Business Consultancy Services Ltd


Open letter

Sir David Normington KCB†††††††††††††††††††††††††††††††††††††††††††††††††††††††††††††††††††††††

Permanent Secretary

Home Office

2 Marsham Street

London SW1P 4DF††††††††††††††††††††††††††††††††††††††††††††††††††††††††††††††††††††††††††††††††††††

4 February 2009

Dear Sir David

Home Office press release misleads the public

The 29 January 2009 Home Office press release Benefits of ID cards for Manchester [1] contains at least 10 misleading assertions.

There is no doubt that the press release is misleading. The matter is demonstrated in the comments appended to this letter.

How can this happen? How can the Home Office issue a misleading press release?

This is not the first time that the Home Office has made these same questionable assertions about the National Identity Scheme (NIS) in press releases and other publications. Several people have brought this fact to the attention of the Home Office several times over a period of several years. It cannot be argued in this case that the Home Office did not know that the 29 January 2009 press release is misleading.

How is it possible that the Home Office does not issue a press release correcting the errors in earlier announcements?

How can the Home Office instead issue a press release in the full knowledge that it is misleading?

The claim is made in the 29 January 2009 press release that:

The public supports the benefits of identity cards Ė more than 18 months research shows on average 59% of people support the Service.


The promised "benefits of identity cards" are to assist in the fights against crime and terrorism and to help make public services more efficient. These are unimpeachable objectives. It would be surprising to meet anyone who doesn't support them. Is the Home Office suggesting in this press release that 41% of the public don't support them?

Of course not. It's just that the press release is imprecisely worded. Misleading.

The real question is whether the NIS could deliver these desirable objectives. Could it?

Examine the evidence, and it is clear that it couldn't. As the Office of Government Commerce (OGC) says [2]:

This has all the inauspicious signs of a project continuing to be driven by an arbitrary end date rather than reality ... I conclude that we are setting ourselves up to fail ... Just because ministers say do something does not mean we ignore reality - which is what seems to have happened on ID Cards.


If 59% of the public still believe that the NIS could succeed, that is because they haven't been presented with the evidence. It is a measure of the extent to which they have been misled.

Unlike the public, prospective suppliers to the NIS have to be presented with some facts. The common reaction is that they then decline to bid for the contracts on offer [3].

On 29 January 2009, at the same time as Home Secretary was telling the children of Newall Green High School in Wythenshawe about the promised benefits of ID cards, the Under Secretary of State (Identity) was at a meeting in London [4] with prospective commercial users of the NIS.

A representative of APACS told her:

The online capabilities that we were hoping were going to be present are unlikely to be there for the foreseeable future ... I have some grave concerns as to whether we are going to get the services we want at a cost that is going to be meaningful.


A representative of Barclaycard told her:

We are a commercial sector. I need to think 'is there a product, a service that I can charge for and that my customers want?'. I have not witnessed any yet.


Why was there a Home Office press release about the Manchester meeting but not the London meeting?

In a speech on 16 December 2008 [5], the Home Secretary said:

I will continue to put safeguards and openness, a sense of proportion and above all common sense, at the heart of everything we do.


Where is the common sense and openness in issuing misleading press releases?

The Home Office didn't have to wait until APACS and Barclaycard told them last week, Sir James Crosby [6] told them in March 2008 that the NIS is of no use to the UK's banks and retailers. Where is the common sense and openness in telling children about the benefits of ID cards when the prospective commercial users of the NIS have already told the Home Office that there aren't any benefits?

The sponsor of the London meeting is a keen advocate of a national identity infrastructure for the UK and wrote on 7 January 2009 [7]:

This one day seminar will be invaluable for delegates who wish to learn of the commercial opportunities that the British national identity card will provide ... It is simply an opportunity too good to be missed ...


The meeting took place on 29 January 2009 and next day [8] he wrote:

The UK is, I can't help but feel, falling behind. The only infrastructure that the government is putting together, the ID card scheme, has nothing to offer the online world.


Even the keen prospective suppliers on the list are disappointed when they see the Home Office's design for the NIS and find that they have been misled. The list keeps getting shorter. No more Accenture. No BAE Systems. No BT and no QinetiQ. No Steria ...

You were interviewed by Civil Service Network on 17 December 2008 [9]. The interview included this exchange:

What are your priorities for 2009?
I think the key challenge for us is to connect better with peopleís real concerns on, for example, policing, crime and immigration. We need to build public confidence that we are tackling effectively the things that make people feel insecure in their daily lives.

