Playing the Identity Card:
Surveillance, security and identification in global perspective

Colin J. Bennett* and David Lyon*

London and New York , 2008

ISBN 978-0-415-46564-9


Back cover:

National identity cards are in the news. While paper ID documents have been used in some countries for a longtime, today's rapid growth features high‑tech IDs with built‑in biometrics and RFID chips. Both long‑term trends towards e‑Government and the more recent responses to 9/11 have prompted the quest for more stable identity systems. Commercial pressures mix with security rationales to catalyse ID development, aimed at accuracy, efficiency and speed. New ID systems also depend on computerized national registries. Many questions are raised about new IDs but they are often limited by focusing on the cards themselves or on ‘privacy’.
Playing the Identity Card shows not only the benefits of how the state can ‘see’ citizens better using these instruments but also the challenges this raises for civil liberties and human rights. ID cards are part of a broader trend towards intensified surveillance and as such are understood very differently according to the history and cultures of the countries concerned.
This collection addresses a variety of issues in international and comparative perspective, bringing together articles on existing and proposed identity systems in countries around the globe as well as from the European Union and the International Aviation Authority (ICAO). The articles in the collection explore not only the technical and administrative dimensions but also the historical, international sociological and political economy perspective as well.


Setting the scene

1. Playing the ID card: Understanding the significance of identity card systems

2. Governing by identity

Plus ça change: Colonial legacies

3. The elusive panopticon: The HANIS project and the politics of standards in South Africa

4. China’s second‑generation national identity card. Merging culture, industry and technology

5. Hong Kong’s ‘smart’ ID card: Designed to be out of control         

6. A tale of the colonial age, or the banner of new tyranny? National identification card systems in Japan

7. India’s new ID card: Fuzzy logics, double meanings and ethnic ambiguities

8. Population ID card systems in the Middle East: The case of the UAE

Encountering democratic opposition

9. Separating the sheep from the goats: The United Kingdom’s National Registration programme and social sorting in the pre‑electronic era

