card. Not all the population can qualify for a driving licence or a passport. These people would be offered a card at a lower cost than a passport or a driving licence in the form of a non-driving licence/ entitlement card. Such cards are commonly used as forms of photo-id in the United States by people who cannot drive. The card would look like a photocard driving licence minus the information on what vehicles the holder is entitled to drive. The use of driving licences and passport cards, suitably adapted, is only one way of delivering cards to the population using existing organisations. Chapter 5 and Annex 4 detail how such a scheme might work if it were decided to proceed. But Chapter 5 is illustrative rather than prescriptive and the figures for costs, charges and timetable cannot be more then broad estimates at this stage.

9. In order to ensure that a card scheme would provide a greater level of protection against identity fraud, it is proposed that the checks currently undertaken for driving licence and passport applications should be strengthened. One of the most difficult parts of a person's identity to counterfeit is their historical background which can only be built up over time for example as they pass their driving test, apply for a passport and open bank accounts. The method of issuing entitlement cards would make greater use of checks on this type of information.

10. Another option which the Government would like to explore is the recording of biometric information as part of a card scheme. This would take the form of recording a fingerprint scan or the image of a person's iris (the coloured ring around the eye) as well as a digital photograph which is already taken for passports and driving licences. There would be strict controls on how this information was used. If it proved feasible and cost-effective, recording this information would greatly reduce the ability of fraudsters to create multiple false identities and provide a powerful way for people to prevent their own identities from being stolen. However it is also important that the introduction of this technology should be acceptable to the general public and the Government would like to use this consultation exercise to seek people's views. This means whether it would be acceptable in principle for this information to be recorded and also whether it would be acceptable in practice as people would need to go somewhere where the appropriate recording equipment was installed when they applied for a card.

11. The Government would ensure that a scheme complied with the requirements of the Data Protection Act 1998 by setting out the purposes of the central register on which a card scheme would be based in legislation and drawing up regulations for the use of any unique personal number which might be given to every person who registered. Under the suggested scheme set out in this paper, the central register would not become the depository for a wide range of information held by different Government Departments or Agencies about individuals. The Government is clear that protection against intrusion or unauthorised access to personal information is crucial if any such scheme were to work.

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12. An entitlement card would probably be issued in the form of a smartcard which incorporated a simple memory chip. This would allow other organisations to make more use of the card which in turn would help it become more useful to card-holders. There would be safeguards to ensure that information which might be held on the chip from one service provider was not made available to other service providers in an unauthorised manner.

Cost estimates 13. The cost of a scheme would depend on whether biometric information was recorded and what type of card would be issued. The more sophisticated the smartcard used, the more often a card might have to be re-issued which would increase the scheme's costs. Over a three year period of developing the systems and a ten year period during which the cards would be valid, the total cost of a scheme would be around £1.5 billion. This figure is based on broad estimates of delivering large scale IT and distribution systems. The figure is subject to a number of caveats and should be treated with some caution. These costs do not take into account any savings to the Government in terms of more efficient administration of services and reductions in fraud. Neither do they take into account any additional revenue paid to the Government by partners who might wish to use the card to help administer their services. It is only after this consultation exercise that the Government will be able to make an estimation of the savings to Government Ð as it needs to know what services people would like to see linked to a card and also whether and how other organisations would want to make use of it.

14. Even if the net costs of a scheme were as high as £1.5 billion, these could be recouped by increasing passport and driving licence fees and by charging a fee for the non-driving licence/ entitlement card. The fee for the non-driving licence/ entitlement card would be lower than the current passport and driving licence fees (which are £30 and £29 respectively). The level of the fee increase would also depend on whether the card was a smartcard and how sophisticated the chip on the card would be. If a 10-year non-driving licence/ entitlement card cost £15, passport and driving licence fees would have to rise by around £10-£ 14 depending on the sophistication of the card. If a 10-year non-driving licence/ entitlement card cost £5 Ð which might be more affordable for less affluent groups in the population Ð this would mean a rise in passport and driving licence fees of around £14-£ 18, again depending on the sophistication of the card. For a further fee increase of £1, non-driving licence/ entitlement cards could be made available free of charge to the 10 million least affluent members of society. The Government is also investigating the feasibility of paying by instalments for some types of entitlement card. The caveats which apply to the cost estimate for a scheme, similarly apply to how the costs might be recovered through fees.

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15. The Government wants to see a full and informed debate on whether a scheme should be introduced. The publication of this paper marks the beginning of that process. By allowing 6 months for comments, the Government hopes that people and interested organisations will have time to consider the issues in depth. The Government is grateful for the contributions and suggestions which it has received since it announced it intended to publish this paper. In the months ahead, it will continue the dialogue it has started with various groups and broaden the range of organisations it has met to discuss the issues raised in this consultation paper.

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Chapter 1 INTRODUCTION 1.1 The UK is increasingly a card-carrying society. Most people are used to carrying forms of identity which are used to prove their entitlement to a wide range of products and services. Approximately 90% of adults hold some form of plastic card used for financial purposes. These include:

° ATM (Automated Teller Machine) cards Ð commonly referred to as 'cash cards' for withdrawing cash and obtaining other services from cash machines. ° Credit cards Ð which allow goods and services to be obtained on credit. ° Debit cards Ð which allow goods and services to be paid for by debiting the card holder's account directly. ° Store cards Ð a form of credit card issued for use by a particular retailer or chain of retailers.

1.2 Over 137 million plastic financial services cards are in circulation in the UK. Increasingly, one card offers more than one service for example most debit and credit cards can also be used as ATM cards. In addition to cards issued by the financial services industries, other types of plastic card are also issued by organisations as diverse as:

° local authorities, for example to access library services or concessionary travel; ° clubs, such as health clubs which often use cards to control access to their facilities; ° rail and bus companies for season tickets; ° retailers for loyalty card schemes; ° other private sector service providers such as motoring organisations.

Since 1998, the Government has also issued plastic cards to over 10 million people in the form of photo-card driving licences.

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1.3 The Government wishes to consult the public and interested organisations on whether it should introduce an entitlement card scheme and if so what form that scheme should take. A card scheme would entail:

° establishing a secure database which could potentially hold core personal information about everyone who is lawfully resident in the UK; ° implementing rigorous procedures to ensure that the information held on the database was accurate and protected from unauthorised access; ° linking the core personal information to other databases which held service entitlement information. This would allow service providers to deliver their services more efficiently and effectively and in a way which made it simpler for people to gain access to the services to which they were entitled; ° issuing entitlement cards to everyone on the central database so they had a convenient way to access services.

This consultation exercise seeks views on whether using an entitlement card would: ° be more convenient for those using services, for example through not having to provide the same information many times over to different Government agencies and through not having to carry a number of cards to access a range of services; ° ensure that people who might have difficulty in obtaining entitlement to services can do so more easily on production of a card; ° allow the Government to administer services more efficiently; ° help to tackle illegal immigration and illegal working by providing a straightforward way for service providers to check entitlement to services and for employers to check eligibility for work.

It also seeks views on what services people would find most useful to link to a card and which service providers in the public and private sectors would wish to use a card scheme.

1.4 If a card was issued subject to stringent security checks such as those associated with passports and driving licences, public and private sector organisations might also use the card to help reduce levels of identity fraud. There are other measures to combat identity fraud which the Government could implement on a faster timescale and at lower cost than an entitlement card scheme. This consultation exercise also seeks views on some of these measures.

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1.5 A card scheme also has drawbacks. People might regard a card as an unnecessary intrusion into their privacy, especially if the scheme required everyone to have a card. It would take some time to set up a scheme and issue cards in sufficient numbers to cover most or all of the population. It might take some time before the up-front costs Ð which might have to be met by fees Ð would yield additional benefits to card-holders. The project would be complex and subject to the risks confronted by all large scale IT projects. The Government would not proceed with a scheme without a full cost-benefit analysis, and a proper risk assessment of the challenges posed by the procurement and roll-out. These studies would be published alongside any decision to proceed.

1.6 Chapter Two of this paper discusses the pros and cons of different types of scheme, for example whether a scheme should be voluntary or universal. It also discusses how a scheme could be established in law.

1.7 Chapter Three discusses some of the potential uses of an entitlement card such as helping to provide better access to Government services and helping to reduce identity fraud.

1.8 Chapter Four discusses some other ways of dealing with identity fraud. It should be read in conjunction with a detailed report on the extent of identity fraud and possible measures to deal with it which the Government is also publishing (www. homeoffice. gov. uk/ dob/ ecu. htm).

1.9 There are many different ways in which a national entitlement card scheme could be set up and run. Chapter Five outlines one option in order to help inform debate about the advantages and disadvantages of a national card scheme. Further detail is provided at Annex 4. The Government would welcome suggestions for improvements to the suggested scheme or other ways in which it could be provided.

1.10 Chapter Six discusses how a scheme would need to comply with the principles of the Data Protection Act 1998 and the Human Rights Act 1998.

1.11 Annexes to this paper provide a summary of all the consultation points in the paper, a brief history of identity cards during the First and Second World Wars, a summary of schemes operating in some other countries, a more detailed description of the scheme outlined in Chapter 4 and a more detailed discussion of how the cost estimates were arrived at.

1.12 The Government hopes that the consultation will be widespread and will be pleased to facilitate meetings around the UK where the issues can be debated. The consultation exercise will last until 10 January 2003.

