MILWAUKEE –

USA – Think you could avoid the TSA’s body scanners and pat-downs by not flying, taking the train or bus, then you’re wrong. The TSA wants to come to your home to complete searches on U.S. citizens even if you do not use any public transport.

“This is just the next step in our special TSA pre-crime initiative where everyone will be screened before they even embark on any type of journey. We’ve heard bad things about you folks who are not even travelling or avoiding public places just because you don’t want your groin groped or an internal body search. Well, we have news for you, we’ll be knocking on your doors at home to bodysearch you there as well,” TSA head, John Lacerta Pistole, told the Washington Observer.

The new TSA rules will require the whole population including new born babies and severely handicapped people to be searched in their homes.

Freedom

Refusing entry to the TSA search party could result in the search denier being detained indefinitely and moved under duress to a secret holding area.

“Remember, the next knock on your home’s door could be from a group of TSA officials waiting with gloved hands to search your orifices and your families holes too. You must grant entry for these officials into your property so that they can violate your bodies with impunity. Once they have searched your bodies, you will be required to put your clothes back on and let the officials leave. You must be calm at all times and any form of agitation, anger or abuse towards our trained TSA goons will result in either tasering or forced detention. Please be aware that we will also be confiscating weapons in all American households, so leave your guns by the door and we’ll take those as well as your daughter’s virginity,” Kevin Pedoslime, a TSA spokesman announced on all U.S. TV channels yesterday.

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Biometrics in Schools, Colleges and other Educational Institutions

The following guidance has been prepared as an aid to schools, colleges and other educational institutions that may be considering the installation and use of a biometric system. This document is intended to encourage such institutions to fully consider if there is need for a biometric system in the first place and then to assess the privacy impact of different systems.

The critical issues to be considered from a data protection perspective are the proportionality of introducing a biometric system and the requirement to obtain the signed consent of the student users (and their parents or guardians in the case of minors) giving them a clear and unambiguous right to opt out of the system without penalty.

The document is not intended to promote any particular system, but is intended to make schools and colleges aware of their responsibilities under the Data Protection Acts 1988 & 2003. It is the use of a biometric system that may give rise to a data protection concern, not necessarily the production or sale of a system. All situations must be judged on a case-by-case basis.

1. Different types of Biometric systems

All biometric systems operate on the basis of the automatic identification or authentication/verification of a person. What differs between systems is the nature of the biometric and the type of storage.

1.1 Information used to generate biometric data

Biometric data may be created from physical or physiological characteristics of a person. These include a fingerprint, an iris, a retina, a face, outline of a hand, an ear shape, voice pattern, DNA, and body odour.  Biometric data might also be created from behavioural data such as hand writing or keystroke analysis. Generally, a digitised template is produced from the biometric data. This template is then compared with one produced when a person presents at a reader.

1.2 Types of biometric data

There are three principal types of biometric data:

• Raw Images, consisting of recognisable data such as an image of a face or a fingerprint, etc.
• Encrypted images, consisting of data that can be used to generate an image.
• Encrypted partial data, consisting of partial data from an image, which is encrypted and cannot be used to recreate the complete original image.

1.3 Types of Biometric systems

There are two principal types of systems:

• Identification systems, which confirm the identity of an individual;
• Authentication / verification systems, which confirm that a biometric derived from a person who presents at a reader matches another biometric, typically stored on a card and presented simultaneously.

1.4 Storage of biometric data.

There are two principal methods of storing biometric data/templates:

• Central databases store the templates on a central system which is then searched each time a person presents at a reader.
• A card is used to store a template. A template is generated when a person presents at a reader, and this template is compared with the template on the card.

Data Protection issues concerning biometrics.

2. Proportionality

Section 2(1)(c)(iii) of the Data Protection Acts states that data

“shall be adequate, relevant and not excessive in relation to the purpose or purposes for which they were collected or are further processed.”

The key word here is “excessive.” Accordingly, the first question to be asked when considering the installation of such a system is what is the need for it? What is wrong with current systems or less invasive alternatives?

As individuals have fundamental Human Rights which are protected by the Data Protection Acts, a school or college must conduct some assessment of the need for a biometric system and an evaluation of the different types of available systems before the introduction of any particular system.

