PDPC seeks public consultation on the use of NRICs

The Singapore Personal Data Protection Commission (“PDPC”) has released a new [public consultation on Proposed Revision of NRIC Advisory Guidelines. Due date is 18 December 2017, 5pm.

The National Registration Identification Card is perhaps the quintessential personal data in Singapore. The number followed you from birth, and will pass through countless life events (including marriages, divorces, old age and coming of age) before surviving your death. Today, the number is the ID for your SingPass, the gateway to accessing all your interactions with the government. It was and still is the ultimate card to verify who or what you are. Some might even have used their NRIC numbers as their password, because I know I have!

The power is irresistible and hence for a very long time, organisations collected NRIC numbers and copies for their own purposes. In the current advisory, the PDPC advised against “over-collecting personal data, including NRIC numbers, where this is not required for their business or legal purposes”. It included some fairly contentious propositions, such as the example that a condo security guard collecting NRIC numbers for verifying birthday party guests is a reasonable purpose, or that collecting NRIC numbers is a good practice because it avoids collecting other forms of personal data.

The main change being proposed is that NRIC numbers or copies should not be collected except in the following circumstances:

Collection, use or disclosure of the NRIC number or copy of the NRIC is required under the law; or
Collection, use or disclosure of the NRIC number or copy of the NRIC is necessary to accurately establish and verify the identity of the individualy.

It appears that the rules are being tightened. Some of the main activities being targeted appear to be:

Using NRIC numbers as an identifier for convenience
Retaining NRICs for no good purpose

This should be welcomed, given the prevalence of the NRIC and the information it contains. Still, I am going to give this some thought and send in something if I can.