Passport Canada distinguishes the ‘contactless chip’ it will use in the e-passport from Radio Frequency Identification (RFID) tags, which can be read using a digital reader from many feet away. RFID tags pose significant privacy risks because of the ease with which a reader can be used surreptitiously, and through clothing. Because of the lack of transparency in the development and implementation of e-passports, it is not clear whether the purported security benefits of ‘contactless chips’ are real or illusory.
It is also not clear what information will be available to the public or to individuals whose photographs would be entered into the Facial Recognition System. At the time of writing, no administrative process for complaint or adjudication appears to have been established (except for that available under the Privacy Act).
One commentator has noted that there is very little information publicly available about the e-passport project. (1) Commentators have noted that both the e-passport project and the facial recognition project (discussed below) are being introduced with little or no public debate. They argue that this amounts to ‘policy laundering’ - introducing programs to meet the standards developed by foreign countries or international bodies that might not meet approval by the citizens of Canada. (2)
Facial Recognition Pilot Project
The Facial Recognition Project is intended to collect from other government agencies and departments photographs of individuals whose status in Canada would make them ineligible for a passport or other travel document. The idea is to match the photos submitted with application forms against photos provided by these other government agencies and departments. Pilot projects have been completed and full implementation is scheduled for 2009.
The Facial Recognition Project involves taking a digital picture of the photos of individuals and converting the digital picture into a string of computer code called a photo biometric identifier.
The biometric identifier is designed to produce a match to a photograph. Early test results of the facial recognition technology indicated that, using images of the best quality, those that meet the International Civil Aviation Organization standard, correct matches were made 88% of the time. When image quality drops, correct matches drop as well.
The accuracy rate of 88% or less means that more than one out of every 10 people is at risk of being misidentified as ineligible for a passport. This means that more than 3.3 million Canadians are at risk of misidentification.
Therefore there will be numerous false positive and false negative suggested matches. A false positive means that the system proposes a match to a photograph, but in fact the biometric and the photograph represent two different people. A false negative means a match should have been made but wasn’t.
When the system indicates an apparent match, a human operator in the Security Division considers whether the match is sufficiently positive to follow up with the department that provided the original photo to determine if the individual is still ineligible for a passport.
The process is designed to be verified by individual staff at Passport Canada and at the department whose source photo matched the biometric. However, the fact of being identified by the biometric facial recognition system will be noted in the individual’s file and if the suggested match is dismissed as false, that is to be noted on the file as well to reduce the chances of a repeated mismatch later.
One can see that there are significant chances for error at the verification and reporting stages which will surely put even more individuals at risk for misidentification or discrimination on the basis of inaccurate information.
- (2) See for example Andrew Clement and Krista Boa Developing Canada’s Biometric Passport: Where are the Citizens in this Picture?