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242 The LSE Identity Project Report: June 2005“The Treasury did not conduct any separate analysis of the costs ofcreating and maintaining a national identity card, and therefore holdsno documents relevant to your request.” 662Nevertheless, enough is now know about the details of the proposal to develop costprojections with some degree of certainty. This section will explore the basis of thosecosts. Previous sections of this report have set out the technological environment in theUK that has created the dynamics for some of those cost elements.In developing these cost projections we have taken into account the publication of tworecent documents: the UKPS biometrics trial and the new Regulatory ImpactAssessment (RIA).The best available estimate contained in the RIA is that the combined passport and IDcard will incur £584 million per year (£5.84 billion over ten years).Government UnderestimationsWe suggest that the Government’s current figure substantially underestimates the likelycost of the scheme. The key reasoning behind this view is as follows:Biometric equipment. The UKPS trial, together with other research, indicates thatthere is likely to be significant disadvantage to disabled enrolees. As foreshadowed inour Interim Report, such disadvantage is likely to breach the Disability DiscriminationAct, and the technologies and techniques used in enrolment and verification musttherefore be improved to the point where no unnecessary disadvantage is created. Irisscanners that substantially engage the user will be necessary. Video or rapid sequencetechnology will be required to accommodate a number of eye conditions. Sophisticatedergonomic features and enhanced user interface features will be necessary to ensure thatensure that the machinery assists the user to the maximum extent. The relatively highunit cost of the equipment, as set out in our estimates, reflect the importance of ensuringthat inherent discrimination is limited to the greatest possible extent. The cost ofdeveloping and deploying the appropriate technology in this regard will be far in excessof the government’s estimates. For example, the RIA states that biometric card readerswill cost between £250 and £750. Even the NPL figures of 2003 are higher than this,estimating £5000 per office (though no mention is made of how many readers eachoffice would house). A more likely figure for secure and reliable non-discriminatoryequipment (using high-end fingerprint and iris recognition) would be in the range of£3,000 - £4,000 per unit (for iris and fingerprint verification). We also believe that thisequipment must be replaced or upgraded at least every three to four years to ensure thatsecurity is maintained.Validity period. The RIA estimates an indicative unit cost for an ID card and passportat £93. This assumes a ten-year life for a card and a recorded biometric. However, alltechnical and scientific literature indicates that biometric certainty diminishes over time,and it is therefore likely that a biometric – particularly fingerprints and facial features –662 Letter to David Banisar, Deputy Director of Privacy International, from John Adams, Manager of CEU, HMTreasury, April 7, 2005.
The LSE Identity Project Report: June 2005 243will have to be re-scanned at least every five years. This cost must be taken intoaccount. If the enrolled biometrics do not significantly mach the re-enrolled biometrics,it may be necessary to conduct another full identity check. Northrop Grumman, theoperator of the national fingerprint information system (Nafis) argued that cards wouldneed to be replaced on average every three years. 663 The question of how a card subjectis accurately verified to receive a new card is unclear, but we feel that the process willnecessarily be costly and time-consuming.Enrolment. The government appears to have underestimated the cost of other elementsof enrolment. The “biographical footprint checking” component of enrolment willinvolve considerable effort, and will encounter significant problems regarding theaccuracy and integrity of historical data. This component could conservatively addanother £10 - £20 to the unit cost. The envisioned use of credit reporting agencies toconfirm some personal data will, in all likelihood, create significant problems relating toenrolment integrity. We calculate that a median of 60,000 person-years will beexpended in registering the entire population, plus “non casual” visitors. A furthermedian of 60,000 person years will be expended in front-office operations.Card replacement. As we outlined elsewhere in this report, cards will have to bereplaced at least twice during a ten-year period. We believe the card selected will haveto embrace substantial processing power to ensure that security and functionality is fullyexploited. Research and development on encrypted biometrics will be required beforethis generation of cards can be rolled out.The Register. The cost of developing, building and maintaining the national register isdifficult to assess at this early stage. However there are clear parallels between theproposed register and the NHS Spine. The Register will involve greater complexity andmust embrace more rigorous security measures. It must also incorporate biometrics –something that we believe will be a technological challenge far greater than thegovernment has anticipated. We have therefore costed the Register at between two andfour times the contract price over ten years of the NHS Spine project.Non-Co-operation. While the government has attempted in the legislation to addressthe issue of challenges to the system by “refuseniks” through the use of civil andcriminal penalties, there is evidence that this population could nevertheless create asubstantial additional cost burden. The administrative costs of handling this group willbe substantial. It will be difficult to distinguish between intentional non-cooperation anda genuine inability to cooperate. The proposed scheme differs from benefitsadministration or other government benefits and services delivery in that it essentiallyrequires user trust and cooperation. Dedicated and systematic disruption by even a tinyelement of the population may create an administrative burden equivalent to the cost ofmanaging ten or twenty times that number of people. We believe, based on results ofopinion polling, that this group of dedicated non-co-operators may be quite significant,possibly as high as two per cent of the population. One such person workingstrategically and systematically can, quite feasibly, exhaust 200 hours of administrationtime through the generation of queries, appeals, access requests, database modificationsand general civil disobedience.663 ‘Memorandum submitted by Northrop Grumman’, submitted to the Select Committee on Home Affairs, January2004, available at http://www.publications.parliament.uk/pa/cm200304/cmselect/cmhaff/130/130we40.htm.
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