AmCham EU position letter on Biometrics (link)

Brussels, 20 Apr 2006

Dear,

Ensuring the development of more secure travel documents has been an integral part of preventing illegal immigration and combating serious organised crime on the one hand, while greatly facilitating legitimate travel on the other. Following the 9-11 terrorist attacks, the US government emphasised the need for `biometric identifiers' as the essential component of travel documentation, specifically for those participating in the Visa Waiver Programme. To this end, the AmCham EU supports the EU's exploration of options on how to effectively implement proposals for `biometric identifier' passports for EU citizens, and the use of biometrics for a new EU-wide Visa Information System.

The members of the American Chamber of Commerce to the European Union (AmCham EU), as producers and users of this technology, have a keen interest in contributing to this debate. For this reason, we would like to draw to your attention below to key areas of discussion concerning security solutions, technology issues, R&D and privacy concerns.

• Security solutions need to be considered in a global context

  Counterterrorism, border security, identity theft, and trafficking are global threats that require a common approach involving stakeholders on both sides of the Atlantic. For this reason, citizens, in both in the EU and the US as well as elsewhere in the world, need to be protected by the best devices, systems and solutions possible regardless of the supplier's origin.

  Although the introduction of biometric identifiers into such travel documents as passports is at an early stage, AmCham EU supports the EU's goal of achieving a harmonised approach across its Member States and the wider Europe. One of the challenges of implementing interoperable biometric standards (global interoperability) is to overcome the current lack of universal requirements.

  Work concerning the development and specification of Globally Interoperable Biometric Standards as proposed by the International Civil Aviation Organisation (ICAO) recommendations provide a good basis and guideline for the EU to follow. As stated by ICAO, "In implementing biometrics standards for MRTDs1, key considerations are: Global Interoperability Uniformity, Technical Reliability, Practicality, and Durability"2. Discussions on biometrics should address these factors.

• Biometric solutions should be technology neutral

  Biometric technology adoption should be market based. AmCham EU suggests that European Commission and Member States make decisions based on best value for money and should remain open to innovative solutions regardless of origin and/or technology. Specific, effective technologies should not be penalised by being shut out of the marketplace. In fact, as recommended by ICAO, multimodal biometrics should be encouraged, as currently is the case for EU border controls.

• R&D should be encouraged for biometrics.

  R & D funding should be directed at encouraging the further take up of biometrics by highlighting best practices and successful examples. As companies of US parentage committed to Europe with substantial investment and operations in Europe, AmCham EU wants to see a Europe that will create a more conducive business environment for innovation across the EU and provide more funding for R&D. Therefore, we urge the EU authorities to allocate an adequate level of funding to security projects within the upcoming R&D Framework Programme 7.

  The current political climate at both national and EU levels highlights the need to explore possibilities to enhance industrial competitiveness and improve the cost-efficiency of technological cooperation in the field. Future research both at EU and national levels should focus on:

  • Improving research and technological development to overcome the lack of interoperability and encourage widely accepted systems;
  • Encouraging multimodal biometrics systems that combine facial and fingerprint recognition as they are likely to be introduced for identity management purposes such as EU border control for certain categories of persons and
  • Promoting empirical data gathering in real­time, large scale implementation.

AmCham EU is keen to contribute to this discussion on biometrics in the EU. If we can assist in providing any more information or clarification also of technical nature, we will be pleased to do so.

Yours sincerely,
Claudio Murri
Chair
American Chamber of Commerce to the European Union (AmCham EU)

American Chamber of Commerce in the EU
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