Determining what is excessive requires a case-by-case analysis. Some factors which may be taken into account include:

• Environment. Does the nature of the school or college require high levels of security? Are there areas of the campus which contain sensitive information, high value goods or potentially dangerous material which may warrant a higher level of security than would areas with low value goods or areas with full public access? Of course such a consideration would also point towards all persons working in the environment being similarly required to use the biometric system.
• Purpose. Can the intended purpose be achieved in a less intrusive way? A biometric system used to control access for security purposes in certain areas of the campus might be legitimate while a biometric system used by the same school or college purely for attendance management purposes might not.
• Efficiency. Ease of administration may necessitate the introduction of a system where other less invasive systems have failed, or proved to be prohibitively expensive to run.
• Reliability. If a school or college suffers as a result of students impersonating each other for various reasons, then a system could possibly be justified as long as other less invasive ones have been assessed and reasonably rejected.

3. Fair obtaining and processing.

Section 2(1)(a) of the Acts require that

“The data or, as the case may be, the information constituting the data shall have been obtained, and the data shall be processed, fairly.”

In order to demonstrate compliance with this provision, at least one of the provisions of Section 2A of the Acts must be met. In the context of the introduction of a biometric system for use by students in a school or college, these include:

• Consent, and
• Legitimate interests of the school or college: where the processing is necessary for the purposes of the legitimate interests pursued by the school or college or by a third party or parties to whom the data are disclosed, except where the processing is unwarranted in any particular case by reason of prejudice to the fundamental rights and freedoms or legitimate interests of the data subject.

Consent: In the context of students attending a place of education, the Data Protection Commissioner would stipulate that the obtaining of consent is of paramount importance when consideration is being given to the introduction of a biometric system. It is the Commissioner’s view that when dealing with personal data relating to minors, the standards of fairness in the obtaining and use of data, required by the Data Protection Acts, are much more onerous than when dealing with adults. Section 2A(1)(a) of the Data Protection Acts states that personal data shall not be processed by a data controller unless the data subject has given his/her consent to the processing, or if the data subject by reason of his/her physical or mental incapacity or age, is or is likely to be unable to appreciate the nature and effect of such consent, it is given by a parent or guardian etc. While the Data Protection Acts are not specific on what age a subject will be able to consent on their own behalf, it would be prudent to interpret the Acts in accordance with the Constitution. As a matter of Constitutional and family law a parent has rights and duties in relation to a child. The Commissioner considers that use of a minor’s personal data cannot be legitimate unless accompanied by the clear signed consent of the child and of the child’s parents or guardian.

As a general guide, a student aged eighteen or older should give consent themselves. A student aged from twelve up to and including seventeen should give consent themselves and, in addition, consent should also be obtained from the student’s parent or guardian. (Consent may not be considered to be in place for students in this age bracket unless it is given by both the student and a parent/guardian). In the case of children under the age of twelve, consent of a parent or guardian will suffice. Consent to the use of a biometric system in places of education should be obtained by means of a positive opt-in on the part of students (and/or their parents or guardians as set out above). An audit trail of the opt-ins should be maintained by the data controller for the duration of each student’s enrolment. All students (and/or their parents or guardians as set out above) should, therefore, be given a clear and unambiguous right to opt out of a biometric system without penalty. Furthermore, provision must be made for the withdrawal of consent which had previously been given.

Legitimate interests: Whilst the “legitimate interest” provision may seem appealing, it requires that a balance be struck. What is acceptable in one case may not be acceptable in another and a school or college seeking to rely upon this provision must take into account the potential effect upon student privacy rights. In any event, the Data Protection Commissioner considers that, in the context of a student environment, the processing of personal data using a biometric system would be prejudicial to the fundamental rights and freedoms of the students concerned in the absence of freely given consent.

3A. Fair obtaining of sensitive data.

If a biometric identifies sensitive data (such as data relating to a student’s health or facial appearance thereby revealing race), at least one provision of section 2B of the Acts must be met in addition to those mentioned above. In the context of the introduction of a biometric system for use by students in a school or college, these provisions include:

• consent explicitly given.
• necessary processing for the performance of a function conferred on a person by or under an enactment.

