Parliamentary briefing – Creation of a Scottish National Identity Register


“The current proposals which are being consulted on represent a bigger threat to Scottish privacy than the UK wide Identity Card system proposed by the last government in Westminster.” – Guy Herbert, General Secretary, NO2ID

What’s the issue?

Currently the Scottish Government and National Records of Scotland (NRS) are consulting on proposals to change regulations that govern what personal information is stored on the National Health Service Central Register (“the NHSCR”), and who that information can be shared with. This consultation is entitled “Consultation on proposed amendments to the National Health Service Central Register (Scotland) Regulations 2006” .

What’s the Problem with this?

The consultation proposes increasing the information held on the NHSCR to include more detailed postcode and address information. It also proposes to allow a whole host of Scottish public bodies (around 120) access to this information. Examples of the bodies who would have access to this information include the Glasgow Prestwick Airport, Scottish Water, Caledonian Maritime Assets Ltd, HMRC, and the Department of Education. The result of this will be to create a Scottish National Identity register.

Tracked across the database state with a unique identifier

The proposed National Identity Register would be linked to Scottish Entitlement Cards through the myaccount system. Both the NHSCR and the myaccount system use the same Unique Citizen Reference Number (UCRN). This is a unique identifier for each citizen that can track them from cradle to death across various database systems. It has all the hallmarks of the UK wide National Identity Register that was established in the Identity Cards Act 2006 and widely opposed at the time. This scheme actually goes further than the Home Office’s defeated scheme as it proposes using this identifier across NHS records as well. The ICO watchdog has warned of the dangers of doing this stating: “The ICO has concerns as to whether there is a sufficient public interest justification. “We do advocate against the creeping use of such unique identifiers to the extent that they could become the national identity number by default.

Linked to entitlement cards

Entitlement cards were established initially to replace bus passes. Since then we have seen a significant amount of administrative ‘function creep’ as to the purposes for which these cards are used. The myaccount system that runs these cards links up to the NHSCR through the same Unique Citizen Reference Number. We think it’s plainly clear these entitlement cards are developing into a fully fledged Scottish National Identity Card .

Medical Research

The proposals involve granting access to the register to researchers’ conducting a medical research project. It is not clear whether consent would be required for this research or whether individuals would be able to object or opt-out of their personal details and information being used for research purposes. We think this is a serious privacy concern that needs addressing.

Privacy Concerns

The creation of such a National Identity Register is a dramatic shift in how Scottish Society is organised. It will have far reaching implications for how things are administered, and the impact on individuals personal privacy. Such a change should be subject to a public debate around the issues. Unfortunately it is currently presented by the Scottish Government as an anodyne change in regulations. We think there are potential compliance problems with other UK data protection laws, and that additional legislation would need to be created to ensure adequate governance and safeguards. None of these wider issues are addressed in the consultation.

The Solution

NO2ID would urge all Scottish parliamentarians and Westminster parliamentary candidates to oppose such an expansion of the database state in Scotland. It is an illustration of centralising control, and an attempt to manage society and people on computers. The system would dramatically increase the surveillance capacity of Scottish public bodies to track individuals through the system.

At the very least we would expect such a dramatic change to be subject to a public debate and be done through primary legislation in the Scottish Government, rather than through obscure changes in regulations that most people do not understand.

For further information on this scheme please contact NO2ID
General Secretary – Guy Herbert – general.secretary@no2id.net – 07956 544 308

Campaigns Manager – James Baker – campaigns@no2id.net – 07817 605 162
The NO2ID Campaign Box 412 19-21 Crawford Street London W1H 1PJ enquiries@no2id.net Tel: +44 (0) 20 7340 6077

About NO2ID

NO2ID is the UK-wide, non-partisan campaign opposing the government’s National Identity Scheme (‘ID cards’) and the database state. We bring together individuals and organisations from all sections of the community and seek to ensure that the case against ID cards and the database state is forcefully put forward in the media, in the corridors of power and at grassroots level.