Five Questions of Doubt of the Digital ID (eID)

The 2019 coronavirus epidemic has hit the global economy. As of now, the tourism industry, aviation industry, financial industry, and service industry have all been greatly threatened. In this environment, the only industry that remains untouched are the e-commerce and delivery industry, which illustrates the importance of the digital age to humanity.

However, were you aware? During the period of the preventative measures of the epidemic, the government also silently advanced other policy agendas in science and technology, such as inserting the "The Regulation of Comprehensive Renewal of National Identity Card".

#1 Question of Doubt:
The Regulation was only announced in March this year, but it took effect in January last year

The one action of the government in so far had been a revision of the law is the publication of the “The Regulation of Comprehensive Renewal of National Identity Cards”. However, this Regulation, which was only announced on March 19, 2020, has an date of effect on January 1, 2019. The silent entry of these policy implementation dates for the plan of renewal of digital IDs was approved by the Executive Yuan in the middle of last year, which suddenly become compliance with the law. However, though the discrepancy of having the Regulation be in effect for more than a year,   the content of the comprehensive renewal plan approved based on the Regulation still remains a black box.

#2 Question of Doubt:
While the administration insists that eID has no privacy and security risks, the Taiwanese government has been frequently reported security incidents in the past

The government continues expect the people to believe that eID will not have privacy and security risks. However, if the government expands the application of ID cards to the digital field, it may have greatly eroded the anonymity of people’s digital lives. Additionally, card reading verification is more likely to have other derived privacy risks, such as digital footprint and online identity theft. These potential risks are indisputable facts. In addition, regarding the information security of a large amount of data, Taiwan’s has experienced incidents of hacking regarding household registration data and health insurance data. How is the government able to ensure people's privacy and information security?

#3 Question of Doubt:
Germany is often cited as a model example, but Taiwan insists on no need for legislation or amendment

In response to the above risks, the government has stated that the current legal system is sufficient and there is no need to amend laws or legislation. Yet, it often takes Germany as a stellar example to follow. However, even when Germany made a similar eID, not only did it have additional provisions of data protection law, but also have agency to oversee such laws that Taiwan currently lacks. Even so, Germany still established a special law and that reaffirms and outlines verification of digital identity cards, verification methods, identity cards information, information security issues, data storing, and penalties for violations of the regulations...etc. On the other hand, in Taiwan, there is no such legal regulations. What remains in policy is greed and convenience. What more should it be said?

#4 Question of Doubt:
While the government insists that there is only one specification for the identity card, it also concurrently plans a card-free identity card

The government said that in order to save administrative and management costs, the national identity card must have uniform specifications with no two types of cards (with chip cards & no chip cards). But the problem is that the government has also begun to design a mechanism for identity verification through mobile apps. If the "identity card" can only have one form, we would like to ask the government whether the cardless mobile app is another form. ? Doesn't designing apps for such purposes actually increase the cost of administration and management?

#5 Question of Doubt:  

The full replacement plan has been under a black box so far, but the bid of 4.4 billion for the project has been nearly completed

It has been more than two years since the government planned to renew the eID. The comprehensive renewal plan was approved by the Executive Yuan in June last year, but the full text of the plan has not yet been announced. Since then, non-governmental organizations have been requesting information to be publicly disclosed. Yet, the government has always insisted on not publishing related plans on the grounds of "preparation before intending any decision". However, despite the project hidden within a black box, the eID project continues to accept bids one after another. Up to now, there have been bids for printed card cases (3.29 billion), hardware and software system construction (890 million), and system verification cases (150 million). With a huge amount of nearly 4.4 billion bids, due process should be followed. However, the procedure is reversed. How should such a policy win the trust of the people?

The Taiwanese Association for Human Rights calls on the Legislative Yuan to submit "The Regulation of Comprehensive Renewal of National Identity Cards" to the Committee for specific review in the future, and not ignore the silent submissions for administrative agencies. At the same time, we call for publicly issuing plans and provide citizens with time to review and confirm the necessity of a full reissue. Other necessary legislations or amendment of laws to protect people's rights and interests should also be considered.