Explicit consent: As stated above, all students (and/or their parents or guardians) should be given a clear and unambiguous right to opt out of a biometric system without penalty. The same consent which applied to the principle of obtaining and processing data fairly also applies to the fair obtaining of sensitive data.

Necessary for the performance of a function conferred under an enactment: Any legal obligation to record the attendance of students need not, in itself, require a biometric system to satisfy. For example, the Education (Welfare) Act, 2000 requires schools to maintain a record of the attendance or non-attendance on each school day of each student registered at the school. This requirement does not specify how the attendance data should be obtained. The key word in this provision of the Data Protection Acts concerning the processing of sensitive personal data is “necessary.” It is the view of the Data Protection Commissioner that the processing of sensitive personal data through use of a biometric system is not necessary to meet the requirements of the Education (Welfare) Act, 2000 in respect of recording student attendance. There are several long established and successful alternative methods of recording student attendance at schools which do not require the processing of a student’s sensitive personal data.

4. Transparency

Section 2D of the Acts require that a school or college provide at least the following information to students when processing their data:

• The identity of the data controller in the school or college.
• The purpose in processing the data.
• Any third party to whom the biometric data will be given.

It is essential that students are aware of the purpose for which the biometrics data will be processed. This means that a school or college must carefully think through any purpose or potential purpose. Is the system solely for attendance management purposes? Will it be used for access control? What are the consequences for the student concerned if there is an identified abuse of the system? Under what circumstances will management access logs created by the system?

Transparency is even more important where the biometric system does not require the knowledge or active participation of a student. A facial recognition system, for instance, may capture and compare images without that person’s knowledge.

5. Accuracy

Section 2(1)(b) of the Acts require that data shall be

“Accurate and complete and, where necessary, kept up to date.”

Any biometric system must accurately identify the persons whose data are processed by the system. If changes in physical or physiological characteristics result in a template becoming outdated, a procedure must be in place to ensure that the data are kept up to date.

6. Security

The requirement, under section 2(1)(d),  that a school or college has appropriate security measures in place to prevent the unauthorised access to, or the unauthorised alteration, disclosure or destruction of data would appear to promote the use of technological solutions such as encryption.

However, in deciding upon what constitutes an appropriate security measure, Section 2C details four factors that should be taken into account:

• The state of technological development.
• The cost of implementing such technology.
• The nature of the data being protected.
• The harm that might result through the unlawful processing of such data.

A minimum standard of security would include:

• Access to the information restricted to authorised staff on a ‘need to know’ basis in accordance with a defined policy.
• Computer systems should be password protected.
• Information on computer screens or manual files should be hidden from persons who are not authorised to see them.
• A back-up procedure for computer held data, including off-site back-up.
• Ensuring that staff are made aware of the school or college’s security measures, and comply with them.
• Careful disposal of documents such as computer printouts, etc.
• The designation of a person with responsibility for security and the periodic review of the security measures and practices in place.
• Adequate overall security of the premises when it is unoccupied.
• Where the processing of personal data is carried out by a data processor on behalf of the school or college, a contract should be in place which imposes equivalent security obligations on the data processor.

7.  Retention

Section 2(1)(c)(iv) of the Data Protection Acts provides that data shall not be kept for longer than is necessary for the purpose. In the context of a biometric system in a school or college, it would be necessary to devise a retention policy in advance of the deployment of the system which clearly sets out the retention period which would apply to biometric data. The Data Protection Commissioner would expect that as soon as a student permanently leaves the school or college, his/her biometric data would be immediately deleted.

8.  Privacy Impact Assessment.

The Data Protection Commissioner cannot give a general approval or condemnation of biometric systems. Each system must be judged in respect of the situation in which it is used. A case-by-case judgement is required. With that in mind, the Commissioner encourages schools and colleges to take the above guidance into account if considering introducing any biometric system.