How do you intend to achieve them?
We need to raise our game again in 2009. We need our people to be more professional, more skilled and more knowledgeable about the issues they are dealing with. We want our staff to be listening more to public concerns and getting a first-hand view of the issues we are dealing with. We also want good, confident relations with our key partners and stakeholders, on many of whom we rely for the delivery of effective services.


The Home Office has had over six years to work on the NIS. Rt Hon David Blunkett MP's consultation document on entitlement cards was issued in July 2002 [10]. Where have we got to after all this time?

Answer, the National Identity Scheme is a scheme with no users and no chance of achieving its stated aims. The number of key partners on whom the Home Office can rely for the delivery of ID card services is small, and seems to be falling. When they get a first-hand view of how the Home Office plan to deal with the issues, their enthusiasm tends to evaporate.

Six years after the starting gun, all the NIS has, is press releases.

The press releases tell one story. Progress on the ground tells a quite different story. There is no connection between the two. The Home Office risks forfeiting public confidence.

The NIS scheme appears to be bound to fail, as OGC says, and disconnected from reality. This open letter to you is an expression of real concern and a challenge to you to connect.

Yours sincerely

David Moss




10 examples of misleading assertions
in the Home Office's 29 January 2009 press release:


1 Costs

The latest (Nov 2008) estimated cost of the Service for the next 10 years is £4,785m for UK citizens, including the issue of both passports and identity cards ...

This is an estimate of the amount of money that would pass through the Home Office's books. It excludes other associated costs.

Thousands of other organisations in both the public sector and the private sector and millions of individuals would need to spend money to use the NIS. Their costs are not included in the £4,785 million quoted and this figure is therefore misleading [11].

2 Savings

£1 billion has been saved from the Service since 2007.

This claimed reduction is the consequence of the decision to outsource the collection of biometrics to high street retailers [12]. People would still have to pay to register their biometrics. They would pay a retailer instead of the Home Office. The fact that the money would not pass through the Home Office's books would not make registration any cheaper and it is misleading to suggest that it would.

3 Budgets

Approximately 70% of this cost will need to be spent in any event to implement secure biometric passports. This means contrary to some claims, there is no large sum of money that could be diverted to spend elsewhere if ID cards were cancelled.

The budgets for ePassports and ID cards are co-mingled and at the moment the public have no idea which components are included in which budget. It would be interesting to see how this figure of 70% is calculated. No support for it has been published as far as I know and it is misleading to suggest that it is known to be accurate.

The UK is exempt from EC 2252/2004 [13] Ė we do not have to record fingerprints on ePassports. The Home Office has decided "voluntarily" to add fingerprints to ePassports [14]. That artificially transfers the cost of fingerprinting from the ID cards budget to the ePassports budget. Ireland, with the same exemption as the UK, introduced ePassports for only Ä6.1 million [15].It is misleading to suggest that in the UK they have to cost 70% of £4,785 million.

The cost of ePassports and ID cards is supposed to be covered by passport application fees paid by the public. The fee for a 10-year adult passport has quadrupled since 1997 from £18 to £72. If ID cards are cancelled and fingerprints are not recorded on ePassports, the fees will be reduced, people will be left with a large sum of money they can spend elsewhere and it is misleading to suggest that they won't.


4 Homogeneity

We are one of the only EU countries not to have ID cards - 24 of the 27 EU member states already have identity cards.

It is misleading to suggest that this is a reason to introduce ID cards into the UK. We do not use the same line of argument as a reason to join the Euro Area, for example. It is misleading to appeal to homogeneity when the goal is practical benefit.

5 Compulsion

From 2011-12 identity cards will roll out to the wider population on an entirely voluntary basis.

Any UK citizen applying for a passport will be automatically and compulsorily enrolled in the NIS [16]. That is the plan, if not in 2011-12, then immediately after. It is misleading to suggest that enrolment is "entirely voluntary".

6 Inducement

Manchester and London City airports have agreed to work with IPS and the government as part of the first wave of airports under the critical workers identity card service ...

It is misleading to omit the fact that, according to the Financial Times [17]: "Controversial plans to make thousands of airport workers the first British nationals to be issued with biometric identity cards have been scaled back because of continuing opposition from the airline industry" and "Manchester and London City airports have signed up in principle to the scheme after the government agreed to fund the trial, introducing the first wave of ID cards free of charge to the users and providing a further £500,000 ($790,315) towards improvements in pre-employment checks at the two airports". It looks as though Manchester and London City airports have agreed to work with the Identity & Passport Service (IPS) because they have been paid to, not because they think the NIS would be effective.