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Comments should be sent to: Stephen Harrison Entitlement Cards Unit Home Office 50 Queen Anne's Gate LONDON SW1H 9AT

Or they can be sent via email to: entitlementcardsunit@ homeoffice. gsi. gov. uk

A copy of this paper and the more detailed report on identity fraud is available on: www. homeoffice. gov. uk/ dob/ ecu. htm All comments received on the consultation paper may be published unless the person or organisation making them specifically asks for them not to be.

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Chapter 2 THE OPTIONS FOR AN ENTITLEMENT CARD SCHEME 2.1 An entitlement card scheme would comprise: ° a central database (' the central register') capable of covering all of the resident population of the UK. The central register would hold core personal information which is commonly used by all service providers such as name and address; ° secure procedures for establishing entries on the central register and for keeping the information up to date so that people would not have to provide the same information time after time to different service providers; ° links between the central register and information held on other systems by service providers so they could make efficient use of the information stored on the central register. The links would need to be designed so that information about specific entitlements (for example medical restrictions on a person's ability to drive) were not made available to other service providers without consent; ° the issuing of plastic cards to everyone on the central register. The cards may incorporate some information and features on a microchip embedded into the card. These are commonly known as 'smartcards'. The cards could provide a convenient way for people to prove their identity and their entitlement to services in some circumstances. In other circumstances such as when services are provided over the telephone, the card-holder's entry on the database would be the main way to prove identity and entitlement.

P1.

Coverage 2.2 An entitlement card scheme needs to be capable, ultimately, of covering the whole population. Unless a card scheme can cover everyone, it is questionable whether it will be

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16 The Government invites views on the principle of establishing an entitlement card scheme as a more efficient and convenient way of providing services, tackling illegal immigration and illegal working and combating identity fraud. 17
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cost-effective to link it to major services. Without this degree of coverage, service providers and employers would need to maintain different ways of checking entitlement. As well as increasing certain costs such as staff training it is likely that more errors will be made if parallel systems are in operation. A scheme which was universal in its coverage would not need to be limited to services which were administered UK-wide (of which there are very few in any case). Each devolved administration or local authority could decide whether to link some of its services to an entitlement card scheme. But in order to give them that choice the scheme itself would need to be universal.

2.3 There could be one or more very targeted entitlement card schemes focused on specific services, regions or parts of the population. For example a card scheme could be used to verify access to particular services or facilities where there is a need to establish identity to a high degree of confidence for example benefit claims or obtaining a VAT Registration Number. In these cases only users of those particular services would require entitlement cards. Particular parts of the country might have problems which are less pressing elsewhere, for example the Government is implementing specific measures to combat electoral fraud in Northern Ireland. The Government is also issuing Application Registration Cards (ARCs) to asylum seekers to help them obtain the services to which they are entitled.

2.4 Even if an entitlement card scheme were limited to specific population groups or services, there would not necessarily be a proportional reduction in the cost of a targeted scheme compares with one which had wide coverage. For example the service the card was linked to might still be nation-wide (for example VAT Number Registration) and so the method of applying for cards might still need to be nation-wide even if only part of the population was covered.

P2.

Voluntary or compulsory? 2.5 The debate on identity or entitlement cards is often confused by imprecise use of the adjectives which describe possible schemes. The following paragraphs discuss the different ways that schemes are often described and then defines precisely what the Government means by the different options available. The Government hopes that this will be helpful to those participating in the consultation exercise.

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17 Should the Government give consideration to one or more targeted entitlement card schemes and if so what sort of schemes should be considered? 18
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2.6 A voluntary entitlement card scheme would be one where: ° it was entirely at the discretion of the individual whether they registered with the scheme and obtained a card; ° it would be the individual's choice whether or not to use a card to access particular services i. e. there would always be a way to gain entitlement to a particular service without a card.

2.7 A universal entitlement card scheme would be one where: ° everyone in the country over a certain age was required to register with the scheme and to obtain a card; ° a card would be the only way to access particular services (other than in an emergency or in cases where a card had been lost or stolen). An analogy could be drawn with taking a driving test. To take a test, the candidate needs to have registered with the Driver and Vehicle Licensing Agency (DVLA), obtained a valid provisional driving licence and produce it at the test.

2.8 A compulsory entitlement card scheme would have the same characteristics as a universal scheme but would also include a legal obligation to carry a card or to produce it within a certain time at the request of a police officer or other authorised person.

2.9 Because a voluntary scheme could never guarantee complete coverage of the population, service providers would need to support different ways of checking the entitlement of the people they serve. Benefits to service providers would therefore be lower than for a scheme where everyone was required to have a card. Another drawback of a voluntary scheme could be that those people who could most benefit from having a simple, straightforward way to assert their rights and entitlements might be among the least likely to apply for a card. From the point of view of society as a whole, the greatest benefit of an entitlement card might well be negated if a section of society were not to take up the card and the protections it could afford to the broader community would be reduced or eliminated.

2.10 A voluntary scheme could help to ensure that more effort would be made to make a card genuinely attractive to cardholders. It could help to keep the issuing organisation focused on meeting customer needs and improving the range of benefits associated with the card. However even with the best conceivable service, there would always be some part of the population not covered. Even if coverage was not universal, a voluntary card scheme would provide everyone with the opportunity to possess an official form of Government-issued proof of identity and entitlement. This is not the case at present as only people who qualify

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for driving licences and passports can obtain such a document. If cards were widely held, service providers might still be able to rely on a card scheme to help them administer their services, though they would also have to have other ways to determine identity and entitlement.

P3.

2.11 The main advantage of a universal scheme would be that it would ensure complete coverage. However universal coverage is not an end in itself, rather it would be a means to ensure more consistent and efficient delivery of services linked to the card scheme and also to realise more benefits which would be linked to the degree of card ownership such as helping the private sector combat identity fraud. The disadvantages of a universal scheme are:

° some people might regard the requirement to have a card as an unwarranted intrusion into their personal lives and might find the process of applying for a card inconvenient; ° if a fee was charged for a card, some people might not be able to afford it; ° service providers would need to have special procedures to identify genuine cases of loss or theft of a card, if the sanction for not having a card was to be denial of service.

2.12 Of course a card scheme cannot dictate to service providers that the card should be the exclusive means of accessing their services. However if they did not make the card the only route to apply for or to demonstrate entitlement to their services, they would have all of the disadvantages of a compulsory scheme without the most important benefit i. e. a consistent and efficient way to identify who was entitled to the service. Requiring a card to be produced for particular services need not mean that it would be required for every service. It could be a matter for each service provider to opt into the scheme when it was deemed most appropriate for them to do so for example after a period of consultation with those who would be most affected.

2.13 The required use of a card would not preclude other ways of accessing services in an emergency for example when a card had been lost or stolen. No person would be denied access to a service in these circumstances. However a universal card scheme could still have a role in these cases, for example a service provider could be able to check with the card issuing authority that a card had been reported lost or stolen.

2.14 The key to being able to determine entitlement in cases where a card had been lost or stolen would be for the database which administered the scheme to have universal coverage of the population. Some services Ð particularly those where there is little or no face to face contact

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(such as services provided via telephone call centres) might use the card scheme without making use of the card itself. They would access the information held on the card issuing database (with the consent of the card-holder).

2.15 The Government has already ruled out the option of a compulsory scheme and does not wish to consult on it. Supporters of a compulsory scheme advocate that it would help the police to identify suspects. The current police powers in this area are set out below. Identifying a suspect is not usually a problem for the police, the vast majority of people they come into contact with are already known to them.

2.16

P4.

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20 POLICE POWERS OF IDENTIFICATION The police generally have no powers to require a person to provide them with information about their identity. However under section 25 of the Police and Criminal Evidence Act 1984, a constable may arrest a person on suspicion of committing an offence which would not normally be subject to powers of arrest, if the identity of the person cannot be readily ascertained or there are reasonable grounds for doubting whether the name and address provided by the person are genuine. The provisions also apply in Northern Ireland by virtue of Article 27 of the Police and Criminal Evidence Act (Northern Ireland) Order 1989. In Scotland under section 1 of the Criminal Justice (Scotland) Act 1980, if a constable has reasonable grounds for suspecting that a person has committed, or is committing an offence, the constable may require the person to give his or her name and address. Failure to comply with that requirement is in itself an offence.

Views are invited on whether the Government should implement a universal entitlement card scheme where: (i) it would be a requirement that all lawful residents of the UK over a certain age register with a scheme and obtain a card; (ii) service providers would be free to decide whether or not to use the card scheme as the means to access their services; (iii) service providers who did choose to use the card scheme would make the scheme the exclusive way to access their services (with exceptions for emergencies such as lost or stolen cards); (iv) some services would rely on the database which administered the card scheme rather than require production of a card if that was a more efficient and convenient way to provide the service. 21
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Legal basis for a scheme 2.17 An entitlement card scheme for UK citizens only could be implemented without legislation if it was based around passports which are issued under the Royal Prerogative. However the Government wishes to consult on a scheme which would cover UK residents and this would therefore require primary legislation. It also believes that primary legislation is the appropriate way to implement a scheme in any case. The scope of any legislation would need to cover:

° the establishment of an entitlement card as a legal entity; ° powers to make regulations on how entitlement cards could be issued (as is currently the case for the issuing of driving licences); ° creation of criminal offences for making fraudulent applications for cards, fraudulent use of cards and counterfeiting of cards; ° the provision of any information sharing powers necessary to check applications for cards (see Chapters 5 and 6); ° rules for the sharing of any information contained in the card issuing database with other parties; ° penalties for failure to notify changes to personal details for example change of address or change of name.

