Dear Ms Picking,

I note your history of supporting the principle of ID Cards. Without wanting to challenge that principle, I'd be grateful if you would take note of the following concerns with the current legislation and associated information and seek reassurance on them:

1. Unrestricted Access to other documents

   In Clause 4(i) of the Schedule to the Bill, the Register may contain:

   the number of any designated document which is held by him and is a document the number of which does not fall within any of the preceding sub-paragraphs;

   I'm extremely concerned that future governments may use this to use the register to link together council tax records, police records, court records, social services records, medical records, military service records [for people who been in the armed forces] and personnel and employment records [for those who have ever been employed in certain types of work in the public sector].

   As an IT professional, I assure you that such linking would be trivial.

   This far exceeds the stated scope of the Bill. It would enable access to all classes of Sensitive Personal Data as defined by Data Protection Act 1998:

   information as to-

   1. the racial or ethnic origin of the data subject,
   2. his political opinions,
   3. his religious beliefs or other beliefs of a similar nature,
   4. whether he is a member of a trade union (within the meaning of the Trade Union and Labour Relations (Consolidation) Act 1992),
   5. his physical or mental health or condition,
   6. his sexual life,
   7. the commission or alleged commission by him of any offence, or
   8. any proceedings for any offence committed or alleged to have been committed by him, the disposal of such proceedings or the sentence of any court in such proceedings.

   In particular, it would enable the same access to DNA information that has been explicitly rejected in public statements to date.

   Therefore, I would be grateful if you could press for a qualifying statement to this clause to the effect that it explicitly names which classes of Sensitive Personal Data the Register may be linked to and excludes all others.

2. Cost of Installing Readers

   Public debate has so far focused on the cost of implementing the scheme and registering citizens. However, a significant cost that has not been suffiently debated is the cost of Biometric Readers. The figures released under the Identity Cards Bill Regulatory Impact Assessment published 29 May 2005 estimates a cost of £250 each.

   However, the same readers are cost estimated in the Immigration, Asylum and Nationality Bill Regulatory Impact Assessment (Annex A, page 42) as costing:

   Reader: £3000-£5000 (each reader)
   PC for reader: £1000 (each reader)
   plus £21,000 for cabling at each location (derived from a estimate of £1 million for 47 airports and ports).

   To achieve the stated benefits in immigration, benefits fraud and prevention of terrorism, this work would also need to be carried out at many further government locations. I would therefore be grateful if you would press for the costs of the Identity Cards Bill be updated in line with the previously stated costs of Biometric Readers.

   To achieve the stated wider benefits in identity fraud, readers will be required in many non-governmental locations, including many existing retail banking and (public and private sector) health service locations, and in many employers. I would be grateful if you could press for an impact assessment of the resulting costs and an indication of the related funding sources.

3. Benefits: Identity Fraud

   I am not at all convinced by the top-line £1.3bn figure suggested for identify fraud that would be avoided by the introduction of ID Cards, as it seems to be based on an unrealistic assumption that 100% of the annual costs of ID fraud are preventable.

   I would be very grateful if you could obtain a statement from the Home Office, estimating what percentage of the 2002 Cabinet Office study figure would be saved by the widespread use of ID Cards, broken down by area (Credit Card, Benefit Fraud, Insurance etc) and the source for each estimate.

Yours sincerely,
Martin Burns