Before a school or college installs a biometric system, the Data Protection Commissioner recommends that a documented privacy impact assessment is carried out. A school or college which properly conducts such an assessment is less likely to introduce a system that contravenes the provisions of the Data Protection Acts 1988 & 2003. This is an important procedure to adopt as a contravention may result in action being taking against a school or college by the Commissioner, or may expose a school or college to a claim for damages from a student. Data protection responsibility and liability rests with the school or college, not with the person who has supplied the system (where that person also acts as a data processor on behalf of the employer,  it will have its own separate data protection responsibilities in relation to the security of the data).

Some of the points that might be included in a Privacy Impact Assessment are:

• Do I have an attendance management and/or access control system in place?
• Why do I feel I need to replace it?
• What problems are there with the system?
• Are these problems a result of poor administration of the system or an inherent design problem?
• Have I examined a number of types of system that are available?
• Will the non-biometric systems perform the required tasks adequately?
• Do I need a biometric system?
• If so, which kind do I need?
• Do I need a system that identifies students as opposed to a verification system?
• Do I need a central database?
• If so, what is wrong with a system that does not use a central database?
• What is the biometric system required to achieve for me?
• Is it for attendance management purposes and/or for access control purposes?
• How accurate shall the data be?
• What procedures are used to ensure accuracy of data?
• Will the data require updating?
• How will the information on it be secured?
• Who shall have access to the data or to logs?
• Why, when and how shall such access be permitted?
• What constitutes an abuse of the system by a student?
• What procedures shall I put in place to deal with abuse?
• What legal basis do I have for requiring students to participate?
• How will I obtain the consent of the existing students (or their parents/guardians if applicable)?
• How will I obtain the consent of new students (or their parents/guardians) who will enrol at a future date?
• How will I ensure that students will be given a clear and unambiguous right to opt out of a biometric system without penalty?
• What procedures will I put in place to provide for the withdrawal by students of consent previously given?
• What system will I put in place for students who opt out of using the biometric system?
• How will I ensure that students who are unable to provide biometric data, because of a disability for example, are not discriminated against by my school or college by being required to operate a different system, or otherwise?
• Does the system used employ additional identifiers (e.g. PIN number, smart card) along with the biometric?
• If so, would these additional identifiers be sufficient on their own, rather than requiring operation in conjunction with a biometric?
• If the introduction of a biometric system is justified, can I offer an alternative system to individuals who may object to the invasion of privacy involved in a biometric system?
• What is my retention policy on biometric data?
• Can I justify the retention period in my retention policy?
• How shall I inform students about the system?
• What information about the system need I provide to students?
• Would I be happy if I was a student asked to use such a system?
• Am I happy to operate a biometric system in an educational establishment where the use of such a system can make students less aware of the data protection risks that may impact upon them in later life?
• Does my school or college have a comprehensive data protection policy as required by the Department of Education and Science since 2003?
• Have I updated this policy to take account of the introduction of a biometric system for use by students?
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  ACDS, HMDA slate RFID summit for Nov

  ALEXANDRIA, Va. — Pharmacy has emerged as a crucial proving ground for radio frequency identification technology (RFID), with the stakes high for retailers, manufacturers, distributors and the public.

  With that in mind, the National Association of Chain Drug Stores is teaming up with the Healthcare Distribution Management Association (HDMA) to cosponsor the first comprehensive overview of RFID implementation strategy for the pharmaceuticals supply chain.

  The RFID Health Care Adoption Summit will be held from November 13 through November 16 at the Hyatt Regency Crystal City hotel here, with attendees given an opportunity to hear from those in the vanguard of the effort in the business community as well as public policy experts.

  “Given the high degree of interest by the regulatory agencies and the commitment of our industry to transmit pharmaceutical products across a safe and secure supply chain, this conference will focus solely on RFID and how it affects the pharmaceutical supply chain, benchmarking, pilot programs, implementation and the advantages of RFID over comparable technologies,” says an NACDS spokesman.

  The summit will begin Sunday, November 13, with an “RFID 101” session that will provide attendees with an introduction to the fundamentals of the technology, offer definitions of common terms, present a vision of an RFID-enabled supply chain and define who the various participants are in the RFID community.

  The meeting also will feature leaders across the health care spectrum. The opening comments on Monday, November 14, will be made by John Gray, president and chief executive officer of HDMA, and will be accompanied by an “FDA Call to Action” presented by Lester Crawford, commissioner of that agency.

