Submission. Access Card - Enrollment. Inch. Executive Summary.

The Department of Human Services ("DHS") claims that one-to-many biometric face-matching against a really big database is sufficiently accurate to find fraudulent registrations, however this isn't carried out by recently published evaluations of their tech, nor by DHS figures to the mistake speed with modern technologies. Introduction.

This submission was created in response to this DHS Access Card Consumer and Privacy Taskforce's Discussion Paper No. 3: Registration [1].

EFA has previously stated our resistance to the Access Card system in its existing form. Since then more information has emerged about the suggested system (e.g. throughout the current Senate Committee query [2] ). But it continues to look that the suggested system isn't fit for purpose; will create greater inconvenience for the majority of members of the public; is likely to lead in unjustifiable refusal of health and pharmaceutical services and fictitious allegations of identity fraud, also involves a higher risk to be a gigantic IT tragedy and hence waste of over one billion dollars of taxpayer funding. The latter is very likely if it is infact rolled out just 1-2 months from today - handed it's apparent that DHS does not even know yet how many aspects of the device may or may do the job.

With respect to the time, while DHS has said that " An important portion of the security frame is test, testing and testing of their end to end access card platform by the Defence Signals Directorate (DSD) - Australia's national authority for information security and signals intelligence " (DHS submission to Senate Committee), it seems suspicious that such certificate will soon be attainable from the scheduled roll out date of April 2008. AGIMO countries in its its newly released Smartcard Framework- Section 2 - guidance at the project management level in important areas such as privacy, technology and security selection [3] which " EAL4 certificates may require between 9 to 12 weeks to complete under perfect circumstances ", ideal being " In circumstances where the product and design documentation is correct the first time ". Many details of the Access Card system seem more likely to require more than EAL4 level certification. Visit luminessair.com website, to read our recommendations or to obtain assistance.