Home Office
UK Border
Agency

Mr David Moss

BY EMAIL

Lin Homer
Chief Executive
XXXXXXXXXX
2 Marsham Street
London
SW1P 4DF

XXXXXXXXXX
Web www.ukba.homeoffice.gov.uk

3^rd February 2010

I am responding to your recent letters and wish to renew the offer of a meeting between you and key staff involved in the assurance of the identity of travellers. I welcome your interest and concern in the development of systems to secure our border, and note your extensive history of correspondence with Home Office ministers and officials. This is an area of great importance not only to the staff who are responsible for ensuring that the UK Border Agency protects the public with the most effective means at its disposal, but to those who have a broader interest in the technology and how it is deployed.

Although this area of our business presents a range of new challenges, not least in terms of the development of technology, we believe that we are putting the right systems in place to help us achieve our objective of securing the border. At the same time, we understand that these systems have their limitations, and cannot be expected to deliver a complete solution in isolation. We are very much reliant upon the skills and experience of our staff to make the most of these tools and protect the public.

I would like to propose a meeting with representatives of the Home Office Scientific Development Branch (Marek-Rejman-Greene), the Identity and Passport Service (Kevin Sheehan) and UK Border Agency (Alex Lahood and Karen Kyle) to address some of the issues you have raised. To prepare for this, we have set out our approach and thinking in the various areas where you have repeatedly raised concerns (please see attached — Annex A). We hope this gives you an opportunity to understand our approach in advance of the meeting.

As I am aware that you make full use of the internet to record your interactions with Home Office officials, I invite you to publish this letter and its annex in full, to ensure that the points made are presented in context.

Please contact XXXXXXXXXX on XXXXXXXXXX or XXXXXXXXXX to arrange the meeting.

Yours sincerely

Lin Homer

Annex A

1. Interpol Lost and Stolen Database

With regard to concerns about whether UKBA makes enough use of the Interpol lost and stolen database:

On 25 July 2007, in response to the findings of the West Review, the Prime Minister announced that the capability to make checks against the Interpol Stolen Lost Travel Documents database (SLTD) would be implemented at UK border crossing points. The solution chosen was the Interpol MIND (Mobile Interpol Network Device). This enabled the UK to retain its capability to search against its national watchlist at ports whilst conducting a parallel search on the SLTD as an integrated process and was made available to 95 sites (32 fixed control sites & 63 Back Office Sites) by the end of December 2008, giving the ability to check the Interpol database at border crossing points and for visa and in-country applications.

The Interpol database has increased rapidly as more countries have participated and now contains approximately 30 million documents. The link to the Interpol SLTD is therefore an effective tool to further enhance the primary frontline role of securing the UK border, reducing illegal immigration and protecting the UK against the risk of terrorism.

Accessing the SLTD has led to a significant number of successful interventions in identifying forged documents, imposters and stolen blank documents at the Border. It has been possible to take prosecution action over offenders identified at the border and there have also been successes from conducting checks pre-entry (visa applications) and in-country (applications for residency, marriage, students etc). One of the first successes within a week of 'go live' was identifying a stolen document in Bogota and refusing a visa.

Around 70 million checks are made against the database per year and to date there have been 13346 hits and 5108 documents seized.

2. Schenqen Information System

An update on plans to connect to the Schengen Information System:

The UK is planning to connect to the second-generation Schengen Information System (the Central SIS II), which is being developed by the European Commission. The Commission-led project has experienced a series of technical issues which have delayed the entry into operation of the Central SIS II, and based on the Commission's current estimates, the earliest the UK will be able to connect is December 2011.

The UK is only taking part in the law enforcement aspects of SIS II. Via the e-borders system, SIS II will provide UK law enforcement agencies at the border with access to alerts on wanted and missing persons, lost and stolen passports and other identity documents, and lost and stolen vehicles.

3. Facial Recognition Technology

ln response to accusations that facial recognition technology used by UKBA is unreliable:

• How we use systems in our business
UKBA is currently trialling the use of automated gates using facial recognition technology at 10 sites across the UK. The gates process EEA passengers over the age of 18 who hold biometrically enabled passports. The technology used has proved reliable within the operational environment, although does not provide a stand alone solution, as the banks of gates are monitored by a Border Force officer at all times. Staff continue to use their judgement and discretion to intervene where necessary.

• Why we are confident they are reliable
There have been considerable improvements in the performance of face recognition technology over the past decade. Taken together with the international standardisation of the face formats as encoded in the chip in first generation biometric passports, this has encouraged a number of countries to trial automated gates at airports. As these and further trials are undertaken, UKBA will continue to review whether such systems meet our operational requirements.

Many trials have been undertaken using facial recognition for 1:1 verification and an independent test in 2006 by NIST actually states that the performance of iris (which has been in use for several years by UKBA), 2D facial image and 3D facial image for the purposes of verification has become comparable. The technology is likely to have improved since 2006 and that is why we are trialling it.

• Evaluation of Manchester trial
We plan to evaluate all 10 sites. Evaluation of Manchester gave us enough confidence to proceed to expand the trial. We are aware that different environments may impact the use of facial recognition technology, we therefore wished to determine and compare results from more diverse airport environments to ensure the technology is robust and consistent.

• Claims that the FBI do not have confidence in facial recognition technology
We understand that you have not accurately represented the views of Mr James A Loudermilk II when you reported his comments about facial recognition technology. Indeed, Mr Loudermilk himself has recently stated that:

"Mr. Moss relies upon some remarks of mine, which he has taken out of context, to support his own conclusions about the efficacy of facial recognition for identity verification. Let me unequivocally state that the FBI holds no such position and never has."

When considering context in terms of biometrics, a business need to bring successful prosecutions to court, for example, may have a very different way of judging an enabling technology than one that is concerned with border control. What works for one business area may very well not be suitable for another.

4. Fingerprint Technology

• How we use it in our business, including role of the IFB
Fingerprints are used to "fix" an identity to foreign nationals. Subsequently they are used to verify this identity in future encounters. IFB (Immigration Fingerprint Bureau) is staffed by fingerprint experts who manually confirm suggested fingerprint matches made by IAFS (Immigration and Asylum Fingerprint System) and prepare evidence for court/appeals when necessary.

• Our view on accuracy and the reliability of these systems
Automated Fingerprint Identification systems are extremely sophisticated systems using proven technology. They are extremely reliable and in UKBA we also use fingerprint experts to verify suggested matches. Through years of experience UKBA understands very well how to deploy our fingerprint comparison specialists in tandem with our current automated fingerprint identification system so as to minimise automated match error rates and provide the highest possible level of confidence to the end business users for fingerprint identifications.

• Why we are confident they are reliable
These systems have been in use for many years all over the world. Experts in UKBA have experience of using several systems all of which proved highly effective. Benchmark testing is carried out at intervals in order to confirm the system's matching performance. In addition, the interaction between IFB Experts and the system (for example in verifying suggested matches) provides an ongoing ability to assess accuracy.

• Are flat scans/electronic fingerprints a less useful format than rolled – e.g. are they inadmissible in court as evidence, or a lower evidential standard.
Flat scans/electronic fingerprints are admissible in court as evidence and they are not considered to be of lower evidential standard. Courts also accept evidence on partial fingerprints.