UK: Privacy questions must be addressed before NHSX contact-tracing app roll-out

Amnesty letter to Matt Hancock ahead of nationwide roll-out

UK Government ‘must answer important questions about its approach at this crucial moment’ - Kate Allen

Amnesty International has written to the Health Secretary Matt Hancock setting out key principles to inform the UK Government’s decision about any proposed nationwide roll-out of the current choice of COVID-19 contact-tracing app.

Since 5 May, the NHSX app has been offered to people in the Isle of Wight but this experiment has led to widespread ethical and practical questions about the chosen system.

Amnesty is warning that there are still key issues that need to be addressed head-on if this is the contact tracing app the UK Government wishes to roll out across England by the end of May.

Kate Allen, Amnesty International UK Director, said:

“We all want to do everything we can to beat this virus, but as we’ve said before, our privacy must not become another casualty of the crisis – a Government decision making approach to this app that incorporates key human rights principles can ensure that does not happen.

“We are certainly not trying to discourage people from using the app, but rather encouraging the UK Government to answer important questions about its approach at this crucial moment.

“Very important concerns around the current choice to adopt a centralised model, and issues like accessibility and transparency, still remain unanswered.

“As the UK Government prepares to roll the app out across England, it is critical that these are addressed so that people can properly understand what is being proposed and why. ”

Amnesty has highlighted seven key principles that should guide the government’s decisions before a full roll-out of any contact tracing app.

1. Consent and transparency

Any individual decision to download and use it must be entirely voluntary and the full source code underlying the app should be available for scrutiny.

2. Limited purpose

All data collection must be restricted to controlling the spread of COVID-19 and it should not be used for any other purpose - including law-enforcement, national security or immigration control. It must also not be made available to any third party or for commercial use.

3. Anonymity

There must be transparent scientific proof that it is impossible for collected data to be de-anonymised, including through combination with other data sets.

4. Privacy and data protection by design

The app must be in line with GDPR and the UK’s data protection laws, with privacy at the forefront. Data collected must be the minimum possible, and securely stored.

5. Independent expert oversight

The app and collection and use of data must be independently overseen by a regulator empowered to enforce its decisions..

6. Time limits

The data and app must be subject to mandatory time-bound deletion and/or deleted as soon as practicable after serving their declared purpose.

7. Equality and non-discrimination

The collection and use of data through the app must not impact disproportionately on any individual as a result of their particular status, such as socioeconomic or immigration position, age or ethnic origins. Moreover, its benefits should be equally accessible to all, accounting for differentiated access to smartphones and similar.

Amnesty is urging the UK Government to set out as a matter of urgency how the current contact-tracing app meets these principles.

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