2.18 As one of the primary suggested uses for an entitlement card scheme is as an immigration control measure to help combat illegal working, any legislation would be a matter for the Westminster Parliament. However the Westminster Parliament could not create specific criminal offences in Scots Law associated with an entitlement card scheme (for example making a fraudulent application for a card) without the consent of the Scottish Executive and Parliament.

2.19 As with driving licences, the detailed rules on how entitlement cards could be issued would probably be best left to secondary legislation. For example the Government would want to be able to introduce changes to the scheme quickly should the design of a card become seriously compromised by counterfeiters. It would be unnecessarily disruptive to the Government's legislative programme to have to introduce emergency primary legislation in such circumstances. It would not be the Government's intention to make significant changes to any entitlement card scheme via secondary legislation. For example it would not be possible to make a voluntary or universal scheme into a compulsory scheme without a change in primary legislation.

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Views are invited on what the contents and scope should be of any legislation to implement an entitlement card scheme.

2.20 It could be possible to link use of the card scheme to particular services in the primary legislation which established the card scheme itself. However it could be many years before cards were widely or universally held. A better option might be to wait until the scheme was established and require each particular service to amend its own rules or enabling legislation when it wished to adopt the card. An example might be the use of a card to help combat illegal working (which is discussed further in Chapter 3 paragraphs 13-20). It would only be when a card was widely held that the regulations deriving from the Asylum and Immigration Act 1996 would be amended to make the card the only means by which employers could comply with the law on checking the eligibility of their employees to work in the UK. This is arguably a more open and transparent approach to linking the card to specific uses over time. However it does mean that Parliament might be asked to approve a card scheme without a complete description at the time of the full range of its potential uses.

P5.

2.21 If the Government decided to proceed with a universal scheme it would have to decide how to ensure that all the population was covered. It could allow a period of grace where card ownership would be voluntary or linked to the renewal of other documents such as driving licences or passports so that ownership would rise gradually. There could then be a specified date by which everyone would be expected to obtain a card.

2.22 The sanctions for failing to obtain a card would depend on the uses of the card. In most cases the sanction would be denial of service, subject to the need to ensure that people whose cards had been lost or stolen could still receive services while waiting for a replacement. In some card schemes in Europe there are criminal sanctions for failure to have a card. A system of civil or criminal sanctions could be employed in a UK scheme, although as the primary purpose of a card scheme is to prove entitlement, the Government believes that denial of service would be sufficient means to ensure that cards were widely held provided that a wide range of service providers adopted the card. If an entitlement card was issued in the form of a driving licence, the criminal sanctions for failure to possess and produce a card when it was being used as a driving licence would remain.

2.23 Card holders would also have a duty to inform the card issuing authority of any changes to certain personal information such as change of address or change of name after marriage. Similar requirements already exist for driving licences and passports. It is already an offence to fail to inform DVLA of a change of name or address.

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Views are invited on what powers the Government should have to require cards to be held in any universal scheme and what incentives and sanctions there could be to help ensure universal coverage.

P6.

2.24 If a card scheme was linked to passports and driving licences as set out in Chapter 5, it would need sufficient flexibility to cover situations where a person was banned from driving or had to surrender a passport for example because of an order made under the Football Disorder Act 2000. Under the possible scheme set out in Chapter 5, there would always be an alternative form of entitlement card available to a UK resident should a driving licence or passport be withdrawn.

2.25 The Government might also use legislation for an entitlement card scheme to make it an offence to provide fake identity documents and other forms of entitlement card such as a proof of age card which can often be passed off as genuine. Under current law, use of such cards can be illegal if they involve some form of deception, but the supply of such cards is not necessarily an offence.

Unique personal number 2.26 Any card scheme would have to be administered by a database which would require each person registered on the system to have some form of unique personal number or identifier. However it is a separate issue whether this number would be visible on any card and available for use by the card-holder and other organisations.

2.27 Different personal numbers have developed over time for different uses for example the National Insurance number, driver number and NHS number. Many large IT systems which administer tax, benefits, driving licence and other systems depend on these numbers. The introduction of a card scheme could offer the opportunity to rationalise their use. However if an entitlement card scheme was voluntary it could not be guaranteed for example that all people who currently had a National Insurance number would also have an entitlement card. There would also be very significant and probably prohibitive costs to revise existing IT systems to use a different numbering scheme.

2.28 However it would be possible to develop cross-references between any unique personal number in an entitlement card scheme and other numbering schemes. There would be two main advantages to this approach. Firstly it would allow other Government organisations to identify discrepancies in their records and amend them as entitlement cards were issued without incurring the costs of re-writing their systems from scratch. However the cost of

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developing such cross-referencing systems may also be significant and would need a clear business justification. A second advantage would be that new services in the future could choose to use the unique personal identifier rather than developing yet another number. However if an entitlement card scheme was voluntary there could again be problems of inconsistent coverage between any new service and the card scheme.

2.29 A unique personal number need not be a new number developed from scratch. It could be based on one of the existing numbering schemes which would have the advantage of reducing by one the potential number of cross-references to other identifiers. The main options for use of an existing number would be the National Insurance number and the drivers number. Although the NHS number has a very wide coverage of the population, it is not as widely known or used by the population at large and its use as a unique personal identifier might raise concerns over the confidentiality of medical records.

2.30 Chapter 5 discusses using driving licences as part of an entitlement card scheme. Although each driver number is unique, a person's driver number can change over time for example if a woman changes her name when she marries this has to be reflected in a new driver number (as the number incorporates part of the name). This ability for a person to change their driver number would make the administration of a unique personal number based on driver numbers more complex than it would need to be. A person's driver number also changes when they exchange a Northern Ireland driving licence for one issued by the DVLA and vice versa.

2.31 The National Insurance number has the widest coverage of all the numbering schemes consisting of 82 million records (including 13.5 million records for people who are dead). While the process of allocating National Insurance numbers to adults has been tightened up significantly, there remain some instances where people have been issued with more than one National Insurance number (though not necessarily through fraud on their part). It might be unwise to rely on a number where there are known problems with data quality as the basis for any new scheme.

2.32 On balance the arguments point in favour of a new unique personal number for any entitlement card scheme. The number could be cross-referenced to other personal numbers. Whether or not these cross-references would be developed would depend on the type of card scheme and the uses of the card and its supporting database. Given the potential for increased data sharing about individuals which might result from a card scheme, and the right of card-holders to know what data sharing is taking place, there is a strong case for making a unique personal number known to the card-holder and ensuring it is visible on the card. It could also provide a convenient reference for card-holders to use if they needed to correspond with the card issuing authority for example when reporting lost or stolen cards. Data protection issues are discussed in more detail in Chapter 6.

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Views are invited on whether any entitlement card scheme should allocate a unique personal number to each card holder, what form any number should take and whether it should be incorporated onto the card itself.

P7.

A population register 2.33 Associated with the range of personal numbers discussed in paragraph 27, there is a multiplicity of large public databases on UK residents, including those for National Insurance, income tax, the NHS, driving licences, vehicle owners, passport holders and voters. Each one holds between 35 and 75 million records. Each database attempts to capture similar core information about people, yet there are inaccuracies and some data is out of date. These arrangements are costly and inefficient, and inhibit the joined-up delivery of public services.

2.34 The Government is also examining the scope for linking public databases on the resident population to improve efficiency and joined-up public service delivery. In particular the Government is examining the feasibility of developing a high-quality common population register, holding core data and a unique identifier on UK residents that could be used across the public sector.

2.35 Such a database would hold a very limited range of core information about people, such as their name, address, date of birth, sex and a unique personal number. A population register should be more accurate and transparent than existing databases, and would have stringent safeguards to protect the privacy of personal data.

2.36 A population register would have the following practical advantages: ° There would be important customer service benefits, enabling people to enter core data only once, and allowing service providers to deliver more personalised, pro-active and targeted communications and services. (There would be additional benefits if people could volunteer to place supplementary information about their circumstances on the database, to help service providers target services more appropriately.) As discussed in paragraphs 26-32 above, people would ultimately have a single identifier number for interacting with state. A common database would be indispensable for enabling more joined up and internet-based delivery of public services. ° There would be substantial gains in efficiency within the public sector by simplifying processing, facilitating matching of records, and reducing error. The common database would replace the core data held inaccurately on existing databases and could in time replace the electoral register. ° The common database could also help deter some kinds of fraud.

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2.37 Many other countries are investigating how citizen databases can be integrated to improve public service delivery. Some countries (such as Sweden) already have a well-established population register.

2.38 Developing a Population Register would represent a major challenge and require a sustained and high-level political leadership and prolonged commitment by the public bodies involved. It would take many years to yield its full benefits.

2.39 The Government nevertheless believes that a more integrated approach to citizen databases is indispensable to realising the Government's ambitions for a more modern, joined-up and internet-based approach to public service delivery.

P8.

2.40 As an entitlement card scheme would need to be underpinned by a database of all UK residents, an issue for consideration is whether this database should be the national population register as discussed above or a new self-standing database.

Views are invited on the development of a national population register which could be used in a sophisticated way across the public sector with the aims of improving customer service and efficiency.

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Chapter 3 POSSIBLE USES FOR AN ENTITLEMENT CARD 3.1 This Chapter sets out the areas where an entitlement card might be used. The Government wishes there to be a completely open debate about the possible uses of a card both by the public and private sectors. The suggested scheme set out in Chapter 5 which builds on the driving licence and passport schemes would mean that entitlement cards would have some basic core uses:

° as a driving licence, possibly with some enhancements such as storing insurance and vehicle details on a smartcard chip; or ° as a travel document in the European Economic Area and possibly other countries.

