From: David Moss
Sent: 20 November 2009 15:23
To: Duncan Hine
Attachments: XXXXXXXXXX; Face recognition. NIST? Or the FBI? You can't both be right.

Dr Duncan Hine
Executive Director
Integrity and Security
Identity & Passport Service

Dear Dr Hine

Thank you for your letter dated 16 November 2009 in response to mine dated 30 October 2009.

You kindly offer to have Kevin Sheehan, Director of Identity Assurance and Document Services, "take this forward".

Gratitude needs to be tempered with scepticism. On 18 September 2009, Lin Homer wrote promising me a meeting with Daniel Souter, Assistant Director of the Border Force, please see attached. Two months later, the meeting hasn't even been arranged, let alone taken place. That meeting is meant to discuss the questions about eBorders raised in my letter dated 8 August 2009.

It is to be hoped that "take this forward" means "promptly inform the public convincingly why we should trust IPS's and UKBA's choice of face recognition and flat print fingerprinting technology to help fight crime and terrorism and to improve the efficiency of public services".

You said in a letter to the Guardian (15 January 2009) that: "We plan to use all 10 fingerprints and facial biometrics to ensure someone can only enrol on the scheme once, thereby preventing multiple identities being established". As you must know, if only from my letter published on 25 January 2009, identification like that is impossible.

Mr Sheehan needs, therefore, to concentrate on the use of biometrics for verification, not identification. The UKPS biometrics enrolment trial (please see §1.2.1) revealed that face recognition fails to verify identity around 50% of the time, and flat print fingerprinting aound 20% of the time.

The Home Office claim that that wasn't really a trial. Which gives Mr Sheehan a problem. Does that mean that the Home Office are spending taxpayers' money on technology without first conducting trials to see if it works?

Not quite. You have subsequently conducted trials of face recognition at Manchester airport which provoked the memorable claim that this technology cannot distinguish between Gordon Brown and Mel Gibson, nor between Osama bin Laden and Winona Ryder. The smart gate technology has nevertheless now been deployed at 10 UK airports. And despite the entreaties of the House of Commons Science and Technology Committee, no trial results have been published: "We are surprised by the Home Office’s unscientific approach ... Given the relative lack of information available publicly regarding the performance of biometrics in a national scheme, we recommend that once the scheme is established the Home Office publishes details of the performance levels of the technology" (para.91).

You haven't published any performance results but you have told The Register magazine that: "We will not give the error rates or technical specifications of the gates for commercial and security reasons". Mr Sheehan will need to explain why a company selling equipment that works would want to keep that fact confidential and why our security would be threatened by telling us how their equipment would make us more secure. He will need to explain also why the FBI are wrong when they say that the face recognition algorithms just don’t exist to deliver the highly reliable verification required.

The Home Office haven't conducted any trials of flat print fingerprinting since the UKPS biometrics enrolment trial. But 1,800 business schools around the world have. For two years, candidates sitting the GMAT entrance exam had their identities verified by their flat print fingerprints. It didn't work, fingerprints have been dropped, and the schools are now trying veinprint technology instead: "The new technology is a more accurate, more efficient and less invasive way to ensure that each test taker has a single GMAT record, preventing people from taking the test for others".

In the absence of any large-scale field trial, the only defence the Home Office advance for their trust in the biometrics they have chosen is a "chimera trial", as Nigel Sedgwick calls it, conducted by the US National Institute of Standards and Technology (NIST). NIST's record on predicting the reliability of biometrics is poor. An enquiry has been sent to the lead author of this report, please see attached. Who is right? NIST? Or the FBI? He hasn't answered. Can Mr Sheehan answer?

We have a Home Secretary who fires scientists who tell him the truth and an Identity Minister who thinks we should spend a fortune on systems to help us collect parcels from the sorting office. We have smart gates installed at 10 UK airports against the best advice of the FBI and against four decades of evidence of the failure of the face recognition biometrics industry. As far as we know, flat print fingerprinting fails to verify the identity of about 20% of people. And now we learn, via a press release in Paris, that IBM, who have a £265 million contract to create the biometric National Identity Register, have contracted with Sagem to supply face recognition and flat print fingerprinting technology before we even know that the technology works.

Mr Sheehan has a lot to "take forward". He must provide independently audited large-scale field trial results promptly which will convince the British public that our money is not being wasted and that our security really is being enhanced. Two months is not long enough for the UK Border Agency to justify its eBorders strategy. Can the Identity & Passport Service do better? Can Mr Sheehan lay his hands on the documentary evidence which justifies the spending of £5 billion by the Home Office alone on the National Identity Service in, say, two weeks? A sort of Christmas present to the long-suffering British taxpayer who finds it harder and harder to respect anyone in government, whether politician or civil servant?

Yours sincerely
David Moss


Business Consultancy Services Ltd


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