10. The United Kingdom identity card scheme: Shifting motivations, static technologies

11. The politics of Australia’s ‘Access Card’

12. The INES biometric card and the politics of national identity assignment in France (full paper here)

13. The United States Real ID Act and the securitization of identity

14. Towards a National ID Card for Canada? External drivers and internal complexities

Transnational regimes

15. ICAO and the biometric RFID passport: History and analysis

16. Another piece of Europe in your pocket: The European Health Insurance Card


Preface and acknowledgements

All modern societies have developed systems to establish that their citizens ‘are who they say they are’. Those systems have evolved over time as new technologies and the demands of a complex, mobile and interconnected world have provided more sophisticated identity management systems. Forms of personal identification might vary from something you own (such as a passport), to something you know (such as a password), to something you do (such as signing a document or speaking in a typical voice pattern), to something you are (the most modem forms of ‘biometric’ identifiers, such as a fingerprint, a retinal scan, a hand geometry and so on). The pocket-sized card remains, however, an enduring symbol of the process of self-identification in our many interactions with different state and private agencies.
Identity cards are not just technologies; they are also contemporary tools of governance which maybe used to address a multiple and shifting set of social and political problems. They may facilitate travel and hence help control illegal immigration. They may provide a more reliable method of establishing the age of the bearer (both for young and old). They may incorporate medical information for use in an emergency (e.g. blood type, allergies, diabetes etc.). They may assist in crime detection. They may improve access to a range of public services (social benefits, health, education, libraries, employment services) and facilitate the preven­tion of fraud and identity theft. More recently, they are seen as tools to assist border management and thus contribute to the ‘War on Tenor’. Advanced card technologies are often seen as solutions that need to be linked to corresponding problems. How that linkage takes place will determine the choices made in different countries and the opposition encountered, raising questions of profound interest to social scientists.
Identity cards vary in terms of their compulsory nature, their contents, their security features, the database support, as well as in terms of the accompanying rules concerning which authorities, under what circumstances, may request their production and access their contents. Most card systems are now designed with sophisticated biometric identifiers. The extraordinary capacity and processing power of advanced card technology now offers a realistic vision that one card cannot only provide more reliable methods of identification and authentication, but can also help the individual engage in a variety of verifiable and anonymous transactions. Cards are now not only forms of identification and transaction; they are also fully integrated ‘smart agents’ of data processing. They are, therefore, instruments of power, which might discriminate, infringe civil liberties and contribute to the spread of surveillance. The fact that the manifestation of this policy instrument is confined to the individual’s pocket does not alter the larger set of relationships that still tend to be politically determined and that raise a complex range of social, eco­nomic, political, legal and technological issues.
This collection addresses these various issues in international and comparative perspective. It brings together papers on existing and proposed identity card systems in 11 different countries (Australia, Britain, Canada, China, France, Hong Kong, India, Japan, South Africa, the United Arab Emirates and the USA), as well as from two international organizations, the European Union and the International Civil Aviation Organization (ICAO). The chapters in this collection explore not only the technical and administrative dimensions but also the historical, international, sociological and political economy aspects. In particular, the book aims to understand how new identification processes contribute to surveillance practices, through the classification of citizens and residents according to varying criteria, thus affecting their life‑chances, status and prospects.
Although some countries have inevitably been omitted, the majority of the world’s population is potentially covered within these chapters. We have deliberately gone outside the realm of the ‘usual suspects’ of North America and Western Europe, also including case studies of identification card systems in Japan, China, India, South Africa and the United Arab Emirates (UAE). We also wanted to look at countries both within and outside the common law tradition, because that distinction has in times past worked as a divider between states with or without such systems. Although we would have liked to have included one or two Latin or Central American countries, or to discuss Malaysia along with Hong Kong, we are confident that this is the most international scholarly treatment of the subject to date.
The authors come from several disciplines: sociology, political science, criminology, communications, law, business and management, and information studies. They were asked to address three questions about the development of identity card systems in their respective countries. What were/are the drivers (both domestic and international)? How is the system designed to work, both administratively and technologically? And what are the lessons? Some chapters emphasize law, others technology, information, politics or policy. Most chapters also give at least a nod – some considerably more – towards the historical background of them system discussed. Some chapters lean towards the factual and descriptive; others are explicit in their commendation or critique. Collectively, the chapters allow us to distinguish the more generic and transnational processes from the more specific cultural and institutional features of individual countries. They permit us to understand the impact of post-9/1 1 security measures in contrast to the historical legacies. They offer an opportunity to understand and compare the opposition and resistance in different countries. They allow a thorough examination of the nature of contemporary surveillance practices.
The collection is based on a research workshop, held under the auspices of the Surveillance Project at Queen’s University, Kingston, Ontario in June 2007. It was funded through the ‘Globalization of Personal Data’ project from the Social Sciences and Humanities Research Council’s Initiative on the New Economy (NE) programme. The editors are extremely grateful to the authors who contributed to this volume for their research and for their diligent and timely submission of drafts. We are also grateful to those who presented papers at the workshop, whose work could not be included, and especially to Charles Raab and Ben Muller. We also appreciate the careful and diligent research assistance from Emily Smith, as well as the Project Manager, Joan Sharpe.

John J. Bennett and David Lyon


Louise Amoore specializes in the geopolitics of risk and security in the Department of Geography, Durham University, UK. She is currently leading two Economic and Social Research Council (ESRC) projects on risk and the technologies of the War on Terror: ‘Contested Borders’ and ‘Data Wars’. She is co-editor (with Marieke deGoede) of Risk and the War on Terror (London: Routledge, 2008), and has published some of her recent work in Security Dialogue, Political Geography, Antipode and Transactions.

Collin J. Bennett is a Professor in the Department of Political Science at the University of Victoria, Canada. His research is focused on the comparative analysis of surveillance technologies and privacy protection policies at the domestic and international levels. He has published three books on the topic: Regulating Privacy: Data Protection and Public Policy in Europe and the United States (Cornell University Press, 1992); Visions of Privacy: Policy Choices for the Digital Age (University of Toronto Press, 1999, with Rebecca Grant); and The Governance of Privacy: Policy Instruments in the Digital Age (Ashgate Press, 2003; with Charles Raab, MIT Press, 2006).

