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294 The LSE Identity Project <strong>Report</strong>: June 200549. We are also concerned that the Home Officemay be leaving it to other government departments,local government and the private sector to decidewhat level of investment to make in card readersand infrastructure. There is an obvious danger thateach organisation will opt for a low level ofsecurity, relying on others to raise the level ofsecurity in the system as a whole. If this happens thevalue of the identity card system will besignificantly undermined. We also expect the HomeOffice and other Departments to give at least broadestimates of the numbers of readers they expect toneed of each type and what level of provision otherorganisations are expected to make. (Paragraph 202)Multiple cards50. We support the issue of multiple identity cardsto an individual in cases where there is a legitimateneed, and welcome the Home Office's expression offlexibility on this issue. (Paragraph 203)Security51. We believe that an identity card system couldbe created to a sufficient level of security. Westress, however, that the security of the systemdepends as much on using the proper procedureswith the appropriate level of scrutiny to verify thecard in use as it does on the integrity of the cardissuing process or the identity register. (Paragraph207)Costings52. The Home Office have provided us with detailsof the assumptions on which their costings havebeen based, on a confidential basis. We are notconvinced that the level of confidentiality applied isjustified. Cost information is an essential element indetermining the value for money of any project. It isof prime importance where expenditure is fundedfrom the public purse and of particular relevancewith regard to public sector IT projects which havea history of poor performance and cost-overruns.We are also concerned that the least robust costestimates appear to relate to the assumptions withthe greatest cost-sensitivity, such as the length ofenrolment time, the anticipated number ofapplications requiring further investigation, the costof card production and the criteria for subsidisedcards. Changes to any one of these factors couldcause significant increases to the cost of theprogramme. (Paragraph 212)Supported by research.Supported by research.Conditionally supported. This conclusion cannotbe drawn until agreement has been reached on aspecific architecture.Supported by research.
The LSE Identity Project <strong>Report</strong>: June 2005 29553. The failure to attach a Regulatory ImpactAssessment to the draft Bill, or to provide anydetailed information on estimated costs andbenefits, significantly weakens the basis for prelegislativescrutiny and the public consultationexercise. This secrecy is all the more regrettablesince the case for an identity card system is foundedon whether its benefits are proportionate to theproblems it seeks to address: a proper cost-benefitanalysis is an indispensable element of this. Theexcuse of commercial sensitivity should not be usedto avoid publishing a full Regulatory ImpactAssessment with the Bill. (Paragraph 213)Procurement54. We welcome the Home Office's efforts toovercome their record on IT procurement. We donot believe that it is impossible for them to deliverthe project on time, to specification and to cost.(Paragraph 215)55. But we are concerned about the closed nature ofthe procurement process which allows little publicor technical discussion of the design of the systemor the costings involved. We do not believe thatissues of commercial confidentiality justify thisapproach. Any potential gains from competingproviders providing innovative design solutions arelikely to be more than offset by the unanticipatedproblems that will arise from designs that have notbeen subject to technical and peer scrutiny.(Paragraph 216)56. Nor do we believe that the Government's OGCGateway process has yet demonstrated the robusttrack record on procurement projects that wouldallow it to be relied upon for a project of this scale.(Paragraph 217)57. The Home Office must develop an openprocurement policy, on the basis of system and cardspecifications that are publicly assessed and agreed.The Home Office should also seek to minimise risk,including, as appropriate, by breaking theprocurement process down into manageablesections. We have already recommended that theChief Scientific Officer be invited to oversee thedevelopment of the biometric elements of thescheme. We recommend that individuals or groupswith similar expertise be invited to advise on thescrutiny of other aspects of the scheme. (Paragraph218)Supported by research.Not supported by research. This conclusionappears to be entirely speculative.Supported by research.Supported by research.Supported by research.
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