LSE team responds to Home Office’s criticisms of The Identity Project report

Abstract

This document sets out the response of the LSE’s ID Project Report Team to the Home Office’s critique (published July 2005) of our Identity Project report. For ease of reference, the LSE response is based on the format of the Home Office (hereafter HO) document. The Home Office document contains some interesting elements and we welcome the fact that the project team are engaging more fully with critics. But we are disappointed that the HO response contains substantial material errors and misrepresentation of fact. It also sets out rebuttals that cite material which is not relevant to the points in question. On a number of critically issues, HO’s response rebuts aspects of the LSE report without providing alternative data (for example, on assumptions relating to population data, card loss and damage rates and the card replacement rates due to change in personal circumstances). It is equally disappointing that the Home Office has chosen to disregard the vast majority of the LSE report. Comprehensive sections on identity fraud, policing, crime, national security, counter-terrorism, discrimination, international obligations and the UK IT environment have been ignored. Even within the two narrow areas that were chosen for rebuttal (cost projections and the alternative blueprint) 80 per cent of the relevant parts of the LSE report – some 25,000 words of analysis of costings and alternative approaches – are not commented upon. The Home Office appears to have ignored the substantial analysis of cost assumptions published in the LSE report. As a result the rebuttals published in its response relating to cost estimates are largely irrelevant. We have, however, accepted a small number of criticisms of the alternative blueprint and will be considering these over the summer in the consultation phase for our proposals. The Home Office’s paper has confused the cost estimates provided by Kable, with those developed by LSE. We stressed in the acknowledgements section of our report that the Kable framework was used as the basis of our approach to developing cost projections. However, the subsequent sets of figures bear little or no relation to each other, as each was built on different parameters and assumptions. We believe that many relevant issues not contained in the Home Office’s response have the potential to form points of agreement between HO and the LSE analysis. For example, the Home Office has not criticised the private credentials architecture explored in the report, nor was there any disagreement expressed with the concept of an invisible identity number. We hope in the future to work with HO officials to develop these lines of research. We note that in its response the Home Office has made a number of new claims for its identity scheme (e.g. that the checking of biographical footprints and updates of the national identity registry will be largely automated). These and other claims are not sourced in the attempted rebuttal. So we await further details before taking them into account in developing Version 2.0 of our report, due for publication in the autumn.