The Office of National Statistics' consultation on 'Civil Registration: Delivering Vital Change' closes today. The proposals include allowing the registration of births and deaths on-line and over the phone, as well as in person and information will be held in a central database.
The intention is to create a "through life record" by joining up all the existing records, making it easier for people to verify their identities, or have their identities verified for them, by the Passport Agency, DVLA or even insurance agencies.
But the FIPR is concerned that the proposed database will develop over time to include other information. Fraud and crime prevention could be argued to justify the inclusion of information relating to social security benefits, tax, passports, drivers' licences, criminal records and more, says the rights group.
Public health considerations might be argued to justify extension of the snapshot of information about the cause of death to an accumulation of information about health events during life. The protection of children might be argued to justify linkage with information accumulated by social services departments.
The FIPR is also concerned about the security of the database. Given the record of Government IT projects so far it fears that mistakes could be made in the inputting of information, or the processing of that information.
In addition, paper records provide historical evidence that is hard to retrospectively alter. Any computer database proposed to replace these records must be very carefully designed to ensure that it prevents information being altered after the fact, warns the FIPR.
According to Nicholas Bohm, General Counsel for the FIPR: "The Government must avoid the risks of turning the register of births into a set of comprehensive dossiers on every citizen."
He added: "We should not be moving towards a system where our very identity is dependent on registration by the Government in a central database."
Dr. Chris Pounder, a data protection expert with Masons, the law firm behind OUT-LAW.COM, commented:
"If these proposals move forward, it is important to understand that the Data Protection Act might offer little in the way of protection to individuals because the scheme will have a statutory basis."
"If this statute defines the content of personal data and specifies uses and disclosures which are widely drawn, then the effect is to negate the impact of the first three Data Protection Principles – and the fact that the purpose is for life-time events effectively negates the requirement to keep personal data no longer than is necessary (the Fifth Principle)".