Krista Boa is a PhD candidate at the Faculty of Information Studies, University of Toronto, Canada. Her research focuses on the development of technology‑based identification systems, such as machine-readable travel documents and national ID cards, by examining the ways in which technologies are framed discursively. She is interested in how these discourses influence the design of the system and transform conceptions of identity, anonymity and privacy. Other related areas of interest which inform her research include: surveillance, access to information, and conceptualizations of privacy, particularly legal and theoretical arguments about reasonable expectations of privacy in public.

Keith Breckenridge is an Associate Professor of History and Internet Studies at the University of KwaZulu-Natal, South Africa. His current research is focused on a history of biometric registration in South Africa, and he has recently published in History Workshop and the Journal of Southern African Studies on this subject.

Cheryl L. Brown, an Associate Professor of Political Science, teaches Internet Law and Policy, Cyberspace and Politics, Digital Forensics and Policy, and Politics of China at the University of North Carolina at Charlotte in the USA. She received a National Science Foundation Award to study the formation of networks in cyberspace in the age of electronic government. Brown has conducted extensive research on information and communication technology in the Asia Pacific and published an article on smart card technology for e-govermnent.

Andrew Clement is a Professor in the Faculty of Information Studies at the University of Toronto, Canada where he has coordinated the Information Policy Research Programme since 1995. He is a co-founder of the Identity Privacy and Security Initiative. His recent research has focused on public information policy, Internet use in everyday life, digital identity, information rights, public participation in information/communication infrastructure development and community networking. Clement is the principal investigator of the Digital Identities Construction project, as well as the Office of the Privacy Commissioner funded CAN-IDVisions for Canada’s Identity Policy, research project.

Simon Davies is Founder and Director of the watchdog group Privacy International and is also a Visiting Fellow in the Department of Information Systems of the London School of Economics and Political Science, UK. He works on privacy, data protection, consumer rights, policy analysis and technology assessment, and his expertise is in identity and identity systems. His publications include Privacy and Human Rights 1998: An International Survey of Privacy Laws and Developments (with David Banisar, 1998) and Big Brother: Britain’s Web of Surveillance and the New Technological Order (Pan Books, 1997).

Kelly Gates is an Assistant Professor of Communication at the University of California, San Diego in the USA. She teaches courses on media law and policy, the history of media technologies, and theories of the information society. She has published several articles on biometrics, and is currently writing a book on the politics of facial recognition technology.

Graham Greenleaf is a Professor of Law at the University of New South Wales, and formerly Distinguished Visiting Professor (2001-2002) at the University of Hong Kong. His research interests include privacy law and policy, commons in intellectual property, and flee access to law. He is Asia-Pacific Editor of the bimonthly Privacy Laws & Business International.

Gus Hosein is a Visiting Senior Fellow at the London School of Economics and Political Science. At the LSE, he co-mentored its research into the UK Identity Card Bill. Subsequently, he co-founded the Policy Engagement Network that continues to bring academic research to policy fora. He is a Senior Fellow at Privacy International and Visiting Scholar at the American Civil Liberties Union. For more information, see

Zeinab Karake-Shalhoub is the Director of Research at the Dubai International Financial Center (DIFC), the United Arab Emirates. Before that Zeinab was a Professor of Business in the School of Business and Management (SBM) at the American University in Sharjah, UAE; she also served as the Associate Dean of SBM for five years. She is the author of five books: Technology and Developing Economies (Praeger Publishers, New York, 1990), Information Technology and Managerial Control (Praeger Publishers, New York, 1992), Organizational Downsizing, Discrimination, and Corporate Social Responsibility (Quorum Publishers, New York, 1999), Trust and Loyalty in Electronic Commerce: An Agency Theory Perspective (Quorum, New York, 2002), and The Diffusion of Electronic Commerce in Developing Economies, coauthored with Sheikha Lubna Al Qasimi, UAE Minister of Economy (Edward Elgar, November 2006).

