The REAL ID Act is one of the largest identity management undertakings in history. It would bring more than 200 million people from a large, diverse, and mobile country within a uniformly defined identity system, jointly operated by state governments. This has never been done before in the USA, and it raises numerous policy, privacy, and data security issues that have had only brief scrutiny, particularly given the scope and scale of the undertaking.
It is critical that specific issues be carefully considered before developing and deploying a uniform identity management system in the 21st century. These include, but are not limited to, the implementation costs, the privacy consequences, the security of stored identity documents and personal information, redress and fairness, "mission creep", and, perhaps most importantly, provisions for national security protections.
The Department of Homeland Security's Notice of Proposed Rulemaking touched on some of these issues, though it did not explore them in the depth necessary for a system of such magnitude and such consequence. Given that these issues have not received adequate consideration, the Committee feels it is important that the following comments do not constitute an endorsement of REAL ID or the regulations as workable or appropriate.
-- The Data Privacy and Integrity Advisory Committee of the Department of Homeland Security