SIM registration system is ill-designed


What is the purpose of digitisation? What is the purpose of digitalisation? What is the purpose of capturing user-biometrics? What is the purpose of SIM registration? There can be so many textbook answers to these questions, but the simple and ultimate goal is for Consumer protection and convenience as well as for Organisational efficiency and seamless service delivery.

We have been asked to register our SIM cards, and the touted reason is for our protection against fraudulent activities – which is laudable. The registration process, however, has not been without issues; because the system design is flawed and seems not to have been developed from the user- or consumer-experience perspective. Technology is an enabler, but if not well-designed can be a burden and costly without achieving the needed benefits to both Consumer and Organisation. It will bring more inconvenience to the Consumer and waste resources of the Organisation. This is what I see in the SIM registration system that has been developed.

I intend to share three registration experiences for this conversation on why the SIM registration system is ill-designed.

  • Experience 1

I am an existing customer of Vodafone with a registered SIM card. This means, my name, date of birth and digital address have already been captured. My biometrics, facials, iris, fingerprints were all captured during the registration of my first SIM card. Also, my Ghana card details have been captured. Vodafone, therefore, to the best of my knowledge has both my biodata and digital data.

I visited a Vodafone office and I told the salesperson I have an existing registered SIM card and want to buy a new one. I was asked to produce my Ghana card, which I obliged. I was then given back the SIM card after payment and asked to go join a long queue to get my biometric details captured to register the SIM card. I told the salesperson that I am an existing customer and already have a registered SIM card; but the response was that I still had to join the queue to get my biometrics recaptured. Honestly, I went berserk – but they told me that is the process, One SIM card, one biometric…and has nothing to do with them. I needed the SIM card so I went through the process once again.

  • Experience 2

A friend of mine lost their wallet which contained their phone and Ghana cards, and so went to a Vodafone office to get a replacement SIM card with the same number. The number already has his biodata, biometrics, Ghana card details linked to it. He was told his biometrics will be recaptured together with the Ghana card details again. He found it strange, but because he needed the SIM card he was obliged to go through the process. They then asked for his Ghana card, which he said was lost but he had the number and it could be used to retrieve his existing captured details, including his picture, to be able to identify him. They said without the actual physical card they could not do the replacement.

  • Experience 3

A friend of mine, an AirtelTigo customer, wanted to buy a second SIM card so went to an AirtelTigo office. She had to go through the whole process of biometric capture again, with the reason being that the details on her existing SIM card are not transferable. Same as my experience with Vodafone.

These are the experiences that will keep anyone with IT knowledge wondering about the quality of system being used, and what went into its design. It beggars belief that one has to go through such experiences in this present digital world.

Designing IT Systems

In designing any IT system there is need to use a Human Centred Design Approach, to view the outcome from the consumers’ perspective. Two technical system designers – User Experience Designer (UX) and Interface Designer (UI) – then come together. First is the User Experience Designer (UX), who understands requirements of the system from the consumers’ point of view and understands the information architecture, user-requirements and expectations. The UX design is based on user-researched needs and what the system is supposed to do; how the consumer is supposed to interact with the system; the convenience and reliability for consumers.

Second is the Interface Designer (UI), who understands the requirements of the system from the technical perspective and is usually the graphics designer and software developer – who designs the system based on user-needs, requirements and friendliness. Ultimately, the UX Designer – the information architect – must test that the final system developed by the UI Designer, the technical architect, meets the desired outcome.

Both the Business UX Designers and Technology UI Designers must work together through the Systems Development Life Cycle (SDLC) from the Planning Stage of requirement gathering, System Analysis and Design, Coding, Implementation and Testing, Deployment and Maintenance.

Most often, in designing IT systems we leave the whole system-design to the UI Designer, the software developer – saying that we want, for example, a biometric SIM registration system or an election collation system. We do not detail exactly the system’s functions and what we want it to be doing from a customer experience standpoint – a business decision that is for the UX Designer, the operations person, and not a technology decision for the UI Designer.

The Current SIM Registration System Design

From my experience and the other experiences above, it seems the of SIM registration system’s developer had no idea of the intended purpose; and if they had, then the system has been poorly-designed. The developer as a User Interface Designer(UI) and the National Communication Authority(NCA) – as the User Experience Designer (UX) – have failed to design a system that brings efficiency in the SIM registration process to the telecommunication companies (Telcos), and convenience of registration to consumers for all stakeholders to experience the purpose and advantages of digitisation and digitalisation. It is also surprising that the ministry responsible for communication and digitalisation approved such a system when both the Telcos and NCA are under their supervision.