  After those presentations Mark Parrish, chairman and chief executive officer of Cardinal Health Inc., will provide insights into “Why RFID Is Important to My Company.”

  On Tuesday, November 15, opening comments will be presented by Craig Fuller, president and chief executive officer of NACDS, followed by a presentation by Dave Bernauer, chairman and chief executive officer of Walgreen Co., who will talk about the importance of RFID to the drug chain.

  Education sessions will be broken out by function, including finance, distribution and logistics, and manufacturing.

  On Wednesday, November 16, educational sessions will focus on retailer operations, health care distributor operations and manufacturer operations, and will be followed by a closing session wrap-up of the summit.

  COPYRIGHT 2005 Racher Press, Inc.
  COPYRIGHT 2008 Gale, Cengage Learning
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• Use of Biometric Identification Technology to Reduce Fraud in the Food Stamp Program: Final Report

  EXECUTIVE SUMMARY

  Biometric identification technology provides automated methods to identify a person based on physical characteristics—such as fingerprints, hand shape, and characteristics of the eyes and face—as well as behavioral characteristics—including signatures and voice patterns. Although used in law enforcement and defense for several years, it has recently been used in civilian applications and shows some promise to reduce the number of duplicate cases in the Food Stamp Program (FSP) and other assistance programs

  Biometric identification systems are currently operational at some level in Arizona, California (under county initiative, first by Los Angeles County), Connecticut, Illinois, Massachusetts, New Jersey, New York, and Texas. Finger imaging is the principal form of technology used in all eight States, though alternative technologies have simultaneously undergone trials in Massachusetts (facial recognition) and Illinois (retinal scanning). By the end of 2000, new systems are expected to be in place in California (statewide unified system), Delaware, and North Carolina. Other States are currently in the initial planning stages, including Florida, Maryland, Michigan, Mississippi, Pennsylvania, and South Carolina. However, there is little information available at this point regarding the specific course and trajectory these States will follow in terms of system types, implementation schedules, and the benefit programs in which they will implement the new requirement.

  This report provides an overview of the experience of nine States with biometric identification technologies as of September 1999 and discusses some of the major policy and operational issues encountered during implementation and testing. The report also synthesizes available information on the effectiveness of the technology in reducing duplicate participation and provides a discussion of measurement complexities and issues on the horizon as use of the technology continues to expand. A companion report contains an overview of biometric identification technology, examining the functional capabilities, performance, and applications of the various technologies with a particular focus on finger imaging, the most commonly used and well known.

  Telephone interviews of 1-2 hours in duration were conducted in May-June 1998 with representatives of human service agencies in Arizona, California, Connecticut, Illinois, Massachusetts, New Jersey, New York, and Pennsylvania. As part of an earlier task of this study, we conducted site visits to San Antonio, Texas to observe the Lone Star Image System (LSIS) demonstration and to interview State and county agency staff. Information on Texas is based on those visits and interviews. The States interviewed, with the exception of Pennsylvania, have installed biometric identification systems and are requiring applicants to federal and State benefit programs to submit to the new procedures during the eligibility determination process.

  The purpose of the interviews was to explore State experiences with biometric identification systems, including factors in the decision-making and planning processes, the dynamics of system start-up and implementation, issues and problems related to system and agency operations, and perceptions regarding the impact of biometric identification procedures on the application and eligibility determination processes. Each of the States participating in the study was asked to provide a description of the critical early events that occurred during the planning phases of their respective projects. In addition, those States that had already implemented systems were asked to describe their implementation experiences.

  Results of State Interviews

  When finger-imaging technology was first applied to reduce multiple participation fraud in assistance programs, there were many concerns about the performance and reliability of the technology in a social service application, as well as about the potential stigma that a finger-image requirement would place on potential clients. The experience of the eight States that have incorporated finger imaging into the process of applying for welfare assistance suggests that many of these fears were unfounded. Finger imaging has been readily integrated into the human services programs of the affected states. However, despite the positive reaction to finger imaging from the State officials we interviewed, there is still uncertainty regarding the extent to which this technology can reduce multiple participation fraud.

