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244 The LSE Identity Project <strong>Report</strong>: June 2005Register updates. There is a requirement on individuals to notify the identity registerwhenever there is a change in personal circumstances. This would mean, for example,that a person would have to contact the register when changing address or name, orwhen disability or change of occupation may affect the recorded biometric. Thisrequirement may result in 250 million – 1.2 billion contacts with the register over tenyears (between 4 and 20 contacts per person over ten years). This additional cost mustbe taken into account. If human management is necessary to ensure that changes areverified, this facet will add between £700 million and £4 billion to the ten-year rolloutof the scheme. This is based on a projected cost of £3 - £4 per contact with Registerstaff. In taking this cost into account we assume that the cost will not be directlycharged to the individual, although the RIA does not rule out this possibility. In anyevent, it is valid to include this component in the overall costings.Integration costs. There will be an obligation across the public sector to implementsome form of ID checking using the card and the register. There appears to be generalassumption that the identity scheme in such circumstances will be a stand-alone system.We do not see how this can be the case. All public sector systems using the identityscheme must be modified so that identity numbers and identity checks can betriangulated, checked and audited through the records held by each organisation. The“audit trail” feature described in the Bill can only be referenced in circumstances thatare in the “public interest”. Routine administrative reference and verification of the factof an identity check must be integrated into existing systems. This integration willnecessitate the modification of many government IT systems. This integration cost hasnot been factored into the government’s estimates.Other public sector costs. Based on the RIA it appears a majority of other costs mustbe absorbed by each department or agency. The cost of verification administration, stafftraining, physical facilities costs and communications costs must be incorporated intothe final estimate. This cost, in the public sector at least, is unlikely to be passed on tothe individual.Private sector integration. While the Bill contains no overt requirement on industry touse the identity card system, it is clear that the current ID checking obligation on certainsectors (e.g. financial and professional services) will require a consequentialinvolvement in the scheme. This obligation will apply equally to employers. These costsare likely to be considerable.Choice of reliable technology. Key elements of this scheme must conform to unusuallyrigorous standards. The UKPS trial failed in part because the equipment selected wasinappropriate to user requirements and to the dynamics of the trial. Because of thecritical nature of this scheme, we believe it will be necessary to select higher-endtechnology. The level of system security required, as outlined elsewhere in this report,will necessitate the selection of technology that conforms to unusually high standards.Further ChallengesWe have not at this point taken into account the potential for savings arising from theimplementation of the scheme other than those that may accrue from reduced identity
The LSE Identity Project <strong>Report</strong>: June 2005 245fraud in the benefits sector. Some of these other areas are set out in the RIA. Nor havewe assumed that contracts established for this project will go over-cost more than to theextent already factored into the RIA costings. In doing so, both we and the Governmentare ignoring the advice from the Institute for Electrical Engineers to that cost analyses“should be based on typical outcomes of other complex projects, not on stand-aloneestimates that invariably assume over-optimistic development and performanceachievements.” 664Further assessment is needed to derive an accurate figure. Our best estimate at thispoint, taking all these factors into account, is that the national identification scheme’simplementation and running costs, together with direct associated costs and compliance,will be in the range of £10.6 billion - £19.2 billion during the implementation (operationof the first ten years) of the scheme.Low Median HighIssuing Identity Cards Over a 10-Year Period 814 1015 1216Passports (Based on Passport Service Figures) 3936 3936 4065Readers for Public Sector (As Specified in the Bill) 291 306 317National Identity Register 1559 2169 2910Managing the National Identity Register 2261 3658 5341Staff Costs Over a 10-Year Period 1719 3368 5308Miscellaneous 22 64 117TOTAL 10602 14516 19274Cost Projections – All figures are in £millions. See Appendix 2 for more information.This figure does not take into account potential cost over-runs in the development of thescheme, nor does it take into account the cost of more general industry use,implementation or compliance.664 ‘Memorandum submitted by the Institute of Electrical Engineers’, submitted to the Select Committee on HomeAffairs, January 2004, available athttp://www.publications.parliament.uk/pa/cm200304/cmselect/cmhaff/130/130we29.htm.
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