SIM Reregistration: NIA raises doubt about quality of NCA bio-data collection


The ongoing SIM reregistration exercise is likely to be in limbo after the National Identification Authority (NIA) raised questions about the quality of biometric data being collected by the National Communications Authority (NCA) during the exercise.

This was contained in a letter from the NIA dated September 13, 2021 titled RE: SIM Registration Exercise – Biometric Identity Verification via NCA Android Registration Application.

The letter, signed by the Executive Secretary of the NIA – Prof. Kenneth Agyemang Attafuah, was in response to another letter dated September 3, 2021, seeking to confirm whether the NCA’s biometric data for the SIM card reregistration was of a format and sufficiently high quality for successful verification against the National Identification System.

Responding to the enquiry, the NIA explained that the design and development of the process by which the NCA – acting by itself or through a third party – will collect and store biometric data of SIM cardholders is exclusive to the NCA, and that the NIA did not have any input in development of the Android Registration Application.

“For this reason, NIA is unable to confirm that the biometric data to be collected by the NCA for the purpose described above will meet the standard that enables successful verification against the National Identification System (NIS) database,” Professor Attafuah explained.

National Identity Register Regulations 2012

Under Regulation 7 of National Identity Register Regulations, 2012 (L.1. 2111), the NIA is required to verify the identity of all persons who seek to partake in transactions which require verification of identity.

To this end, NIA entered into a Public Private Partnership Agreement with Messrs. Identity Management Systems II Limited (IMS II), its technical partner, to develop and manage a state-of-the-art Biometric Verification System Platform that guarantees the highest security and meets the highest international standards for use by all user agencies to confirm the identity of their clients during transactions which require proof of identity.

The said verification platform has been duly developed by IMS II in collaboration with NIA and is running efficiently.

Again, by Regulation 9 of L.1.2111, NIA may by “notice published in the Gazette specify the types of instruments approved by the Authority as portable identity card readers …”

As a result, the NIA said it “cannot endorse or guarantee the quality of biometrics to be captured by NCA (during the SIM card registration exercise) with devices NIA has not duly certified”.

Sole prerogative of NIA

The ongoing SIM reregistration started in October 2021 and is expected to last for six months –giving enough space and time for SIM card owners to get their Ghana Cards to facilitate the re-registration process. The exercise has however been met with undue delays and long queues at SIM registration centres across the country, because the NCA mandated telecom operators to collect another set of biometric data using an android app.

According to the NIA, verifying the identity of SIM cardholders against the National Identity Register (NIR) is the sole prerogative of NIA and cannot be performed by a third party for and on behalf of NIA.

Although by plan NIA said it was aware that it will play a role in the SIM card registration process, the exact details of the role and its associated cost have not yet been agreed on and concluded between NCA and NIA. Rather, NIA has informed the telecommunication companies that the fee for verification per SIM card is GH¢40.50.

Options for verification

The NIA has provided the telecommunications companies with four (4) options for verification of identity against the National Identity System database as follows:

  1. USSD and thereafter bulk verification of PINs and numbers provided by the SIM cardholders during the SIM registration exercise
  2. Online verification of biometrics – The online verification process makes use of a desktop application that verifies an individual’s identity within the NIS
  • Offline biometric verification by use of an NIA-approved device – To guarantee the results after verification and in line with the Fees and Charges Instrument 2019, devices for reading the Ghana Card must be duly licenced and certified by NIA through a documented process. The devices to be used by NCA for any offline verification services will have to be tested and certified by NIA and IMS II to confirm their technical suitability and ability to read Ghana Cards. This is essential to NIA’s statutory obligation to preserve the accuracy, integrity and reliability of the NIS database and the Ghana Card. IMS II has also ordered 100,000 of these prescribed devices, some of which are currently being used successfully by other user agencies for verification services.
  1. Mobile Application – This is an Android Selfie App that will perform the SIM registration and verification of SIM cardholders’ identity in one step and return to the telecommunication companies and NCA in one step a verification code and agreed dataset from NIA that is guaranteed by NIA to be accurate and reliable.

However, “The use of an App that is not developed or certified by NIA to read the Ghana Card using a two-step data collection and verification process is outside NIA’s control. NIA is therefore unable to guarantee the results of such a process. There will be chaos in the ID ecosystem if any entity can develop its own application to read the Ghana Card and declare the resultant verification feedback as an official one for and on behalf of NIA. It must rather be emphasised that NIA cannot defend disputes and lawsuits emanating from such reading and verification processes,” the authority stated.

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