News that the Scottish Government has dropped plans to turn the NHS central register into a national identity database are very welcome. But this isn’t the end of the story: Scotland retains the legacy of an identity system that is extremely similar to the UK’s discredited ID cards project, which was dropped after Labour lost the election in 2010.
The Scottish identity system is remarkably similar to the now-abandoned model constructed by Labour. It features the same strong linking of personal data across government, through a single strong identifying number.
What has just been abandoned is the universal identity register, and the roll out of the system to encompass everyone who pays tax uses the health service.
The Scottish identity system is not well documented. There is nearly nothing in legislation about it, except a few lines creating the duty to assign all Scots a “Unique Citizen Reference Number” (UCRN) at birth. This duty is given to National Records of Scotland.
The second part of the system is the “National Entitlement Card”, which is not mentioned in legislation at all. The card system is run by a private body owned by the Scottish government and local authorities, known as the Improvement Service.
Users of the Entitlement Card use it as a card to identify themselves for government services. This includes bus passes, library cards and student service cards.
However, use of the Entitlement Card is theoretically ‘voluntary’ and based on user ‘consent’ - in practice this means that you have the ‘choice’ to reject your right to free bus travel as a pensioner; or to choose a different college as a student. The only serious legislation governing it is Data Protection, as you can read in the Entitlement Card’s terms and conditions.
The Entitlement Card uses the UCRN to ensure that each person only has one Entitlement Card; this has the effect of linking the user of the Entitlement Card across the datasets. As the number of datasets used increase, so does the amount of information that can be linked to individuals. The temptation to use this for data mining, profiling or other purposes, also increases.
Linking data was seen as the big advantage of the UK ID Card system. It is also a massive risk and a potentially huge change in the way that the state deals with citizens.
The final piece of the system is the “MyAccount” initiative, which appears to use the UCRN and Entitlement Card for people to access Scottish online services. This again means that anyone using MyAccount is potentially linked across any MyAccount service and elsewhere, where services are accessed via the Entitlement Card.
The use of the NHS register as a central ID registry would have advanced this ad hoc, extra-legislative structure enormously. It would have cemented it into the Scottish tax and health systems, and then across other departments. However, the UCRN and Entitlement Card system has been in operation for many years now, and continues to pose risks.
Now that the Scottish government has put parts of the system into a review, we must push for the whole thing to be looked at again. It is top-heavy, probably very expensive for what it is, and pretty much as bad as the UK ID Cards system. It’s time for the whole policy to be looked at from scratch.