The importance of Doing No Harm: India’s plan to create a new national facial recognition database

This coming Friday, the government of India is planning to announce the winner of a Request For Proposals to create a large, national, centralized facial recognition system for law enforcement purposes. The tender for the project outlines an ambitious program of facial surveillance in India utilizing image databases that law enforcement officers could access in the field via mobile devices. Regrettably, India does not have a data protection law that would put guardrails in place for this system, and the tender did not propose use restrictions or privacy protections.

In another country, the ambitious plan to construct such a widespread centralized recognition system might be seen as overly optimistic. But India is the country that stood up the Aadhaar national biometric ID in five short years, going from zero enrollees in 2010 to more than a billion enrollees by 2016.

I was present in India in 2010 when the government began enrolling people with iris scans and fingerprints into the Aadhaar system. It was an extraordinary effort, and I’ve not witnessed anything like it before or since. So when a tender for a national facial recognition system is open for bidding in India, I take it seriously, understanding that such a system can potentially be implemented very rapidly.

Similar to Aadhaar, the facial recognition system planned for India is one that will need to be watched very closely. And I repeat the Do No Harm call that I have repeatedly made regarding Aadhaar:

It is important that digital biometric identity systems be used by governments with a Do no Harm mandate, and the establishment of regulatory, enforcement and restorative frameworks ensuring data protection and privacy needs to transpire prior to the implementation of technological programs and services.

India’s proposed national facial recognition system needs privacy and data protection frameworks in place prior to installation. And the system must be used with a Do No Harm mandate and charter. Otherwise, in the context of a national facial recognition system with broad capabilities for real-time surveillance, great harm may indeed occur.

-Pam Dixon, Executive Director

Related Documents:

Original publication date: 6 November 2019