New America

Report Part Title: Key Differences Between the U.S. Social Security System and India’s
Aadhaar System
Report Part Author(s): Kaliya Young
Report Title: The Promise of Public Interest Technology:
Report Subtitle: In India and the United States
Report Author(s): Richard Abisla, Subhodeep Jash, Aditya K. Kaushik, Sylvia Mishra,
Ananth Padmanabhan, Pranesh Prakash, Tanvi Ratna, Joshua Simons, Madhulika
Srikumar and Kaliya Young
New America (2019)

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 Key Differences Between the U.S. Social Security
System and India’s Aadhaar System (Kaliya Young)
Kaliya Young also known as "Identity Woman" is the author of A Comprehensive
Guide to Self-Sovereign Identity and the Domains of Identity. She holds a Master
of Science in Identity Management and Security from the University of Texas at
Austin. She currently serves on the faculty of Merritt College in Oakland California.

Acknowledgments: The author would like to thank all the people she spoke with in
India about Aadhaar. This paper would not have been possible without the support of
New America and the guidance provided by Awista Ayub and Melissa Salyk-Virk. The
author would also like to thank the 2019 India-U.S. Fellows.

Introduction

As the world’s largest democracies, with 1.3 billion and 326 million people
respectively, India and the United States both need to support the abstract
representation of individuals and entities and support their transactions with
each other confidently in the digital world.

In a 2013 lecture, Nandan Nilekani, founding chairman of Unique Identification

Authority of India (UIDAI) stated, "the same thing happened in the 1930s in the
United States when Roosevelt passed the Social Security Act as part of the New
514
Deal.” Because the United States is often admired as a large functioning
democracy, the fact that it uses a national ID number means that there is an
assumption that the U.S. system must be a good model.

The United States began issuing Social Security numbers (SSN) to a small
515
segment of citizens in 1935. The system has evolved over the past 85 years and
now numbers are issued to children at birth. Today, Social Security numbers are
used by employers to verify employment eligibility and by the government to
track the collection of taxes, social benefit contributions by people, and to
support them receiving benefits. Most residents also have a state level driver’s
license or ID card that an SSN is required in the application process. This type of
516
ID has a photo biometric and is held by 87 percent of adults.

Over the past 10 years, India has rolled out an identity system based on the
collection of biometrics and simple demographic information from all of its
residents. The system is called Aadhaar, meaning foundation in Hindi. To date,
Aadhaar claims to have enrolled 1.3 billion residents.

Both Aadhaar numbers and SSN are unique numbers issued to residents by their
federal government. A card with the number on it is mailed to the resident. To

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 this extent, the numbers are comparable. There are differences in the registration
and enrollment processes, but this is not really where the major differences lie.

The important differences center on how numbers serve as part of an overall

identity system in both the public and private sector. This paper walks through
the specifics of these differences comparing the U.S. and Indian systems
throughout.

The first section provides context for each ID and considers the historical and
contemporary risks of identity systems.

The second section considers the role of the number itself, and, further, explains
how the creators of Aadhaar position the number within a sprawling system that
continues to add new features, particularly in contrast with the limited role of the
SSN within the U.S. context.

The third section looks at the very different legal and regulatory frameworks that
inform the operation of the agencies responsible for both Aadhaar and Social
Security, along with contrasts in the visibility of operations through the court
systems where challenges occur.

The fourth section outlines how the national-level UIDAI worked with state-level
governments and consultants in India to create vast databases of information
about residents at the local level. These state-level databases are called State
Resident Data Hubs. In the United States, there are no large scale databases of
this type. This section walks through the range of regulations that have been put
in place since the 1960s to guard against the creation of such databases in the
United States.

Finally, the paper concludes with a discussion in sections five and six about how
the use of the SSN has become limited to employee enrollment and financial
services in contrast to the ever-expanding use of Aadhaar in the private sector
and employment context.

Risks of Identity Technologies

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Identity systems, one of the original public interest technologies, arose with
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the creation of contemporary nation-states. The first identity documents were
simply receipts that proved that an individual had been surveyed in a census or
that they were registered by a local authority in return for a government service
in response to a live event (e.g., birth, marriage, and/or death). As a result, these
documents or statuses shaped a citizen’s perception of identity as a member of a
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common public or state.