3.2 However this chapter mainly focuses on broader potential uses of an entitlement card scheme. The Government would welcome views from individuals and organisations in the public and private sectors as to whether a card would be helpful to them in delivering their services and what features they would like to see in a card scheme to allow them to make most use of it.

Providing better services 3.3 Public services in the UK have developed their own individual ways to identify the people they need to serve and to determine what their service entitlements are. As a result, people need to provide the same information about themselves to many different organisations. They may also need to provide the same document such as a birth certificate a number of times. As well as being irritating, this can lead to delays in people getting the services they are entitled to. At the extreme, people might not apply for services they are entitled to, especially if they have difficulty filling in forms or using the telephone.

3.4 When personal information changes for example on moving house, a wide range of public and private sector organisations needs to be informed. This can be time consuming and can

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leave people open to the risk of fraud if they forget to inform all the organisations they deal with. Correspondence can go astray and be used to obtain goods and services fraudulently in their name, damaging their credit rating.

3.5 An entitlement card along with the information held in a supporting database could provide a simple way for people to provide core personal information to a range of central and local Government services. As more services are delivered over the telephone, the ability to use information in the database would be particularly helpful, provided there were adequate controls on access to and use of the information. There is also a commitment to provide more Government services over the Internet. An entitlement card scheme could support this in two ways:

° by providing a means to check that people are who they say they when they access a service (authentication); ° by storing some service entitlements electronically on a microchip embedded in an entitlement card (a so-called 'smartcard').

3.6 As well as benefits for users of services there could be benefits for service providers. These could be passed on to the public through improved service levels and lower costs. Just as users of services have to provide the same information time after time, each service provider also has to key it in to their systems. Time and effort is wasted in confirming details on incomplete forms. Organisations repeat checks which have already been done by others. Access to core personal information held either on a card or in a supporting database could help service providers deliver more efficient and responsive services. Some new services which required some form of card might not be affordable because of the cost of administering a dedicated card scheme. However they might be able to proceed by using an already existing entitlement card scheme. Existing cards such as loyalty cards issued by retailers could use the entitlement card, saving the cost of producing and distributing cards. Organisations might also be able to make use of cards for internal purposes for example access control to their premises or computer systems.

3.7 However a move to relying on an entitlement card as a universal gateway to a range of services would be complex with significant set-up costs and also raises a number of concerns:

° each service would face transition costs in adapting IT systems and procedures and in training staff; ° as it would be some time before cards were widely held, services would need to be able to deal with those without cards as well as card-holders. Unless cards became mandatory for all users of a particular service, it would have to maintain at least two ways of operating indefinitely;

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Views are welcomed on whether an entitlement card scheme would allow for more efficient and effective delivery of Government services and what services people would most like to see linked to a card scheme.

Views are also welcomed from organisations providing services in the public and private sectors on whether they would like to link their services to a card scheme and what features they would want to see in a card scheme that would most benefit their services.

° if the card scheme became the only way to access a very wide range of services, people might be denied services while they waited for a replacement for a lost or stolen card unless there were effective procedures in place to check records on the central register in the absence of a card; ° most people interact with Government infrequently compared with other services. This is particularly the case for central Government as opposed to local Government services. There may be limited value in a card which simplified just a few of their dealings with service providers; ° a significant amount of personal information would be held in one place and there would need to be sufficient safeguards to prevent abuse; ° the project would be large scale and challenging with the kinds of major risks associated with any large IT project; ° retailers and other organisations might be reluctant to use the card in place of their own cards because of the loss of brand identity.

3.8 Any scheme would have to address these concerns. Lessons should be learned from past IT projects and sufficient time should be set aside to design, develop and implement a scheme with a thorough analysis and ongoing management of the risks. A balance would need to be struck between ensuring that the first cards issued were sufficiently useful to encourage people to want them, while avoiding building too much risk into the scheme from the outset by linking them to a large number of services from day one. A phased approach would need to be adopted both in terms of linking services to cards and in how 'hi-tech' the cards themselves were.

P9.

P10.

Identity Fraud 3.9 Identity fraud where a person adopts a completely false identity, falsifies part of their identity (for example their age) or adopts the identity of another person is estimated to cost the UK at least £1.3 billion each year split equally between the public and private sectors. The true cost of this crime is difficult to measure. It is often linked to other crimes of conspiracy,

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fraud and deception, ranging from opportunistic impersonation to very sophisticated money laundering and people-trafficking operations.

3.10 An entitlement card scheme could help to combat identity fraud if it provided a higher level of assurance of a person's identity than existing documents such as a passport or driving licence. The benefits would be maximised if:

° the card scheme was flexible in how it could be used to prove identity. If a scheme only provided proof of identity when the card was shown, this would severely limit its usefulness as organisations move to provide their services over the telephone and the Internet; ° the process for applying for a card was simple and not in addition to applying for other forms of Government issued 'identity' documents such as the photocard driving licence and the passport; ° the card scheme could be used by the private sector where at least half of all identity fraud takes place.

3.11 The main drawbacks of depending on a card scheme to counter identity fraud are: ° it will be some years before entitlement cards are widely held. There would be a need for legislation before the systems could be developed and cards would probably be issued gradually; ° it is highly likely that an entitlement card scheme would become the target of organised criminals who would attempt to produce counterfeit cards. Even if counterfeit cards could be detected by sophisticated checks, many people might still be fooled by them and become victims of crime; ° best practice in combating identity fraud stresses that organisations should not rely on a single source document or check to establish a person's identity. Organisations should make a number of checks from different sources. The range and sophistication of the checks will depend on the value of the product or service offered. Some commercial organisations have indicated their reluctance to undertake checks on identity Ð preferring to tolerate a level of fraud Ð unless they can clearly identify a financial benefit which would outweigh the cost of the checks.

3.12 The Government is not relying on a possible entitlement card scheme as the only measure it will take to combat identity fraud. A report from a Cabinet Office led study on identity fraud is also being published (www. homeoffice. gov. uk/ dob/ ecu. htm). This identifies a series of measures which the Government will take in the short term along with some other projects about which it wishes to consult. More details of these projects are provided in Chapter 4.

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Views are sought on whether an entitlement card scheme would be a cost effective additional measure against identity fraud and related criminal activities such as money laundering.

P11.

Tackling illegal immigration and illegal working 3.13 The Government's White Paper Secure Borders, Safe Haven published in February (CM 5387) set out a range of measures to deal with the problems of illegal immigration and illegal working. As entitlement cards would be available only to lawful UK residents, it would help those who had recently arrived lawfully in the country to gain entitlement to services as most entitlements are linked to lawful residence. In the absence of a straightforward way to demonstrate entitlement in the way that could be offered by a card scheme, it can be difficult for service providers to ensure that only those entitled to services get them. The impression that it is easy to obtain a range of public services in the UK with minimal checks on entitlements, adds to the 'pull' factor which encourages people to risk their lives at the hands of people traffickers and other organised criminals. An entitlement card which was widely recognised and was issued to all legal migrants whatever their route into the UK could be an important measure to combat illegal immigration.

3.14 Another important component of the pull factor is the impression that those in the UK illegally can obtain work easily and those in the UK legally but with no right to work can also obtain employment. By its very nature, the scale of the problem is extremely difficult to measure. The problem is particularly severe where the availability of work is greatest. Lower wage employment sectors such as catering, cleaning and hospitality are particularly affected. Other sectors such as the construction industry and agriculture are disproportionately affected but the problem is not limited to these areas. Winston Churchill's statement in 1909 when Wages Councils were established that "the good employers are undercut by the bad, and the bad are undercut by the worst" still rings true today.

3.15 Section 8 of the Asylum and Immigration Act 1996 made it an offence for employers knowingly or negligently to employ people who have no permission to work. The maximum penalty that can be imposed on an employer if the offence is proved is £5,000 per illegal employee. Employers can establish a defence by proving that they were shown one of a number of documents showing entitlement to work and that they believed this to be genuine. The measure has not proved an effective deterrent with less than 30 convictions

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in the year 2000. Employers are often confused about their duties, are unclear how to verify employment status and may not be able to detect fraudulent documents.

3.16 One of the measures the Government announced in the White Paper was that it would limit the range of identification acceptable for Section 8 compliance. In the Nationality, Immigration and Asylum Bill currently before Parliament the Government proposes:

° to give greater flexibility to the sort of document that the Secretary of State can require an employer to see in order to establish a statutory defence. For example, under the new provisions the Secretary of State will be able to require the production of one or more documents establishing the employee's ability to work and one or more documents establishing the employee's identity. The previous provisions allowing the Secretary of State to require the employer to take specified steps to retain or record these documents before he can establish his statutory defence will be retained; ° to extend the powers of immigration officers in relation to the investigation and prosecution of suspected offences under the 1996 Act to confer powers of search, entry and arrest directly on immigration officers in relation to a section 8 offence.

These changes would not impose an additional burden on employers and businesses. They would not have to alter their recruitment procedures. The Government is simply clarifying what is expected of employers and making it easier for them to comply with the legislation.

3.17 Looking beyond the immediate proposals in the Bill, the Government would like the views of employers and other interested organisations as to whether an entitlement card scheme would be helpful in meeting their obligations under the law. If an entitlement card contained a clear statement of the card-holder's eligibility to work, was very difficult to counterfeit and the card scheme provided a simple way for employers to check valid cards it could Ð over time Ð become the sole way for employers to comply with Section 8 of the 1996 Act. In order to achieve this:

° entitlement cards would have to be issued to everyone who was lawfully resident in the UK, i. e. the scheme would have to be universal; ° cards would have to be issued promptly to avoid there being an undue delay between a person taking employment for the first time and obtaining a card. Employers would be allowed a period of grace if the employee was waiting for a card; ° employers would need to be able to check the entitlement card database to confirm that an employee without a card had an application pending for a new or replacement card. This check would not necessarily need on-line access to the database, it could be provided by telephoning a call centre.

