Major Concerns about the UID Project

The Government of India’s ambitious project to provide a Unique Identity (UID) Number to every resident of the country on the basis of biometric data has raised several concerns among rights activists and civil society groups for various reasons. Following are a few issues raised by independent law researcher, Dr. Usha Ramanathan, in the course of two meetings held at the IGSSS head office in Delhi, on January 25, 2011 and March 14, 2011:

[While the first meeting was attended by representatives from the Mother NGO – St. Stephen’s Hospital, the second meeting saw no participation from either the MNGO or UIDAI officials (both had been invited for the same). Had a UIDAI representative been present at the meeting, a number of doubts regarding the UID issue would have been cleared by now. IGSSS sent a list of questions on the UID project to the MNGO and the UIDAI, following the meeting.

The meeting on Jan 25, 2011 was attended by – Jyoti Gupta (IGSSS), Feroze Ahmed (IGSSS – HCRC Central Delhi), Smriti (MNGO), Dr. Amod Kumar (MNGO), Bipin Kumar Rai (IGSSS), indu prakash singh (IGSSS), Dr Usha Ramanathan (Activist and Researcher), Gopal Krishna (Activist and Researcher), Miloon Kothari (HLRN), Shivani Chaudhry (HLRN), Anjali Borhade (Disha Foundation, Public Health Foundation of India – PHFI), Meeta (IGSSS – HCRC North Delhi), Neelam (IGSSS – HCRC North Delhi), Ambrish Rai, Sandhya (IGSSS)

The meeting on March 14, 201 1was attended by – Dr Usha Ramanathan (Law Researcher), Kulisha Mishra (PRAXIS), Jyoti Gupta (IGSSS), Meeta (HCRC North, IGSSS), Nadim (HCRC Central Delhi, IGSSS), Ankur (HCRC North Delhi, IGSSS), Jayanta Bhakat (Humana), Ravinder Kumar (Humana), Feroze (HCRC Central Delhi, IGSSS), Rakesh (HCRC North Delhi, IGSSS), indu prakash singh (IGSSS), Abdul Shakeel (SAM-BKL), Kamlesh Saxena (HCRC Central Delhi, IGSSS), Sandhya (IGSSS)]:

• Authentication
• Feasibility Studies
• Not a proof of nationality, domicile
• Tagging individuals – fear of India turning into a police state
• Companies involved do not have a clean track record
• Process not foolproof: iris scans, fingerprinting often do not work
• UIDAI says it is voluntary; may not be true
• Connections with NATGRID, PII, NPR etc (policing)
• Problem of introducers: what are their liabilities?
• Date of issuance like erasing the past history of an individual