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 Identity technologies have tremendous power. They can enable the constructive
engagement of citizens with their government, but can be used by the state in
ways that cause great harm.

Democracies benefit from diverse input into the design of identity systems and a
broad consensus about their operation, transparency, and accountability to the
citizens whose information is managed by these systems.

Existing mental models of how identity and identification systems work are
based on government registries for births, deaths, and marriages where events
are recorded on paper in a ledger book and certificates issued. Identifier oriented
systems like the SSN originated at a time when paper-based punch cards were the
latest technology. There were limits to how far and wide a number could circulate
when paper technologies like punch cards, index cards, and the physical mail
system were the only means of circulation.

Even when identity technology is limited to paper, its abuse could lead to horrific
results. IBM’s punch card technology was instrumental in facilitating the Nazi
520
genocide of Jews in Europe via the census records in various countries. Several
Indian subjects interviewed for this research paper pointed out that there have
been a number of significant events of communal and caste violence in India:

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• Keezhvenmani (Tamil Nadu, 1968)

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• Gujarat (1969)

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• Nellie (Assam, 1983)

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• The Anti-Sikh Riots (1984)

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• Hashimpura (Uttar Pradesh, 1987)

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• Lakshmanpur Bathe (Bihar, 1997)

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• Gujarat (2002)

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• Khairlanji (Maharashtra, 2006)

Some of these incidents were facilitated by datasets from Voter IDs and Ration
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Cards, and some had implicit state involvement. Beyond these large incidents
involving thousands of deaths at one time, there are also tens of thousands of
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reports of more isolated incidents of violence every year against Dalits.

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 In the third millennium, computers became ubiquitous and we, i.e., society writ-
large, must consider how identification-based systems translate into a new digital
medium. There are new opportunities and risks created by the design and
implementation of identity technologies and the systems they are connected to.
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Techno-Utopianism, the predominant stance of UIDAI, iSPRIT and India Stack
532
proponents, does not address some of the real security risks. In India, security
researchers and reporters who have brought to light the flaws, vulnerabilities,
and leaks of the Aadhaar number system have been prosecuted by the UIDAI as
533
criminals. This has led to groups of concerned critics collaborating and
publishing under pseudonyms to ensure the public knows about the issues and
534
vulnerabilities while limiting their own risk.

What is the Role of The Number

Both the U.S. Social Security Number and Aadhaar Number are core to how the
respective systems work but the way the number is seen and how the designers of
the programs orient around it is quite different.

In India, there has been a proliferation of digital services linked to and

surrounding the Aadhaar number. Some examples include:

• Aadhaar-enabled payment services for bank transfers using only the

Aadhaar number;

• Aadhaar payment bridge for government-to-citizen transfers;

• Offline authentication with QR code;

• Mobile Aadhaar application including lock and unlock service;

• Aadhaar authentication history logs;

• VirtualID creation;

• Mobile OTP for authentication;

• eKYC (electronic Know Your Customer);

• DigiLocker, a service for people to download all the documents they have
been issued by different government departments; and

• eSignatures and document signed locker.

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 However, security researchers I spoke with highlighted major flaws in the design
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of many of these services. There has also been a stream of reporting about
specific security vulnerabilities that have been uncovered, like API’s to the core
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demographic database that was reported to be completely open.
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The creators of Aadhaar and the India Stack led by iSPIRT, a trade association
of software makers focused on the Indian market, see the Aadhaar number as the
center of a bottleneck in an ecosystem. The Aadhar system is built under the
assumption that national identity numbers are the equivalent of IP addresses in a
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digital network. This assumption creates significant correlation risks and the
potential to amass vast datasets that can be used for commercial and government
surveillance.

In the United States, public concern about the possible use of the SSN for
government surveillance has limited the use of the number and led to regulations
about its use in both the public and private sector.