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3.18 The need to determine eligibility to work could complicate the process of applying for an entitlement card as it would require specific expertise in interpreting the immigration rules. However for the vast majority of entitlement card holders, eligibility to work would be straightforward as all UK citizens and citizens of other countries in the European Economic Area (EEA) have a right to work in the UK. (The European Economic Area comprises the countries of the European Union together with Iceland, Liechtenstein and Norway). The card could be issued on the production of valid documentation showing eligibility to work such as a national identity card from an EEA country or a copy of a work permit issued to the employer. An entitlement card scheme could help deal with those who stay in the country for longer than they are allowed by setting the expiry date of the card to be the same as the document on which the card-holder entered the country for example the work permit. In other words a two year work permit would result in the issue of an entitlement card that lasted for two years only.

3.19 Adding an additional step to the process of hiring overseas workers (i. e. the need to apply for an entitlement card), might make the UK less attractive to those who can easily take up legitimate employment such as other EEA nationals and have an adverse effect in the economy. (Some EEA countries require UK citizens to hold foreign residents' cards when working in their countries). Small businesses in particular might be disproportionately affected. However this additional step would only apply once to UK and citizens of other EEA countries who were lawfully resident in the UK when they took up employment for the first time. Their cards Ð unlike those issued for example on the basis of a work permit Ð could be valid for several years (for example 10 years like a passport) and they would thus be in possession of a card (or registered on the central register) when they moved to other jobs. This should lessen the burden of checks on subsequent employers.

3.20 A card scheme on its own could not be wholly effective in bringing illegal working to an end. Many cases involve unscrupulous employers colluding with illegal workers and a card scheme could only be one part of the overall strategy which is set out in the White Paper. A card scheme would facilitate the more effective enforcement of the law, it would not be an answer on its own.

P12.

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Views are sought on whether an entitlement card should be available to UK citizens in a form which allowed it to be used as a more convenient travel document to Europe than the passport book.

A convenient travel document 3.21 Most citizens of EEA countries travel within Europe using their national identity cards rather than a passport. UK citizens must use a full UK passport book which is less convenient to carry than a card. The UK Passport Service has announced that it is examining the feasibility of introducing a passport card which would be issued alongside the passport book. Unlike current identity cards in Europe (with the exception of the new Italian identity card), the passport card would conform to standards laid down by the International Civil Aviation Organisation (ICAO) and endorsed by the countries of the European Union. This means that the passport card could also be valid for travel to countries outside Europe.

3.22 The possible entitlement card scheme outlined in Chapter 5 suggests using the passport card as one component of a scheme. As the card could only be issued to UK citizens, it would not on its own provide universal coverage. However it would provide a form of entitlement card which was clearly linked to citizenship and could have important symbolic value for those who acquired citizenship.

P13.

Proof of age 3.23 An entitlement card which clearly showed the age of the holder could be used to help retailers and licensees comply with the laws which restrict the sale of age related goods. In the absence of a national proof of age card, various schemes Ð some nation-wide, some local Ð have developed over the years. However the plethora of different schemes can be confusing for retailers who might not for example recognise cards produced by young people on holiday which were issued in a different part of the country. It is also increasingly easy to apply for fake identity or proof of age cards on the Internet which can also confuse retailers. Recognising the additional responsibilities placed on retailers by the Criminal Justice and Police Act 2001, the British Retail Consortium has proposed an accreditation scheme which would ensure that proof of age cards were issued to a common standard and incorporated a holographic logo which would be easily recognisable by retailers all over the country and would be difficult to counterfeit. The Government has welcomed this development.

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P O S S I B L E U S E S F O R A N E N T I T L E M E N T C A R D 35 Table 3.1 Examples of Age Restrictions ( not exhaustive) Age Restriction

5 Alcohol consumption under parental control Entry to pubs for which a children's certificate has been obtained (except Northern Ireland)

10 Agricultural or horticultural employment permitted (under parental supervision) 12 Entry to 12 certificate cinema films Purchase or rental of 12 certificate video films and games Ownership of a pet

13 Part-time employment (up to 25 hours per week) if a work permit is obtained 14 Employment as a babysitter Purchase of airguns Entry to pubs without children's certificates (except Northern Ireland)

15 Entry to 15 certificate cinema films Purchase or rental of 15 certificate video films and games Part-time employment (up to 35 hours a week for 15/ 16s) if a work permit is obtained

16 Full-time employment Consumption of beer, cider, sherry (and in Scotland wine) if consuming a meal outside the 'bar' area of a pub or restaurant (except Northern Ireland)

Purchase of tobacco Purchase of lottery tickets & scratchcards Purchase of knives

Purchase of sparklers & party poppers Purchase of razor blades Purchase of liqueur chocolates

17 Driving a car Purchase of crossbows

18 Purchase of lighter fuel & restricted solvents Purchase of fireworks Purchase of alcohol not previously permitted as above Entry to pubs in Northern Ireland

Entry to most nightclubs Entry to betting shops, bingo halls and casinos Playing fruit machines Entry to licensed sex shops Entry to 18 certificate cinema films

Purchase or rental of 18 certificate video films and games (and R-18 films from licensed video premises)

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Views are sought on whether an entitlement card would be an effective proof of age card, whether there should be a minimum age at which entitlement cards should be available and if so what that age might be.

3.24 For an entitlement card scheme to be an effective proof of age card, it would need to be available to young people over the full range of age restrictions that apply to various goods and services, some of which are illustrated in Table 3.1 above. Even if an entitlement card scheme was in place, there might still be a role for straightforward proof of age cards. Parents might be reluctant to apply for (and pay for) an entitlement card which was more expensive than a straightforward proof of age card unless the card provided other benefits for their child for example as a passport. Even so, some young people might be reluctant to carry a 'valuable' entitlement card (such as a passport card) to gain entry to places where it might be lost or stolen such as pubs and clubs.

P14.

Reducing crime 3.25 An entitlement card scheme's contribution to reducing crime would be greatest in the areas of tackling identity fraud, money laundering (where it could help financial services companies 'know their customer') and organised crime associated with people trafficking and illegal working.

3.26 It is debatable whether an entitlement card scheme on its own would have a significant effect on other types of crime. As discussed in Chapter 2, paragraphs 15 and 16, it is rarely the case that the police cannot identify suspects as most are already known to them. Those engaged in criminal activity are unlikely to carry a card.

3.27 An entitlement card scheme might provide some efficiency savings for the police if cards were widely held and if they were able to access the central database with consent. If cards could be read automatically (for example by a hand-held device), recording the details of people questioned and eliminated from enquiries could be straightforward if they happened to be carrying a card at the time.

3.28 In the police station, if identity was established, personal information could be entered into police systems via the card or the card database if suitable links were in place, saving the cost of keying personal information for example into custody systems. However this would require the subject's consent which would not be forthcoming in all cases.

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Views are sought on: (i) whether an entitlement card scheme would be effective in reducing crimes other than those related to identity fraud; (ii) whether an entitlement card scheme would reduce administrative burdens on the police; (iii) whether the police, the intelligence services and other organisations investigating very serious crimes such as HM Customs & Excise should have access to the central register Ð including biometric information Ð in closely prescribed circumstances in cases where they are investigating matters of national security or very serious crimes and what those safeguards should be.

3.29 The police might benefit from access to any biometric information (such as fingerprints, iris patterns or a digital photograph) held on the entitlement card database. (Biometric information is discussed in more detail in Chapter 5 paragraphs 20-24). However as noted, most offenders are already known to the police and their own biometric databases of fingerprints and DNA are much more sophisticated than anything envisaged for an entitlement card scheme. The thought that the police might have access to this information might cause public unease and lead to a lack of confidence in the overall entitlement card scheme. There may still be a case in very closely prescribed circumstances for the police, the intelligence services and other organisations investigating very serious crimes such as HM Customs and Excise to have access to the biometric information when matters of national security were at stake or for the prevention or detection of very serious crimes. However the Government would want to see a full debate on this point and seek views on what safeguards there should be. For example whether access to the database in these circumstances should be governed by a warrant applied for on a case-by-case basis.

P15.

Electoral registration and voting 3.30 An entitlement card scheme might be helpful in drawing up and maintaining the electoral register for example it could help administer rolling voter registration by automatically transmitting changes of address to the electoral register. There would not be a straightforward link between entitlement card holders and eligibility to vote. Some card holders such as foreign nationals from outside the EU would have no right to vote, nationals of other EU countries could vote in elections to the European Parliament but not in Westminster elections, UK citizens may be entitled to vote for more than one council if they are resident in more than one part of the country. So a card scheme could not itself substitute for voter registration but it might make the system more efficient and it might help to develop new ways of voting.

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3.31 An entitlement card could be shown at a polling station and make it easier to cast a vote at a polling station other than the designated one. Chapter 5 and Annex 4 discuss various ways that the central register supporting a card scheme might be used to validate the identity of a card-holder when sending applications by post or conducting business over the telephone or on-line. These could be used to support new ways of voting (for example by telephone) and to increase confidence in the security of voting by post if the latter became more widespread.

P16.

Emergency Medical Information 3.32 One of the most common suggestions from members of the public who write to the Home Office about identity and entitlement cards is that a card should hold Ð with the consent of the card holder Ð a limited amount of medical information for use in an emergency for example, current medication or allergies and also double as an organ donor card.