  The States planned for implementation of their biometric identification systems in response to a wide variety of factors and considerations idiosyncratic to each State environment. Some States reported that their respective legislative mandates, which prescribed specific dates by which biometric systems were required to be in place, allowed insufficient time for development and planning. The States developed and followed implementation schedules in accordance with internal priorities and considerations. The States uniformly described their implementation processes as largely uneventful, though they encountered a variety of minor implementation issues, most of which were associated with the logistical difficulties of mobilizing and managing such a complex initiative.

  Preparing staff for the implementation of the biometric systems, both philosophically and operationally, took different forms, priorities, and levels of effort in the States. At implementation, advance notification to clients and/or the general public about new biometric client identification procedures was considered important by all State representatives. The objective of providing advance notification was to inform and prepare clients for the additional application or recertification step (i.e., to explain the requirement and who is required to submit, and to address client concerns), as well as to accelerate enrollment of the existing caseload. All States prepared informational mailings to clients advising them of the new requirement. Some States reported developing additional outreach media including multilingual (English and Spanish) videos, posters, and brochures for viewing and distribution in the local office. Most of the States also identified various outlets in the community through which they informed the general public in advance about the implementation of biometric client identification procedures.

  The States with operating systems reported that implementation of new biometric client identification procedures had a negligible impact on operations at the local office level. In general, States also reported that the problems and obstacles encountered in operating their respective projects are not unlike those encountered in demonstrating any new technology or procedural modification. These States also reported that their systems and procedures were implemented without unexpected difficulty and were rapidly institutionalized. All the States confronted a range of basic physical space and logistical issues, including where to situate the new equipment, how to appropriately alter job descriptions, who to reassign or hire to handle the new procedures, and how to adjust the flow of clients and paperwork most efficiently. However, none reported any particularly noteworthy difficulties. States reported that clients have been cooperative and accepting of the technology.

  Finger Imaging and Fraud Reduction

  Assessing the ability of finger imaging to reduce fraud is difficult because the amount of fraud caused by duplicate participation in welfare programs is unknown, and because changes in caseload after the introduction of finger imaging cannot be interpreted unambiguously as reduction of fraud. The evaluations of finger imaging systems conducted by six States have produced the following findings.

  • A small number of duplicate applications (approximately 1 duplicate for every 5,000 cases) have been detected by finger imaging systems. Finger-imaging systems appear to detect more fraud in statewide implementations than in regional pilot systems. Additional matches have been found by interstate comparisons of finger-image data.
  • Institution of a finger-imaging requirement can produce a significant, short-term reduction in caseload, because some existing clients refuse to comply with the requirement. The number of refusals depends on the implementation procedures and appears to be lower when finger imaging is incorporated into the recertification process.
  • The most carefully controlled estimate of non-compliance among existing clients suggests that introduction of a finger-imaging requirement reduces participation by approximately 1.3%. However, this estimate reflects both reduced fraud and deterrence of eligible individuals and households.

  Finger Imaging as a Deterrent to Legitimate Participants

  Clients do have some concerns about finger imaging. Roughly 15% expressed concerns in the State surveys and interviews conducted to evaluate finger-imaging programs. These concerns center on issues of privacy, unjust treatment of poor people, inconvenience, and fear of interagency sharing.

  There is little data on which to estimate the size of the deterrence effect. Based on the results from client surveys in five States, a substantial majority of clients had no objection to finger imaging and thought it was a good idea.

  There was little evidence that clients discontinued benefits because they were intimidated by the finger-image requirement. Interviews with former clients in Texas found that only two of the 78 former food stamp recipients (both of whom had refused to be imaged) attributed their loss of benefits to finger imaging. Similar interviews in Los Angeles County found that, of those former clients interviewed, no one who refused to be finger imaged expressed a concern with the process.

  Cost and Effectiveness of Finger Imaging

  Since there is no reliable estimate of the magnitude of duplicate participation in the FSP, there is uncertainty regarding the cost effectiveness of finger imaging. Available data are inadequate to make precise estimates of either the costs or benefits of finger imaging for the FSP. Calculations using the data that are available, supplemented by a number of assumptions, suggest that reduction in caseload covers the costs of finger imaging technology. However, the percentage of the caseload reduction due to decreased multiple participation is unclear.

