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Lin Homer Chief Executive UK Border Agency |
Open letter
8
August 2009 |
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Dear
Ms Homer The danger exists with eBorders that UKBA misleads the public, brings
the international passenger transport systems in the UK to
a near-standstill and spends a fortune deploying biometric
technology at home and overseas, while the borders remain
less safe than they could be because front-line staff don't
have the right equipment and/or the biometrics chosen for
eBorders don't work reliably enough and/or they aren't admissible
as evidence in court, while visa conditions are not enforced
at home, while an internal passport system is perniciously
introduced into the UK and while the personal data of UK citizens
and others is disseminated out of control to agencies all
over the world, when all the time border security could actually
have been increased by using Interpol and EU databases that
have been available to but ignored by the UK for nearly a
decade. That
was the burden of my letter to Sir David Normington
[1],
Permanent Secretary at the Home Office, dated 16 April 2009.
Mr Brodie Clark [2], Head of the Border Force, kindly
replied on behalf of Sir David on 26 June 2009. A lot of questions
remain unanswered nevertheless, and some new questions have
arisen. These are tackled in nine sections below. 1
UKBA 10-point delivery plan UKBA's 10-point delivery plan [3] was announced in a press release dated 24 February 2009. Point #7 is: August 2009 - Have completed delivery of new facial
recognition technology in 10 terminals, giving British passengers
a faster, secure route through the border. It is now August 2009. May I enquire if facial recognition technology has now been delivered to 10 terminals? If the plan has been followed, where are these 10 terminals? If not, may I enquire why not? 2
Facial recognition technology – smart gates UKBA announced a six-month
trial [4]
of facial recognition technology at From this
month the UK Border Agency is trialling new technology at
New facial recognition gates will use scanning equipment to compare
the faces of The history of biometrics
based on facial geometry is an uninterrupted line of failure
[5].
Consistent with that, union leaders and UKBA staff have been
reported by the BBC [6],
the Sunday Times [7]
and the Daily Telegraph
[8] [9]
as saying that the biometric technology being tested is not
up to the job. UKBA deny these reports. But they do not publish
the results of the Presumably the 3
Status of the smart gates initiative In his letter dated 26 June 2009, Mr Clark states that: UKBA commenced testing our Automated Clearance System (ACS) at Is the technology still being tested, as Mr Clark suggests, in which case the 24 February 2009 press release is surely misleading? Or are UKBA confident that it works, as the press release suggests? Which is it, please? 4
Visas – biometric registration centres eBorders requires that non-EEA citizens record their
fingerprints as part of the application process for The Home Affairs Committee has found there are not enough biometric
recording facilities in foreign countries, which is causing
"disproportionate delays and expense" to applicants. The decision to admit non-EEA citizens, or to refuse admission, is based partly on the use of flat print fingerprinting technology. May I enquire what is the performance of the equipment being used? That is, for each tested matching threshold set on the flat print fingerprinting equipment, what are the corresponding false match and false non-match rates? How do these rates vary with the age of the applicants [13]? And with their race and their sex? What alternatives are there for people who are missing fingers? According to the Home Office's July 2002 consultation document on entitlement cards [14] (paras.5.14, 33 and 51), evidence based on flat print fingerprinting is not admissible in court. Is this still the case? And if so, what happens if someone brings a case against UKBA, whether for granting a visa to a non-EEA citizen or for refusing one? If the false match or false non-match rates are unacceptably high, and/or if visa decisions are based on inadmissible evidence, then the Home Affairs Committee are of course wrong to recommend more biometric registration centres. In that case, they will have missed the point – the technology is a waste of time and money, and should be dropped altogether. These UKBA visas are related to the Identity & Passport Service's (IPS) proposed ID cards. They use the same biometrics, they rely on the same technology and they are open to the same problems. The House of Commons Science and Technology Committee were distinctly unimpressed with IPS's plans for ID cards. In their July 2006 report [15], the Committee declared themselves to be "concerned", "surprised", "regretful", "sceptical" and "incredulous" at the "confusion", "inconsistency" and "lack of clarity" of those plans. In particular, the Committee asked IPS to conduct large-scale field trials of biometrics before choosing which ones to rely on. Instead, IPS have chosen first and may or may not conduct trials second. It's back to front and UKBA may suffer the consequences. 5