P17. Views are sought on: (i) whether an entitlement card should display emergency medical information and/ or

act as an organ donor card at the card holder's consent? (ii) if so, what sort of emergency medical information would be most useful to display? (iii) given space constraints on the card, whether storing emergency medical information on a smartcard chip on an entitlement card would be useful?

Views are invited on whether an entitlement card scheme would benefit the maintenance of the electoral register and facilitate new ways of voting.

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Chapter 4 COMBATING IDENTITY FRAUD 4.1 Identity fraud arises when someone takes over a totally fictitious name or adopts the name of another person with or without their consent. It is not easy to gauge the extent and nature of identity fraud as some instances of identity fraud are recorded as other crimes. An example would be the theft of a credit card. When the stolen card is used, the thief is adopting the card holder's identity. However the crime might be recorded as one of theft or obtaining property by deception. In some cases, organisations might not even record that a crime has been committed and write the loss off as a bad debt.

4.2 Despite the difficulty in measuring identity fraud, there is widespread consensus in the public and private sectors that the level is rising. A cross-Government study led by the Cabinet Office was set up to establish the nature and extent of the problem and to recommend how it might be tackled. The findings of this study will be published and made available at www. homeoffice. gov. uk/ dob/ ecu. htm. The report provides a comprehensive analysis of the problem and potential projects to counter it.

4.3 The report estimates that the minimum cost to the economy of identity fraud is £1.3 billion pa. Some examples of the extent of identity fraud in 2000/ 01 are:

° 3,231 driving tests were terminated prematurely because of doubts over the driver's identity; ° 1,484 fraudulent passport applications were detected; ° approximately 50 cases of fraudulent documentation were detected every month at Terminal 3, Heathrow Airport; ° in the course of a two week exercise targeted at Portuguese documents in June 2001, 59 fraudulent documents were detected at selected UK ports and the Benefits Agency National Identity Fraud Unit (NIFU). The majority were counterfeit identity cards, detected at NIFU; ° although there is little reliable information on the number of people trafficked into the UK, a recent Home Office study estimated that 1,500 women a year are trafficked for sexual exploitation;

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° in 1999 over 21,000 illegal immigrants were detected; during the same period 5,230 were removed or left voluntarily; ° 18,500 referrals were made to the Financial Services Authority under the money laundering regulations; ° 564 cases involving identity fraud were identified by the Benefits Agency's Security Investigation Service, whose specialist teams investigate organised fraud cases across the country; ° in the private sector, the credit reference agency Experian estimated that around 1-2% of transaction value is lost through fraud and that about 3-5% of all fraud is identity fraud.

4.4 As well as the immediate financial gain associated with identity fraud, it can also be associated with wider organised criminal activities. Examples include:

° trafficking of people into the UK and illegal immigration more widely. If illegal immigrants are to enjoy goods and services, from the public or the private sector Ð or, indeed to work Ð in the UK, they will usually require a (false) identity; ° drug running: drug couriers also often adopt a false identity rather than risk using their own; ° money-laundering. Money-laundering depends on concealment of identity, not on identity fraud per se (concealment may be achieved through the creation of a fictitious company as much as through false individual identities); ° organised fraud: to develop multiple identities to make fraudulent claims to state benefits or, in the private sector, credit card applications etc. Organised fraud Ð rather than individual fraud Ð is increasingly likely to be the source of identity fraud in future, as new technology, such as the introduction of chips on credit and debit cards and the requirement to enter a PIN (personal identification number) for each transaction will reduce the value of stolen cards. Fraudsters are increasingly likely to attempt to obtain cards by applying for cards in other peoples' names and redirecting or intercepting their post.

4.5 Combating identity fraud has often attracted a low priority compared with other types of fraud. Most fraud in the benefits system is not committed by people adopting other identities, rather they mislead the Benefits Agency about their status, for example they work while claiming benefits. While the number of fraudulent passport applications detected may seem large at 1,484, this represented just 0.03% of total passport applications in 2000/ 01. However it is likely that many instances of identity fraud are not detected. Certainly the rate of growth of identity fraud is rising considerably. Figures from CIFAS, the UK's Fraud Prevention Service) showed an increase in ID fraud of 462% in 2000 compared to the previous year.

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4.6 An entitlement card scheme such as the one set out in Chapter 5 of this paper could have an important role in combating identity fraud. However a card scheme itself could become a target for organised criminals to produce counterfeit cards. The existence of a card scheme could also mean that organisations could place too much reliance on the card and drop their guard in checking applications thoroughly. This could perversely result in an increased risk of identity fraud. Although the Government would look at options for increasing the take-up of cards if it decided to proceed with a scheme, it could take some time before cards were widely held and the full benefits of a scheme in combating identity fraud were realised. Whether or not a card scheme goes ahead, there is a need to identify and implement measures against identity fraud that could be implemented on a quicker timescale.

4.7 The card scheme suggested in Chapter 5 includes much of the good practice identified in the Cabinet Office report. Some of these good practice points such as greater use of biographical checks of applicants' details could be implemented without proceeding with a universal entitlement card scheme.

4.8 The Home Office now has responsibility for developing an identity fraud work programme. An early step will be to establish a new Identity Fraud Forum to steer the work. This will require the participation of a number of departments most affected by identity fraud such as the Department for Work and Pensions, the Inland Revenue, HM Customs & Excise, the Immigration and Nationality Directorate of the Home Office, DVLA and the UK Passport Service. The Home Office will also invite representatives from the private sector to join the Forum and participate in drawing up the work-programme and the projects which will follow.

4.9 Some of the areas where the Government would like to make early progress are: ° making legislative provision for data sharing between the UK Passport Service (UKPS) and the Driver and Vehicle Licensing Agency (DVLA) to allow the agencies to cross-check applicants' data. This would remove the need for some applicants for photo-driving licences to send their passport to DVLA or take it to a Post Office for examination if their passport was issued after 1998. (The Passport Service's systems hold digitised photographs of these passport-holders and a link between the agencies' systems would allow the photograph provided for the driving licence application to be compared with the one held on the passport system); ° investigating further the establishment of links to credit reference agencies for checking passport and driving licence applications. Checks via credit reference agencies can give confidence that a person has established a 'historical footprint' in the community by opening bank and credit card accounts and paying utility bills at an address. The Government is not proposing that it undertakes a credit-worthiness check before granting access to Government services. The check would be to help establish identity, particularly proof of

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The Government invites views on the early steps it would like to take to tackle identity fraud and welcomes expressions of interest from the private sector to collaborate in this work.

residence. People are more likely to inform utility companies and their credit card issuers when they move house than they are Government agencies as they deal with the latter less frequently. Credit reference agencies may be particularly useful 'one stop shops' for verifying a person's address because of the wide range of information sources they draw on; ° improving staff training on the scrutiny of applications, for example in the detection of fraudulent identity documents by sharing best practice across the public and private sectors; ° undertaking scoping studies to identify the costs and benefits of: -establishing a public sector database of known frauds and fraudsters and the degree to which information could be shared with a service which already provides this service for the private sector (CIFAS, the UK's Fraud Prevention Service); -checking the consistency of application details (e. g. address) for a range of services. A commercial service known as HUNTER which was originally developed by the Council of Mortgage Lenders provides this facility at present; -developing a management information system to record instances of identity fraud in Government and possibly the private sector for statistical and possibly for intelligence purposes; -developing a central register of stolen identity documents.

P18.

Consultation on potential identity fraud projects 4.10 There are a number of other potential activities and projects which could reduce identity fraud on which the Government is inviting views during this consultation exercise.

4.11 Chapter 5, paragraphs 17-19 set out how the Government could strengthen the checks on applications for passports and driving licences as part of an entitlement card scheme. If the Government decided not to proceed with an entitlement card scheme, there might still be merit in issuing passports and driving licences to these higher standards including the use of biometric information. There is increasing international interest in the use of biometric information on travel documents both to reduce the number of counterfeit documents but also to provide speedier clearance of passengers at busy terminals. In exploring the options for including biometric information on passports and entitlement cards, the Government will work with its international partners on using common standards. This should maximise the benefits to passengers, for example being able to obtain fast entry clearance in the UK and abroad by swiping a passport card through readers operating to common standards.

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If more secure passports and driving licences were issued based around a common identity database shared between the UK Passport Service and the DVLA, the Government invites views on: (i) whether it should take the necessary legislative powers to allow other departments to access this identity database to allow them to make their own checks; (ii) whether it should allow the private sector to access the identity database provided this was done with the informed consent of subjects.

P19. 4.12 The results of the checks associated with issuing more secure driving licences and passports could be recorded in an identity database shared jointly between the passport and driving licence systems. This information could be made available to other Government departments and the private sector to help them counter identity fraud. In the case of some Government departments where there was a clear justification the information could be made available without the consent of the person it related to, provided the necessary legislative powers were in place. For private sector organisations, the information would only be provided with the subject's informed consent.

P20.

4.13 A lower risk approach than that outlined at paragraph 12 might be for the Government to procure a service from the private sector which checked applications for services against a number of databases used by the credit reference agencies or similar organisations and selected biographical data held by the Government. The Government would still need new powers to allow the necessary data-sharing. Unlike a database linked to passport and driving licence applications which would conduct one-off checks when these documents were issued, this service could be used every time a person applied for a Government service.

P21.

C O M B AT I N G I D E N T I T Y F R A U D

43 Views are invited on whether checks on applications for passports and driving licences should be strengthened to the degree outlined in Chapter 5 whether or not the Government decided to proceed with an entitlement card scheme based around these documents.