  The analysis makes no assumption about how costs or benefits are allocated among Federal or State agencies. In addition, it does not include the cost required to modify existing software to make it compatible with the finger-imaging system. Finally, it does not take into account that certain cost elements, such as the cost for infrastructure or centralized equipment, may be independent of caseload fluctuation.

• ============================================

• Use of Biometric Identification Technology to Reduce Fraud in the Food Stamp Program: Final Report

  EXECUTIVE SUMMARY

  Biometric identification technology provides automated methods to identify a person based on physical characteristics—such as fingerprints, hand shape, and characteristics of the eyes and face—as well as behavioral characteristics—including signatures and voice patterns. Although used in law enforcement and defense for several years, it has recently been used in civilian applications and shows some promise to reduce the number of duplicate cases in the Food Stamp Program (FSP) and other assistance programs

  Biometric identification systems are currently operational at some level in Arizona, California (under county initiative, first by Los Angeles County), Connecticut, Illinois, Massachusetts, New Jersey, New York, and Texas. Finger imaging is the principal form of technology used in all eight States, though alternative technologies have simultaneously undergone trials in Massachusetts (facial recognition) and Illinois (retinal scanning). By the end of 2000, new systems are expected to be in place in California (statewide unified system), Delaware, and North Carolina. Other States are currently in the initial planning stages, including Florida, Maryland, Michigan, Mississippi, Pennsylvania, and South Carolina. However, there is little information available at this point regarding the specific course and trajectory these States will follow in terms of system types, implementation schedules, and the benefit programs in which they will implement the new requirement.

  This report provides an overview of the experience of nine States with biometric identification technologies as of September 1999 and discusses some of the major policy and operational issues encountered during implementation and testing. The report also synthesizes available information on the effectiveness of the technology in reducing duplicate participation and provides a discussion of measurement complexities and issues on the horizon as use of the technology continues to expand. A companion report contains an overview of biometric identification technology, examining the functional capabilities, performance, and applications of the various technologies with a particular focus on finger imaging, the most commonly used and well known.

  Telephone interviews of 1-2 hours in duration were conducted in May-June 1998 with representatives of human service agencies in Arizona, California, Connecticut, Illinois, Massachusetts, New Jersey, New York, and Pennsylvania. As part of an earlier task of this study, we conducted site visits to San Antonio, Texas to observe the Lone Star Image System (LSIS) demonstration and to interview State and county agency staff. Information on Texas is based on those visits and interviews. The States interviewed, with the exception of Pennsylvania, have installed biometric identification systems and are requiring applicants to federal and State benefit programs to submit to the new procedures during the eligibility determination process.

  The purpose of the interviews was to explore State experiences with biometric identification systems, including factors in the decision-making and planning processes, the dynamics of system start-up and implementation, issues and problems related to system and agency operations, and perceptions regarding the impact of biometric identification procedures on the application and eligibility determination processes. Each of the States participating in the study was asked to provide a description of the critical early events that occurred during the planning phases of their respective projects. In addition, those States that had already implemented systems were asked to describe their implementation experiences.

  Results of State Interviews

  When finger-imaging technology was first applied to reduce multiple participation fraud in assistance programs, there were many concerns about the performance and reliability of the technology in a social service application, as well as about the potential stigma that a finger-image requirement would place on potential clients. The experience of the eight States that have incorporated finger imaging into the process of applying for welfare assistance suggests that many of these fears were unfounded. Finger imaging has been readily integrated into the human services programs of the affected states. However, despite the positive reaction to finger imaging from the State officials we interviewed, there is still uncertainty regarding the extent to which this technology can reduce multiple participation fraud.

  The States planned for implementation of their biometric identification systems in response to a wide variety of factors and considerations idiosyncratic to each State environment. Some States reported that their respective legislative mandates, which prescribed specific dates by which biometric systems were required to be in place, allowed insufficient time for development and planning. The States developed and followed implementation schedules in accordance with internal priorities and considerations. The States uniformly described their implementation processes as largely uneventful, though they encountered a variety of minor implementation issues, most of which were associated with the logistical difficulties of mobilizing and managing such a complex initiative.

