From jd@scn.org Mon Apr 26 12:47:37 1999
Date: Sat, 20 Mar 1999 14:45:15 -0800 (PST)
From: SCN User <jd@scn.org>
To: local-computer-activists@scn.org
Subject: Driver License Alert

Wonder why you haven't heard about the driver license bill yet this year? 
There IS no license bill, only an appropriation buried in the 1999-00
Washington State Transportation Budget.  In one simple budget item, the
Department of Licensing can be granted funds for a digitized license
without special policy hearings or pesky protective changes to state law. 

Although the latest proposed budget language would forbid funding the
placement of fingerprints or Social Security numbers on the driver license
itself (with this money) it leaves other biometrics and machine readable
technologies unrestricted. 

The House Transportation Budget is expected to be moved out of committee
for a vote in the entire House this coming week.  You can leave a message
for your legislators on the Legislative Hotline at 1-800-562-6000. 
 

The message below is essentially what was sent to House Transportation
Committe members on Friday, March 19th: 


Re:  Transportation Budget - PSHB 1125
     Driver License Budget Item - Section 215


Dear Representatives Fisher and Schmidt, 

Thank you for the opportunity to testify briefly on PSHB 1125 at the
public hearing held last week.  Let me further explain our concerns with
proposed section 215, which includes funding for a new state driver
license and identicard. 

Computer Professionals for Social Responsibility is a national group of
computer professionals interested in the impact of technology on society. 
The Seattle Chapter has followed the state driver license debate for the 
last two years. 

We believe the proposed budget allocation does not give enough direction
to the Department of Licensing as to what the form and uses of the new
license should be.  In past years, the Legislature explicitly rejected
certain technologies, including most biometrics, and proposed some
safeguards for the use of digital photos and the Social Security number. 
Others were scheduled for debate on the Senate floor last year.  

We believe the Legislature should be deciding these matters of public
policy, not the Department of Licensing.  Let me share a few examples: 

1. Digital Photos

If the new licensing process includes digital photos, who can access them? 
Under current law,

"The department may make the file available to official governmental
enforcement agencies to assist in the investigation by the agencies of
suspected criminal activity."  RCW 46.20.118

What exactly is a governmental enforcement agency?  Don't most agencies
have some enforcement capability? 

Unlike a traditional negative file, an entire digital photo database can
be released effortlessly to an untold number of local, state and federal
agencies for general enforcement purposes -- effectively giving the
agencies new powers.  At a time when Great Britain is already
automatically crossmatching photo databases with pictures from public
surveillance cameras, this is not necessarily an appealing prospect. 

Leaving the RCW unchanged while adding this powerful technology upsets the
delicate balance between citizens and those who govern. 


2. Computer Chips and Machine Readable Technologies

Depending what technologies are chosen, a driver license or identicard
could contain several pages of information about an individual.  Concerns
have been raised over the last two years about merchants or others reading
and indexing license and identicard information for marketing and other
purposes.  More than a simple budget item is needed. 


3. Other Biometrics

While fingerprinting would be prohibited in the proposed budget item,
other biometrics, including but not limited to iris scans, hand geometry
and facial recognition systems, would not.  If you do not intend the
Department of Licensing to use other biometrics, the RCW needs to say so
clearly. 


4.  Digitized signatures 

Unauthorized release of digitized signatures to someone inside or outside
the system could actually be used to commit financial fraud, rather than
prevent it. 


5.  Derivatives of the Social Security number

The budget item does not address using derivatives of the Social Security
number on the face of the license, or in machine readable form. 
Prohibiting use of the SSN but still allowing the use of a related number
from which it could be reformulated, or making the SSN available
electronically from the Department of Licensing, does not protect the
public. 

In summary, we believe this budget item bypasses the legislative
policy-making process on several key issues and urge you to reject it. 

Sincerely,

Janeane Dubuar
Computer Professionals for Social Responsibility 
Seattle Chapter

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