I will now use the three quoted experiences to show the flawed design of the current registration system that is in place.

  • Registering a second SIM card

To register another SIM with your existing telco when you already have an existing registered SIM card, your biometrics are recaptured again with the Ghana card. The telcos are not able to just link the new SIM card to your existing identity. Every new SIM card purchased will require a new biometric capture. One SIM card, one biometric capture.

This system as it is operating now is inefficiently designed and is not helpful to the telcos, NCA and citizens. For the telcos, queuing is becoming a nuisance and affecting their non-registration service-delivery. NCA, if they are the data controllers, will need more hardware resources to accommodate these multiple data captures since we are being told each person is limited to having ten (10) SIM cards on all networks. I wonder how this can be detected when the system does not seem to be centralised but individually distributed. Finally, for the citizens, recapturing the registered user’s biometrics again is an unnecessary waste of resources and works against the benefits of digitalisation.

There will also be data redundancy. Should I want to update my digital address, for example, do I have to change it for each SIM card number separately? What if I change it for one SIM card but forget to do so for my other number with the same telco? What if I give a different digital address when registering my second SIM card? Any analysis of SIM card-holders for decision-making by geographical area would have me living in two places.

  • Replacing lost SIM and Ghana cards

To replace a lost SIM card with your telco when your lost SIM card was already registered, your biometrics are recaptured again with your Ghana card. The telcos are not able to just retrieve the existing registered data upon identification to give a new SIM card with the existing number and link it to the already-captured biometrics. Every replacement SIM card with the same number in your name will require a new biometric capture.

If you lose your Ghana card that was used to register a SIM card and you lose your SIM card, to get a replacement SIM card you will have to wait till you get a new Ghana card from the National Identification Authority. This simply beggars belief!!! Can you imagine if you have mobile money on the number? This defeats the very purpose and advantages of moving from a manual system to a digitised environment where record-retrieval is supposed to be in real-time.

The telcos should be able to retrieve your data by using a Ghana card number without the physical card, since they also captured your facials and you are physically standing in front of them to be identified.

Best-case Design

The ideal design for this whole SIM card registration once the Ghana card was designated the only card to be used, was for the telcos to after taking our biodata link the number to the card in their system – with no need of capturing our biometrics.

The Ghana card already has our biometrics captured, so should there be any fraudulent activity by a user, all the telco has to do is under a court order or a legal procedure disclose to any relevant law enforcement agency the Ghana card to which the number is linked. It is now up to the law enforcement agency to do its investigations with the National Identification Authority (NIA) for whatever information it needs. The telcos per se do not need our biometrics to deliver their telecommunication services, and the capture is against the data protection law and principles as well as unnecessary.

Worst-case Design

Since the telcos are being made to capture our biometrics despite already capturing details from our Ghana cards, the worst-case design is to allow existing registered SIM card holders to buy additional SIMs or replace lost SIMs buy linking them to already captured data of consumers.

Does it make sense if you are a customer of a bank with a current account and you want to open a savings account the bank asks you to bring new passport pictures and say they need to capture your details again?

Way Forward

Of course the current system is able to capture our biometrics and link them to a SIM card. The registration system, however, has to be redesigned as a centralised, online real-time system that will allow the telcos to link multiple SIM cards to the same captured data of consumers. In fact, the telco should be able to use one centralised database with our biometrics captured just once; with all them being able to link their SIM cards to our names. This would even make it easy to monitor the maximum of ten (10) SIM cards per person across all networks.


Digitalisation, with respect to public service delivery, is supposed to benefit the citizenry by way of a seamless e-government business and Citizen-to-Government (C2G) interaction, as well as enhancing productivity. This poorly-designed SIM registration system for registering a second SIM card or replacing a lost card is stressful, inconvenient, time-wasting and unproductive.

Data already captured for a particular person should be transferable to any additional SIM being registered by that person. If this cannot be done, then it means the telcos are not hosting the database in-house and the database is also not centralised – not online to be accessed in real-time, and one wonders who is hosting and storing the biometrics.

We might be investing in this digitisation and digitalisation agenda, but we will not reap the intended benefits if we have poorly-designed systems – as we are experiencing with this SIM registration. I hope such ill-designed systems are not cutting across other sectors of the economy.

The author holds an EMBA (IT Management) an LLB and LLM (IT & Telecommunication) (visit:; contact: [email protected])

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