7 Redundancy

Identity cards issued to airside workers ... will help ... give holders a highly secure and convenient identity document that can be used to prove their identity ... [and] help ensure all people using airports are confident about their safety whilst there.

Identifying airside workers is not a new issue in the airline industry. Neither is security. There are already measures in place and it is misleading to omit the fact that the airline industry believes that NIS ID cards would add no value[18] [19] .

8 Reality

Identity cards are already a reality for foreign nationals ...

In her speech [the Home Secretary] stressed that in those areas where identity cards are delivered first residents, businesses, local authorities and others will reap the rewards the cards bring including ... a universal and simple proof of identity ... ensuring that foreign nationals living, working and studying here legally are able to easily prove their identity and prevent those here illegally from benefiting from the privileges of Britain ... [and] convenient travel in Europe using the identity card.

There are no scanners to read the ID cards that have been issued [20]. Instead, employers and educational establishments have to rely on this advice from the UK Border Agency [21]: "Physical checks can also be performed on the card. As it is made entirely from polycarbonate, it will have a distinctive sound when flicked ...". It is misleading to assert that this amounts to any sort of proof of identity, let alone a universal proof.

The police arenít linked to the National Identity Register (NIR), DWP arenít linked to the NIR, hospitals and GPs and schools and universities and employers [22] and banks and retailers arenít linked to the NIR, and neither is anyone else, not least because there is no NIR. The NIS is just a plan, an expression of wishful thinking and it is misleading to suggest that NIS ID cards in the sense of the Identity Cards Act 2006 are already a reality [23].

It is unclear how listening out for the distinctive sound of a polycarbonate card being flicked can ensure that only those entitled to them can enjoy the privileges of Britain and it is misleading therefore to suggest that it does.

When it comes to foreign travel, it is unclear how ID cards would be more convenient than the passports we already have and it is misleading therefore to suggest that they would be.

9 Fraud

Statement from the Home Secretary

Jacqui Smith, said ... 'Those benefits include increased protection against identity fraud for the individual ...'

While in Manchester the Home Secretary visited Newall Green High School in Wythenshawe to meet young people who could be some of the first to be able to apply for cards from 2010. Together they discussed how identity cards will help young people strike out on their own by opening their first bank account ...

The Home Office have failed to explain how ID cards would provide increased protection against identity fraud and it is misleading therefore to suggest that they would.

They could not protect against online fraud [24]: "The UK is, I can't help but feel, falling behind. The only infrastructure that the government is putting together, the ID card scheme, has nothing to offer the online world".

Sir James Crosby [25] has already told the Home Office that the banks and the retailers see no benefits in the ID cards scheme.

On the same day the Home Secretary was in Manchester extolling the benefits of ID cards, Meg Hillier MP attended a meeting in London [26] with prospective suppliers to the NIS where APACS and Barclaycard both told her that they see no benefits in the ID cards scheme.

The creation of the NIR could itself increase the level of identity fraud [27] by collecting together in one place so much information the security of which the Prime Minister himself says cannot be guaranteed [28].

This claim of the Home Secretary's is quintuply misleading to the children of Newall Green High School and to everyone else.

10 Biometrics

Statement from the Home Secretary

Jacqui Smith, said, 'Identity cards are already a reality and thanks to Manchester Airportís agreement to work with us, the city is leading the way in their roll-out. As the cards become more widely available the whole country will see real benefits for citizens, businesses and the country by giving a convenient and secure proof of identity that locks people to one identity ...

'Those benefits include increased protection against identity fraud for the individual and help in protecting our communities against criminals, illegal immigrants and terrorists trying to exploit multiple identities.'

The claim that ID cards could lock people to one identity and prevent criminals, illegal immigrants and terrorists from establishing multiple identities relies on biometrics.

The biometrics proposed for the NIS are not reliable enough [29] to lock people to one identity and it is impossible to guarantee that there will be no multiple identities on the NIR [30].

This matter was investigated by the House of Commons Science and Technology Committee and they recommended that the Home Office should make no decisions about biometrics until their reliability has been demonstrated in large-scale field trials [31].

The Committee's recommendation has been ignored by the Home Office. The biometrics have been chosen before the trials have been conducted and in the face of a lot of evidence that these biometrics don't work. That seems unscientific, unbusinesslike and irresponsible[32].

At the very least, it is misleading to suggest that the biometrics proposed would deliver the benefits promised.



[19] see motion 45, National Identity Scheme