1. Apart from the problems with the process of the issuance of UID cards, there are problems with the concept itself. There is a major fear within the civil society that the UID may eventually be used for monitoring and tracking purposes, and will seriously limit individual freedom. The stated purpose of the UID, which is to make accessing basic services simpler for the common person, is completely at odds with the perceived real purpose – which is that of policing.
2. Biometrics: The creation of biometric data on such a large scale is not feasible. Biometrics can work only under controlled conditions and on a much smaller scale. Iris scans will not work in millions of cases because of malnutrition-induced cataract. Finger prints, too, would generate a lot of noisy data which may ultimately be unusable. There are no existing standards for the creation / collection of biometric data in India and consequently no way to monitor the process.  [Excerpt from ET Report – July 17, 2010 – “a passport applicant with worn-out fingers may present his newly-issued UID number as a conclusive proof of identity, but could find the application rejected. The authentication process using a fingerprint scanner could classify the applicant’s worn-out fingers as a so-called ‘false negative’ .A December 2009 report by the UIDAI Committee on Biometrics, says there is no estimation of the extent of this problem. The fingerprint quality, the most important variable for determining accuracy, has not been studied in depth in the Indian context,” the report says. Subsequently, a pilot study was done, and 250,000 fingerprints were collected and analysed. The committee’s conclusion: “There is good evidence to suggest that fingerprint data from rural India may be as good as elsewhere when proper operational procedures are followed and good quality devices are used … (but) the quality drops precipitously if attention is not given to operational processes.”]
3. Concept tests and authentication studies for the UID system have not been conducted, or if they have, not been made public, which leads the civil society to suspect that it is really being carried out as a large-scale experiment.
4. The multinational companies to which the UID work has been outsourced do not have a clean record.
5. While the UIDAI says that getting a UID card or number will be voluntary, service providers themselves may make it compulsory for people to avail of their services. Human rights activists feel that it is not actually intended to be voluntary.
6. The UID process involves an introducer, whose liabilities have not been made clear. One can either use one of 14 documents to enrol for a UID card / number, or enrol through an introducer, who ‘introduces’ or signs for the one seeking a number.
7. The UID card itself says that it is neither proof of a person’s domicile nor of his/her citizenship, making its role or benefit to the holder suspect. The same is true for the Homeless Cards issued by the Delhi Government under Mission Convergence.
8. The UID, once issued, will act as the primary identification card for any individual. However, this will render the existing proofs / ID cards of an individual useless. A fresh date of issuance for a UID card will be like erasing the past record of a person’s residence in a certain area / city. This may be especially harmful to the homeless. The UID issuance process witnessed by Dr. Ramanathan did not involve the collection of any information apart from a person’s biometric details, name, age, gender etc. and the Beghar Card issued to him/her earlier. Other proofs of identity like ration cards, voter ID cards  etc. were not seen, even in cases where people had these. 
9. Other national governments, most recently in the UK, have scrapped similar projects. In the UK, the National ID programme, which was aimed at tackling fraud, illegal immigration and identity theft, was criticised for being too expensive and an infringement of civil liberties. The UK government cited higher costs, impracticality and ungovernable breaches of privacy as reasons for the cancellation of the NID project.
10. The UIDAI does not say if a cost-benefit analysis for the project has been done, and whether it is feasible in terms of costs to the exchequer. If the reasons for scrapping the UK NID project include ‘higher costs’ then surely there is also a need to examine India’s UID project from the angle of expenses.
11. Incomplete information given to organizations involved: At the operational level, the UID project has been outsourced to NGOs, banks etc, none of which have been given adequate information about their liabilities and other issues. This problem is especially apparent in the case of introducers, many of whom have ‘introduced’ hundreds of homeless citizens for the purpose of enrolment. The liabilities of these introducers have not been made clear.
12. Technologically unfeasible: The project also may not be technologically feasible. The iris scan was introduced to tackle the problem of the noisy data generated by fingerprinting. However, the iris scan technology may not be available to all the service providers that will eventually use the UID number. This may pose authentication-related problems.
13. No monitoring system: While the UID authorities have outsourced the enrolment work to NGOs and other agencies, their own officials have not put a monitoring system in place to ensure accuracy.
14. Undelivered cards: The UID cards for the homeless are all sent to the NGOs responsible for their enrolment. Finding the individuals in whose names the cards have been made, however, is a difficult task, with the possible result that many of these cards may never reach the intended beneficiaries. A foolproof system needs to be put in place to prevent this.
15. Changes in contact information: In case of a change in address, phone number etc., individuals themselves will have to intimate the UID authorities from time to time. However, this may not always be possible, especially when it comes to the poor.
16. Authentication: A major problem is that of authentication. There is no clarity on what will happen if the biometric data is inaccurate or does not work because of technical problems, at the time of accessing services. If the authentication process does not work, would the concerned individual be treated as an outsider, or as being ineligible for accessing services?
17. Dismantling of social security: There is a fear among activists that the government will eventually dismantle all subsidies / social security mechanisms by means of the UID. After the inclusion of cash transfers for LPG, kerosene and fertilizers (through UID) in Budget 2011, this fear has only grown stronger. The major problems with cash transfers are that (a) these are not insulated against inflation (b) many of these transfers will be conditional (c) cash transfers work well only with smaller populations and in places where the service delivery systems are extremely efficient.
18. Financial Inclusion: Having a UID number itself does not guarantee access to services. The only thing it is currently said to be linked to is financial services. Financial inclusion means providing a bank account to every person. The reasons why banks are interested in the project (and to open zero balance accounts) are that (a) the primary customer of the UID is the government (b) government money will keep rolling into these accounts through various schemes
19. Monitoring Banking Correspondents: However, many big banks are slowly backing out because carrying out transactions for the poor will ultimately involve banking correspondents or intermediaries, monitoring whom on such a large scale will be difficult. In such a situation, the role of banking correspondents will be taken up by Micro-Finance Institutions (MFIs). There is also  talk of making it sustainable. Will it entail service charge from the poor for withdrawing money?

Questions for UIDAI:

• For the state government: The Delhi Government has not made any commitment to give any entitlements / rights to CityMakers (homeless citizens) on the basis of the UID. Is the government willing to make such a commitment?
• For the state government: Can the government / UIDAI give a written guarantee that no social security system (PDS etc) will be dismantled after the UID is introduced on a large scale
• What happens if the number of people enrolled (through a certain NGO) does not match the final number of UID cards received? How many UID cards are not finally generated after enrolment, and what is the reason for this? Is it because of noisy fingerprints or some other problem with the biometric data? Do we then need to call these people again (if they can be found) for enrolment?
• What happens to those cards that cannot be delivered? Will the NGO involved be answerable for these? IGSSS has been receiving UID cards for the homeless (approx. 36 so far) but it has so far been difficult to locate most people. If these people cannot be found, what happens to their cards?
• Is there a default arrangement for those individuals whose biometric data is not accurate and who have a problem during authentication?
• What are the introducer’s liabilities?
• Can those who have already introduced a sizeable number of people withdraw from the role of introducer and be freed of any liabilities that they were not informed of before being assigned the task.
• For the UIDAI: Is the Homeless (Beghar) Card data being incorporated in the UID database as well? If yes, what is the mechanism being followed for the same? The UID card for homeless citizens mentions the Survey Frame Pocket (SFP) number. Are the survey details, too, being included in the UID data?

 [IGSSS has sent the above questions to the UIDAI, and has sought clarifications on the same]