May 22, 2006

Public Interest Comment on the Use Of RFID For Human Identification

Key materials
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The Report

The Department of Homeland Security's Data Privacy and Integrity Advisory Committee-a panel of experts that advices DHS on privacy matters-recently released a report on the use of radio frequency identification (RFID) technology to track humans. RFID systems are a subset of a larger class of technology known as automatic identification (Auto-ID) systems. Other Auto-ID systems include such common technologies as barcodes, magnetic stripe cards, and optical character recognition systems. The purpose of these technologies is to identify and track people, animals, and goods. While a barcode requires line-of-sight scanning, and smart cards require physical contact with a reader, RFID-tagged objects can be identified at a distance because the technology employs radio frequency transmission.

Our Findings

  • RFID technology has been used effectively to manage inventories of goods and to track objects in supply chains and other logistical undertakings. However, the tracking of humans using RFID, especially by government, presents serious privacy questions.
  • While the threats to privacy presented by RFID tracking of consumer goods have been exaggerated, government use of RFID to identify humans does entail serious privacy consequences. As the Committee noted, the privacy concerns created by using RFID to identify humans generally outweigh any benefit that could be gained.
  • The surreptitious monitoring of persons cannot easily be accomplished by tracking RFID tags embedded in consumer goods. If RFID becomes widespread in government identification documents that citizens must carry with them out of convenience or to comply with the law, then the surreptitious RF surveillance of humans does become a real concern.
  • The cost of including RFID technology in government identification documents would be more expensive relative to other comparable Auto-ID technologies, such as magnetic stripes or barcodes. Therefore, any planned adoption of RFID should measure the marginal increases in speed against the relative higher cost of employing RFID technology.