Views are sought on whether the Government should procure a service from the private sector which checked applications for services against a number of databases used by the credit reference agencies or similar organisations and selected biographical data held by the Government. 44
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A new criminal offence of identity fraud 4.14 The Government believes that there is a case for consulting on the creation of a new criminal offence of identity fraud which would also cover identity theft. The use of a false identity or the adoption of another person's identity is not a criminal offence unless it can be proved that there was some conspiracy to commit a criminal act or fraud, or it can be proved that a criminal act or fraud took place. However in these circumstances, the defendant would be prosecuted for the conspiracy or criminal act itself as this would be the more serious offence and would carry a higher penalty.

4.15 By making it an offence to use a means of identification of another person or a fictitious person without reasonable cause, the very act of using a false identity would be a criminal offence without the need to prove any criminal intent or conspiracy. This would provide the police with the means to disrupt the activities of fraudsters in the early stages of their criminal activities, for example while they are conducting business using false identities in preparation for a money laundering exercise or the importation of drugs. At present the authorities must wait until they have sufficient evidence to prove conspiracy or the main criminal offence itself. If they wait, they run the risk that the criminals might succeed and escape arrest or that the prosecution for the main offence might fail because of the complexity of the case or for other reasons such as witness intimidation.

4.16 As the offence would not require any criminal intent to be proved, the Government believes that the offence should be summary-only and should attract a maximum sentence of 6 months imprisonment. If criminal intent could be proved, another offence attracting a higher penalty such as a conspiracy offence could be used. Defendants would need access to a reasonable defence to cover the more innocent uses of a false identity such as adopting another identity when fleeing an abusive partner.

P22.

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44 Views are invited on whether a summary-only offence of identity fraud should be created. 45
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Chapter 5 HOW A SCHEME MIGHT WORK IN PRACTICE 5.1 The previous chapters of this paper have set out the general arguments for and against different types of entitlement card scheme. While it is important to set out the issues in this consultation paper, most people and organisations have settled views about the principle of introducing identity or entitlement cards. The Government believes that people will be able to make a more informed decision about whether or not they would favour a card scheme if they had a clear view as to how a scheme might work in practice. This Chapter provides an overview of how one version of such a scheme could work. More detail is provided at Annex 4. All this material is illustrative rather than prescriptive. The Government has made no decision on whether or not to introduce an entitlement card. The option described is equally applicable to a voluntary or universal entitlement card scheme. There are other ways in which a scheme could be delivered and as part of this consultation exercise, the Government welcomes suggestions for how this suggested scheme could be improved or other ways in which a card scheme could be implemented.

A scheme based on passports and driving licences 5.2 Many people hold existing forms of photo-id issued by the Government in the form of a photocard driving licence or a passport. Around one-third of the 38 million holders of driving licences now possess a photocard licence. The UK Passport Service recently announced that it would seek to develop a passport card which would be issued alongside the passport book which would simplify travel to other parts of Europe and potentially other countries also. If an entitlement card scheme was introduced, rather than ask most of the population to have yet another form of photo-id, it would be sensible to make both of these cards forms of entitlement card. As well as not adding to the number of documents most people possess, a scheme based on driving licences and passports would also build on the expertise and systems of the DVLA and UK Passport Service (and possibly Driver and Vehicle Licensing Northern Ireland (DVLNI) if this agency issued cards to residents in Northern Ireland). This should be a lower-risk approach to introducing a card scheme rather than setting up a new organisation from scratch.

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5.3 Not all lawful residents in the UK would be covered by an entitlement card based solely on passports and driving licences. Some people are medically unfit to drive or disqualified from driving and others do not meet the requirements for a UK passport (for example nationals of other EU countries). In this suggested scheme a special variant of the driving licence entitlement card would be available which contained the same information as the driving licence minus driving eligibility and driver number information. Such 'non-drivers' licences are commonly used as forms of photo-id in the United States.

5.4 If the Northern Ireland administration did not wish DVLNI to be involved in any entitlement card scheme, residents of Northern Ireland who did not wish to hold the passport/ entitlement card could be issued with a non-driving licence/ entitlement card from the DVLA in Swansea.

5.5 Having two forms of entitlement card could be confusing although some people might welcome having more than one kind of card for convenience or in case one was lost or stolen. It is not possible to combine both the photocard driving licence and the passport card into one. Each must comply to standards agreed at either EU or international level and when their requirements are aggregated, the information which must be displayed cannot fit legibly on a card the size of a credit card. However the Government would ensure that both forms of entitlement card had a similar look and feel so that they would clearly belong to the same family of entitlement cards. They could display a common logo incorporating the words 'entitlement card' and security features so that they clearly belonged to one family of entitlement cards. (see figure 5.1)

5.6 Another advantage of building on passports and driving licences is that a large proportion of the population could be covered by an entitlement card scheme without them having to make a specific application for a card. Over a period of 5-6 years, around 35 million people would naturally come within the scope of the scheme:

° as they applied for a passport or driving licence for the first time; ° when they renewed an existing passport or photo driving licence; ° when they applied for a replacement passport or driving licence if their existing document was lost or stolen; ° when they informed DVLA or the UK Passport Service of a change of circumstances such as a change of name after marriage or (for driving licences only) a change of address.

5.7 In order to ensure that a scheme had universal coverage, people who did not qualify for a driving licence or passport could apply for the non-driving licence/ entitlement card described in paragraph 3 above at any time.

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P23. H O W A S C H E M E M I G H T W O R K I N P R A C T I C E

47 Figure 5.1 Illustrations of possible forms of entitlement card This figure illustrates how the different possible forms of entitlement card might look. These pictures are illustrative only and do not represent how any forms of entitlement card might look should the Government proceed with a scheme.

Comments are invited on whether any entitlement card scheme should be based around a passport card and the photo-driving licence (including a non-driving licence/ entitlement card). In particular, comments are invited on whether having a family of cards rather than a single card would be helpful or confusing. Suggestions of other models for an entitlement card scheme are also invited. 48
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E N T I T L E M E N T C A R D S A N D I D E N T I T Y F R A U D 48 Entitlement cards for young people 5.8 The scheme described above would be applicable to some young people as well as adults. Many young people now have their own passports and would therefore be able to acquire a passport/ entitlement card. Many young people are also keen to acquire a provisional driving licence when they reach the age of 17. However there is another key age which marks a young person's transition to a more economically active stage of their citizenship.

5.9 At the age of 15 years and 9 months, young people are sent a plastic card with their National Insurance number and it might be feasible to issue an entitlement card alongside the issue of a National Insurance number. When young people were sent their National Insurance card, they could also be invited to apply for an entitlement card. The invitation might include a partially completed application form based on information held on the National Insurance system and a freepost envelope (or a reference to a website where the rest of the application could be completed). The entitlement card could be issued in the form of a passport/ entitlement card (if the young person qualified) or in the form of a non-driving licence/ entitlement card. The latter could be upgraded to a provisional driving licence at age 17 provided the young person met the requirements for a provisional driving licence (for example medical fitness to drive).

5.10 As there would be advantages to the Government in establishing a young person's participation in the entitlement card at an early age, this could be reflected in a lower fee charged for young people when they applied for other documents based on the scheme such as a provisional or full driving licence or a passport.

P24.

P25. Views are sought on whether young people should be invited to apply for an entitlement card when they are issued with a National Insurance number.

The Government is particularly keen to hear young people's views on what features they would like to see on an entitlement card which would make it attractive to them. 49
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H O W A S C H E M E M I G H T W O R K I N P R A C T I C E 49 Entitlement cards for foreign nationals 5.11 Most entitlements to services in the UK are based around lawful residence rather than citizenship. A universal entitlement card scheme would therefore also have to cover foreign residents other than those staying for short holidays or business trips where their passport or national identity card would suffice.

5.12 The Government would not wish to require wholesale changes to existing procedures for foreign residents to enter the country legitimately. These would stay in place but foreign residents would also be required to obtain an entitlement card. For example a foreign national who entered the UK on a work permit would be required to obtain an entitlement card before taking up employment. Work Permit UK's systems could be linked to those of the entitlement card issuer so the only additional information the foreign national would have to provide would be an address and biometric information. The entitlement card would be valid only for the period of the work permit on which he entered the country. Any changes to his employment status such as the extension of the work permit would require the issue of a replacement entitlement card.

5.13 Citizens of other EEA countries have a right to live and work in the UK. An entitlement card scheme would not infringe that right. Citizens of other EEA countries would have to apply for an entitlement card just as UK citizens have to apply for foreign residence cards in some EEA countries. Applications would need to be supported by passports or national identity cards issued by their native country. Applicants would also be required to provide biometric information.

5.14 Asylum seekers are now being issued with Application Registration Cards (ARCs) which also include biometric information in the form of fingerprints. Asylum seekers present a particular problem in verifying identity as they often enter the country without any official documents such as passports and those they have may not be genuine. The fingerprinting of asylum seekers to a legal standard of proof (unlike that suggested for the entitlement card scheme) helps to ensure that an individual cannot make more than one application for asylum and that the fingerprint evidence can be used in court.