Visas – card readers On 24 November 2008, a Home Office press release [16] announced that: ID cards for foreign nationals will help secure the On 30 November 2008, the Observer [17] reported that: Do any universities, colleges, schools, hospitals, GPs, job centres, police forces, front-line UKBA staff, etc ..., have appropriate ID card readers yet? If not, how can ID cards secure the UK's borders, improve immigration control, reduce identity abuses, help legal immigrants to prove their right to be here or identify illegal immigrants? Is it the case that the 24 November 2008 press release is no more than wishful thinking or fantasy on the part of the Home Office? If so, do you agree that the press release is misleading? 6
Interpol and Schengen – border-crossing In December 2004, Ron Noble,
Secretary General of Interpol [18],
expressed his surprise at not having his passport checked
as he came into the Ron Noble,
an American, said he was not asked for his passport serial
number when he entered the "It's been proven in every single terrorist incident that a fraudulent passport has been used," Mr Noble told a House of Lords committee. He said officials should record and check the numbers against Interpol's list of five million stolen passports ... As well as the Interpol list, the EU has a database of 10 million lost or stolen passport serial numbers, the EU Home Affairs sub-committee was told. Mr Clark kindly refers to this point in his 26 June 2009 letter: ... the Prime Minister announced on 25 July
2007 our intention to connect the Could you please clarify, front-line officers are now able to check instantly, but do they? In all cases? Or would Mr Noble be just as surprised today as he was in 2004? And is UKBA now making use of the EU database of 10 million lost or stolen passports? If not, why not? In July 2007, after the
"We
have the passport numbers, fingerprints and photos of more
than 11,000 suspected terrorists on our database. But the
Interpol
said last night that the "Why is it that some countries make sure passengers do not carry a bottle of spring water on to a plane, yet aren't careful to ensure convicted felons aren't entering their borders with stolen passports?" It is not clear whether this is covered by Mr Clark's answer. Does UKBA now check everyone against this Interpol list of 11,000 suspected terrorists? If not, why not? And then there is the Schengen Information System (SIS). From the Observer [20], 1 February 2009: The Experts say the database could form a powerful weapon in the fight against crime and terrorism. In the past, Home Office officials have said that connecting British forces to the system had proved impossible due to technical difficulties and "acts of God", such as a fire that destroyed vital IT equipment. Nine years after it became
possible, is the 7
eBorders –
53 questions It has been reported since
November 2007 that, under eBorders, travellers will have to
answer 53 questions [21]
before being allowed to leave the It was reported then, and it still is, that eBorders will lead to travel chaos [22]. Has this problem been resolved? If so, how? It was reported then, and it still is, that the collection and sharing of all this personal data may be illegal [23]. Has this problem been resolved? If so, how? According to the March 2007
joint Home Office-FCO paper describing the eBorders scheme
[24],
personal data may be distributed from the UKBA computer centre
at Wythenshawe [25]
to all or any of the following organisations. Is that still
the case? How will UKBA keep control of that data? And how
can passengers keep control of what is, after all, their
data? · ALON, the Airline Liaison Officer Network, operated
by UKBA, Airline Liaison Officers' "main tasks include the provision of comprehensive training for airline
staff on the United Kingdom's passport and visa requirements
as well as basic techniques of passenger profiling and forgery
awareness"
· ATC, the Authority To Carry scheme operated by UKBA, based on API/PNR and watchlists,
airlines and other carriers can have their authority to
carry refused
· BERR, the Department of Business,
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