PRINCETON JUNCTION, NJ–The U.S. Department of Homeland Security (DHS) and several states including Arizona, Vermont and Washington, have recently announced programs to develop and issue enhanced state driver’s licenses that could be used as acceptable alternative documents for crossing the United States’ land and sea borders. The Smart Card Alliance has serious privacy and security concerns for U.S. citizens participating in these programs based on the direction DHS has been recommending for the enhanced driver’s license technology.

The Smart Card Alliance applauds state efforts to boost security at borders while facilitating trade and tourism; however, the Alliance also believes that ensuring the privacy and security of U.S. citizens is a primary requirement and that the technology choice for an enhanced driver’s license must also address this critical requirement.

The Smart Card Alliance, a not-for-profit, multi-industry association, is in a good position to be objective on the merits of different technologies under consideration for border crossing cards because its members provide both the technology favored by DHS, long-range radio frequency identification (RFID) products, and the more secure and privacy-sensitive products the Alliance recommend for enhanced driver’s license programs, secure RF contactless smart cards. Even as manufacturers of RFID, the Alliance attests to the fact that long-range RFID, the most likely technology to be selected by DHS, is an inappropriate technology for human identity documents.

Within the WHTI specification and in the Washington and Arizona enhanced driver’s license projects, DHS has proposed a long-range vicinity-read RFID technology solution. This proposal raised serious privacy, security, and operational functionality issues among industry experts in responses to the Department of State’s Federal Register Notice for the WHTI passport card. Industry concerns include:

• The lack of strong cryptographic features in long-range RFID-based cards, making it easy for criminals to read the unprotected, static citizen identifiers from the cards and create fraudulent documents.
• The reliance on real-time access to central databases and networks in order to verify every individual’s identity, leading to vulnerabilities to infrastructure failures and attacks or to network and system security breaches.
• The challenges of reliably reading large numbers of long-range RFID tags at crowded border crossing points, making it unlikely that desired operational efficiencies will be achieved.
• The ability for criminals to use inexpensive long-range RFID readers to detect the citizen’s electronic identity from a distance, putting U.S. citizens carrying the enhanced driver’s license at risk of having their movements tracked.

The full Smart Card Alliance response to the Department of State Federal Register Notice for the WHTI passport card is available at www.smartcardalliance.org.

In addition, recent U.S. Government Accountability Office (GAO) reports have identified both performance and security issues with the DHS implementation of the US-VISIT program, which uses the same long-range RFID technology and architecture that has been proposed for WHTI-compliant documents.

The only broadly deployed, proven technology existing today that meets the objectives of increased border security, citizen privacy and efficient border crossing is contactless smart card technology – the technology that is being used for ePassport.

DHS has repeatedly defended the choice of long-range RFID technology by saying that it will move people through the border points faster. The Smart Card Alliance disagrees with this position. There are inherent wait times in the border crossing process that allow enough time to read a smart card chip in a passport card, enhanced driver’s license or ePassport prior to reaching the document checkpoint. An enhanced driver’s license based on smart card technology can also leverage the infrastructure that is being put in place by DHS and the Department of State to support the new ePassport, which is now being issued to millions of U.S. citizens.

The Smart Card Alliance is committed to advocating technologies that are appropriate for different identity applications. RFID technology was designed for automating the tracking of products and pallets through a supply chain, not for validating human identities. The Alliance urges states that are considering enhanced driver’s licenses programs to challenge the DHS-selected technology and consider contactless smart card technology to achieve a faster, more secure means for citizens to cross our borders from land and sea, while still protecting their security and privacy.

Additional information about the use of RFID and secure contactless smart card technology in identity applications can be found at www.smartcardalliance.org.