5.15 An asylum seeker who was granted leave to remain would be able to exchange his ARC for an entitlement card. The biometric information recorded on the Home Office's systems would be cross-checked against any recorded for the entitlement card. This would help ensure that the person applying for an entitlement card was the same as the person who had applied for asylum and subsequently been granted leave to remain. 50
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5.16 Within the family of entitlement cards, only the passport card would be available exclusively for British citizens. Thus within a scheme which would embrace all lawful UK residents, there would be a card which was a visible symbol of British citizenship. The issuing of this card to those taking up British citizenship Ð for example after being granted leave to remain and then applying successfully for naturalisation Ð could form part of the citizenship ceremonies discussed in the Government's White Paper Secure Borders, Safe Havens (CM 5387) published in February 2002.

P26.

Confirming identity 5.17 The Cabinet Office study on identity fraud recommends that existing procedures for issuing driving licences and passports should be strengthened. In particular it discusses the greater use of biographical checks on applicants (ie checks that confirm that a person has been known by a certain identity and lived at known addresses for a number of years). Biographical information of this kind is the most difficult to counterfeit. The most effective method of confirming this biographical information would be to check some of the information provided by applicants with information held on other Government databases. Under this suggested scheme, the application could be checked against information held on:

° the passport and driving licence systems; ° National Insurance records; ° the electoral register; ° registers of births, marriages and deaths.

5.18 One of the areas where Government information is frequently out of date is address information, mainly because people interact with Government services (particularly central Government services) much less frequently than with private sector services such as credit card companies and utilities. The Cabinet Office identity fraud report suggests that the Government could make greater use of information held by credit reference agencies as their address information

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50 The Government invites comments on its suggestions for how entitlement cards could be issued to various categories of foreign nationals. The Government is particularly keen to ensure that any entitlement card scheme would not make the UK a less attractive place for foreign nationals to work and settle lawfully and welcomes specific suggestions on how to ensure this. 51
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H O W A S C H E M E M I G H T W O R K I N P R A C T I C E 51 is usually more up to date. The suggested entitlement card scheme therefore also includes such a check. (The practical usefulness of such a check is currently being evaluated by the UK Passport Service). The UK Passport Service and DVLA would use the check against credit reference agencies to help establish a person's address not his credit-worthiness. People would not be refused an entitlement card because of a poor or non-existent credit history.

5.19 An entitlement card scheme would also retain some of the existing checks used by the UK Passport Service and the DVLA, in particular the use of a countersignatory to verify a person's identity and appearance.

P27.

Biometric information 5.20 Another way to strengthen identity checks would be to record applicants' biometric information. Biometric techniques exploit the peculiarity of certain anatomical features such as DNA profile, fingerprints, iris patterns or hand or facial characteristics and features arising from how a person speaks or writes her signature. The strength of biometrics lies in the one-to-one relationship between the person and their unique biometric information.

5.21 Recording biometric information as part of an application for an entitlement card would help to ensure that one person did not establish more than one identity in the scheme. It could also help to verify that the person presenting a card was the person it was issued to. The biometric information most likely to be of use in an entitlement card scheme are fingerprints, iris pattern recognition or facial recognition. These are discussed in more detail at Annex 4. Before deciding whether to incorporate biometric information into a scheme, the Government would need to be satisfied that the technology:

° was sufficiently mature and reliable; ° could be implemented at a cost which justified the benefits; ° was acceptable to members of the public.

Views are invited on whether more background biographical checks than currently take place should be conducted before applicants were issued with entitlement cards and whether the checks suggested in this paper are useful, feasible and proportionate. 52
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5.22 On the acceptability of recording biometric information, the Government would need to be satisfied that people were content with the principle of recording this information. It would be a powerful technique to help protect people from becoming victims of identity theft or fraud. However some might be concerned that the Government was recording such intimate information about them and would quite rightly expect stringent safeguards on how the information was used.

5.23 Of perhaps equal or greater significance would be the acceptability of recording biometric information in practice. Recording biometric information would require special equipment to be installed around the country and for people to make a personal visit for the information to be recorded. This could be inconvenient unless equipment was installed at sufficient sites around the country. Arrangements would also need to be made for people who lived in sparsely populated areas and who were housebound or less mobile than the majority of the population. The Government has commissioned a more detailed study of the feasibility of using biometric information for passports, driving licences and entitlement cards and will publish the findings of this study during the course of the consultation exercise.

5.24 The combination of more biographical checks and the recording of biometric information should allow for much greater security in the issuing of passports, driving licences and entitlement cards. In general a risk-profiling approach would be adopted so that while more detailed checks would be performed on some higher risk applications, most could be processed on a fast track so that overall customer service levels would not be adversely affected and might even be improved. Failure of a particular check such as a non-match against a National Insurance record would not automatically result in an entitlement card being refused but in further checks being made. This would also be the case with checking biometric information as no system would be 100% accurate and there would always be a small number of 'false positive' matches where the computer system matched the records of two different people.

Figure 5.2 shows some examples of biometric equipment Ð an example of a fingerprint scanner used to check information recorded on a card or on a central database via a mobile telephone and an iris camera used to speed up passenger clearance at an airport. The pictures are used by the permission of the copyright owners and do not imply any preference on the part of the Government for particular suppliers of equipment.

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H O W A S C H E M E M I G H T W O R K I N P R A C T I C E 53 Figure 5.2 Examples of biometric equipment HOW WOULD THE APPLICATION PROCESS FOR DRIVING LICENCES AND PASSPORTS CHANGE UNDER THIS SUGGESTED SCHEME?

The application process would be essentially unchanged. Applicants would still need to provide their details, a photograph and details of a countersignatory. However more information would be required on the form to establish nationality and applicants would also be asked for a National Insurance number (if they had one) to help establish their biographical identity. Also, by the time any entitlement card scheme might be introduced, it is likely that there will be more use made of on-line 54
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E N T I T L E M E N T C A R D S A N D I D E N T I T Y F R A U D 54 applications from a public kiosk or from a home PC. The UK Passport Service is currently developing these systems.

The main difference would be if biometric information in the form of a fingerprint or iris pattern formed part of the scheme. This would require applicants to 'go somewhere' so their fingerprints could be scanned or iris photographed. If facial recognition was used as a biometric the current processes would not have to change as the photograph supplied would be scanned into and recorded on the database (as has been the case for passports and driving licences since 1998). At present people do have to 'go somewhere' to have a passport sized photograph taken Ð usually at a booth located in a busy part of town such as a shopping centre which also involves an additional cost over and above the passport or driving licence fee. However this can be done pretty much at peoples' convenience, if there is a queue by the booth they can always come back later unless their application is urgent (e. g. they have forgotten to renew their passport just before going on holiday). The number of biometric recorders would be far fewer than the number of photograph booths and an operator would be required to ensure that the information was recorded correctly.

It might be possible to design the scheme such that biometric information could be recorded at any time convenient to the applicant. For example the biometric recorder could issue a reference number when the information was recorded which could be used to link an application form to the biometric information. However it will be important to ensure that this did not increase the risk of fraudulent applications for example a person paying a casual visitor to the country to register a biometric and then applying for an additional card using this information. (Such a card would fail a biometric check at the point of use but many transactions might not make use of this facility).

Iris pattern cameras are being developed that can also take a 'head and shoulders' digital photograph at the same time as photographing the iris. If such technology was used for an entitlement card scheme, people would not have to pay for a separate photograph (though they would still need a good quality paper copy of the image in order for the photograph to be countersigned).

The Passport Service is moving towards an appointments system for personal passport applications. Appointments could be arranged in a number of ways e. g. by telephone or over the Internet. This could be another way of minimising the inconvenience to applicants by ensuring that they would not have to queue at peak times. 55
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(i) Comments are invited on whether an entitlement card scheme should include the recording of biometric information with particular regard to the cost, feasibility and acceptability of the three most likely options (fingerprints, iris patterns and facial recognition). (ii) The Government would like to hear the views of potential partners on how a nation-wide network of easily accessible biometric recording devices could be established and operated, how people who are not mobile or who live in sparsely populated areas could be served and what other value added services potential partners might offer.

P28.

What sort of card could an entitlement card be? 5.25 The current photocard driving licence is a plain plastic card and contains no additional information other than that which is printed on the card itself. If entitlement cards were issued in this form they would be simple and relatively inexpensive to produce and under normal conditions of wear and tear would last 10 years. Simple plastic cards could hold biometric information on a two-dimensional barcode which is a more sophisticated version of the type of barcodes used to price goods in shops).

5.26 However there is increasing interest in the use of smartcard technology where a card incorporates a microchip. As well as storing biometric information securely, the information displayed on the card can also be stored on the chip for ease of processing. It could also allow other organisations to make use of the card Ð at the card holder's discretion Ð so that it could fulfil other important uses for the card-holder and reduce the number of plastic cards people have to hold. For example it could be easier for card-holders to enrol for other services Ð joining a local library might be as easy as swiping a card at the library counter. There would also be benefits for the library service which would save the cost of keying in the card-holder's name and address into its systems.

5.27 However the incorporation of smartcard technology would increase costs in two ways: ° the cards themselves would be more expensive to produce; ° the cards would need to be re-issued during their 10 year validity period as the chip would degrade over time for example through the wear and tear of being carried or inserted repeatedly in card readers.

Issuing entitlement cards as smartcards is attractive but the Government will want to see the case for this properly established. The comments received during this consultation

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Views are sought on what benefits issuing an entitlement card as a smartcard would bring to card holders, whether the use of a smartcard chip could be shared by a number of organisations effectively and whether any potential partners would be interested in managing the sharing of a chip on behalf of the Government.

exercise will be crucial in making this assessment. Initial cost estimates indicate that a simple memory only smartcard would increase the costs of the scheme by around 25% (£ 30m per annum) compared with a plain plastic card. A more sophisticated smartcard which needed to be re-issued twice in a 10 year period would incr