Laurent Laniel is a sociologist of international relations and a Research Fellow at the Institut National des Hautes Etudes de Sécurité (INHES) near Paris, France. His research interests are international trade of illicit drugs, policing, and identification. He was a member of UNESCO’s MOST-Drugs network between 1997 and 2002 and co-author of the MOST-Drugs final report, Drugs, Globalization and Criminalization. He is the author of many papers and translations on the international drug problem and law enforcement. Most of his writings and photographs are available at

David Lyon is the Director of the Surveillance Project and Research Chair in Sociology at Queen’s University, Canada. Professor Lyon has been working on surveillance issues since the 1980s, and has particular research interests in national ID cards, aviation security and surveillance and in promoting the cross-disciplinary and international study of surveillance. His most recent books are the edited collection Theorizing Surveillance: The Panopticon and Beyond (Willan, 2006) and Surveillance Studies: An Overview (Polity, 2007). He is currently preparing Identifying Citizens: Software, Social Sorting and the State for Polity Press (2008).

Willem Maas is Associate Professor and Chair of Political Science at Glendon College, York University, Canada and was previously Assistant Professor of Politics and European Studies at NYU. He has been a Parliamentary Intern and also worked at the Privy Council Office in Ottawa and the European Commission in Brussels. Professor Maas’ teaching and research focus on comparative politics, European integration, citizenship and migration, sovereignty, nationalism, democratic theory and federalism. He is the author of Creating European Citizens (Rowman & Littlefield, 2007) and many chapters and articles.

Taha Mehmood is trained as a media practitioner. His areas of interest include the history of surveillance, work practices of new economy labour, urban studies and film. His chapter stems out of his research with the Information Society Project at SARAI CSDS, Delhi, India. He is currently pursuing his Master’s in City Design at London School of Economics.

Midori Ogasawara worked for Japan’s national newspaper, Asahi Shimbun, from 1994-2004. As a reporter, she covered surveillance issues including national identification card systems, CCTV in public spaces, war compensation between Japan and Asian countries, especially sex slavery on behalf of the Japanese army, and other human rights issues. She is also the author of four books including a children’s picture storybook, Princess Sunflower, which is based on the Convention on the Elimination of All Forms of Discrimination against Women. She has been an MA student in Sociology at Queen’s University in Canada since 2005.

Pierre Piazza is a lecturer in political science at Cergy-Pontoise University near Paris, France. He is a specialist of the social history of state identification systems and techniques and has published several papers on the Bertillon system (anthropometry), finger printing (dactyloscopy), identity cards and biometrics. Piazza is author or editor of Histoire de la carte nationale d’identité (A History of the French National ID Card) (Paris, Odile Jacob, March 2004), ‘Police et identification. Enjeux, pratiques, techniques’ (‘Policing and Identification: Issues, Practices and Techniques’), and Du papier à la biométrie. Identifier les individus (From Paper to Biometrics: Identifying Individuals) (Paris, Presses de science Po, June 2006).

Jeffrey M. Stanton (PhD, University of Connecticut, 1997) is Associate Dean for Research and Doctoral Programs in the School of Information Studies at Syracuse University. Dr Stanton’s research focuses on organizational behavior and technology, with his most recent projects examining how behavior affects information security and privacy in organizations. He is the author with Dr Kathryn Stam of the book The Visible Employee: Using Workplace Monitoring and Surveillance to Protect Information Assets – Without Compromising Employee Privacy or Trust (Information Today, 2006).

Scott Thompson is a PhD candidate in sociology at the University of Victoria and is currently engaged in research concerning surveillance, classification and its consequences during the pre‑electronic period. He has published several papers on surveillance and liquor control in Ontario, Canada and is currently writing a book with Dr Gary Genosko tentatively entitled Punched Drunk: Alcohol, Identity and Surveillance in Ontario 1927-1975 (forthcoming).

David Wills is a final year doctoral student at the University of Nottingham, and will be taking up a Research Fellowship at POLSIS, University of Birmingham, UK. His research interests include political theory, social movements, and the politics of information technology. He has taught political theory at Nottingham and wrote the POSTnote on Computer Crime for the Parliamentary Office of Science and Technology in 2006.

Dean Wilson is a Senior Lecturer in Criminology in the School of Political and Social Inquiry, Monash University, Melbourne, Australia. His research interests include the impact of biometrics on border control, police interactions with victims of crime, and the role of surveillance in the structuring of security. He has published widely on policing, CCTV in Australian public spaces and biometrics. He is the Oceania editor for the online journal Surveillance & Society and the editor (with Clive Norris) of Surveillance, Crime and Social Control (2006).