  Preparing staff for the implementation of the biometric systems, both philosophically and operationally, took different forms, priorities, and levels of effort in the States. At implementation, advance notification to clients and/or the general public about new biometric client identification procedures was considered important by all State representatives. The objective of providing advance notification was to inform and prepare clients for the additional application or recertification step (i.e., to explain the requirement and who is required to submit, and to address client concerns), as well as to accelerate enrollment of the existing caseload. All States prepared informational mailings to clients advising them of the new requirement. Some States reported developing additional outreach media including multilingual (English and Spanish) videos, posters, and brochures for viewing and distribution in the local office. Most of the States also identified various outlets in the community through which they informed the general public in advance about the implementation of biometric client identification procedures.

  The States with operating systems reported that implementation of new biometric client identification procedures had a negligible impact on operations at the local office level. In general, States also reported that the problems and obstacles encountered in operating their respective projects are not unlike those encountered in demonstrating any new technology or procedural modification. These States also reported that their systems and procedures were implemented without unexpected difficulty and were rapidly institutionalized. All the States confronted a range of basic physical space and logistical issues, including where to situate the new equipment, how to appropriately alter job descriptions, who to reassign or hire to handle the new procedures, and how to adjust the flow of clients and paperwork most efficiently. However, none reported any particularly noteworthy difficulties. States reported that clients have been cooperative and accepting of the technology.

  Finger Imaging and Fraud Reduction

  Assessing the ability of finger imaging to reduce fraud is difficult because the amount of fraud caused by duplicate participation in welfare programs is unknown, and because changes in caseload after the introduction of finger imaging cannot be interpreted unambiguously as reduction of fraud. The evaluations of finger imaging systems conducted by six States have produced the following findings.

  • A small number of duplicate applications (approximately 1 duplicate for every 5,000 cases) have been detected by finger imaging systems. Finger-imaging systems appear to detect more fraud in statewide implementations than in regional pilot systems. Additional matches have been found by interstate comparisons of finger-image data.
  • Institution of a finger-imaging requirement can produce a significant, short-term reduction in caseload, because some existing clients refuse to comply with the requirement. The number of refusals depends on the implementation procedures and appears to be lower when finger imaging is incorporated into the recertification process.
  • The most carefully controlled estimate of non-compliance among existing clients suggests that introduction of a finger-imaging requirement reduces participation by approximately 1.3%. However, this estimate reflects both reduced fraud and deterrence of eligible individuals and households.

  Finger Imaging as a Deterrent to Legitimate Participants

  Clients do have some concerns about finger imaging. Roughly 15% expressed concerns in the State surveys and interviews conducted to evaluate finger-imaging programs. These concerns center on issues of privacy, unjust treatment of poor people, inconvenience, and fear of interagency sharing.

  There is little data on which to estimate the size of the deterrence effect. Based on the results from client surveys in five States, a substantial majority of clients had no objection to finger imaging and thought it was a good idea.

  There was little evidence that clients discontinued benefits because they were intimidated by the finger-image requirement. Interviews with former clients in Texas found that only two of the 78 former food stamp recipients (both of whom had refused to be imaged) attributed their loss of benefits to finger imaging. Similar interviews in Los Angeles County found that, of those former clients interviewed, no one who refused to be finger imaged expressed a concern with the process.

  Cost and Effectiveness of Finger Imaging

  Since there is no reliable estimate of the magnitude of duplicate participation in the FSP, there is uncertainty regarding the cost effectiveness of finger imaging. Available data are inadequate to make precise estimates of either the costs or benefits of finger imaging for the FSP. Calculations using the data that are available, supplemented by a number of assumptions, suggest that reduction in caseload covers the costs of finger imaging technology. However, the percentage of the caseload reduction due to decreased multiple participation is unclear.

  The analysis makes no assumption about how costs or benefits are allocated among Federal or State agencies. In addition, it does not include the cost required to modify existing software to make it compatible with the finger-imaging system. Finally, it does not take into account that certain cost elements, such as the cost for infrastructure or centralized equipment, may be independent of caseload fluctuation.