On the other hand, in the India stack model, not only does the Indian
government provide an identity card to citizens, acknowledging them and giving
539
them a “proof ” to share, but it also provides authentication services. Indians
can use their UID to log in to services and then either use a biometric or get a
one-time password (OTP) sent to their phone which they then enter to complete
remote authentication. This means that the UIDAI has a record of all of the
places where a person authenticates their identity, and this information is kept in
Aadhaar’s logs for six months.

It is very difficult to imagine a proposal by private sector companies or

government leaders in the United States that would require individuals to “log

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 540
in” with their SSN. U.S. government agencies, both as a matter of policy and
law, are reducing or ending their reliance on the SSN as the canonical identifier of
people. There is no way an SSN can be used for authentication against a factor of
authentication (password, OTP, biometric) held by the Social Security
Administration.

There is ongoing work in the United States to develop ways for individuals to
prove they are a particular person by leveraging government-issued identity
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documents in digital form. An important feature of some of these systems is
that they do not rely on a connection to a central government database to prove
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their veracity.

Legal and Regulatory Frameworks

UIDAI and its leadership have a culture of operating just beyond or just within a
legal and regulatory framework. Two books about the story of the creation of
543
Aadhaar have been written by journalists. Both document how the project did
not have a legal or regulatory basis for six years between 2009 and 2016 and
operated with a startup culture. They describe how the UIDAI leaders pushed to
build out Aadhaar despite this legal limbo.

When it was finally made legal with the Aadhaar Act of 2016, the UIDAI was also
left as its own regulator with enormous freedom to expand aspects of the system
and build new “features” without any need to consult the public. UIDAI did not
do privacy impact or security assessments that would bring transparency to how
the system would work or change in the future and what the implications would
be. In my interviews with UIDAI leaders, they described the next new features
that were going to be appearing within the India Stack framework while at the
same time saying that the UIDAI had no responsibility for how people were asked
for their identity information or how that information was used by those
requesting it.

Unlike UIDAI, when the U.S. government changes any technology at the core of
its operations, it moves with a deliberate and careful approach bound by the legal
and regulatory framework of the government, particularly when working with
the sensitive personal information of its residents. For decades, there have been
extensive on-the-record hearings by various legislative committees and
presidential commissions addressing government systems for registering citizens
and collecting and using data about them. Hearings of this type are, by default,
not public in the Indian parliamentary system.

Another contrast between the two systems is a key mechanism for public
accountability. Challenges to U.S. government procedures happen in the courts,
where proceedings produce court transcripts. The 38 days of hearings about
Aadhaar before the Indian Supreme Court produced no transcripts: the best we

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 544 545
have are some summaries and aggregations of live tweeting done by
observers in the courtroom.

In contrast to the U.S. Social Security Administration, the UIDAI is its own
regulator. This is in part because, in India, most legislation is written in a way that
delegates significant regulatory power to the government while the law
concentrates on legal and policy issues. In the case of the Aadhaar Act,
substantial regulatory power was given not to the government but to UIDAI itself,
546
meaning it is not actually accountable to any other organization. And the
UIDAI is exempted from Right to Information [RTI] requests and it sets the
547
grievance mechanisms for itself. The UIDAI is responsible for regulating the
ecosystem around it. Many have questioned the revolving door that is seemingly
connecting the UIDAI and private industry and question whether this limits the
548
ability of UIDAI to regulate its own ecosystem.

From Enrollment to Mass Databases

Governments register people into systems through enrollment. In the United

States, enrollment systems are run entirely by government officials who are
accountable to government agencies within which corruption is very rare. There
is coordination between the local county and state levels that have the authority
to register births and the federal Social Security Administration through a system
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called enumeration at birth (EAB).

Enrolling people in more than one program or system at once is multi-context

enrollment. In the United States, legislation at the federal level, colloquially
550
known as the Motor Voter Act and officially as National Voter Registration Act
of 1993 mandates that states provide the opportunity for people who are signing
up or renewing a driver’s license to also have the opportunity to register to vote in
elections. Individuals getting a driver’s license must proactively choose to be
enrolled in this second and very different system. A special process pushes data
from the driver's license registration process over to the government agency that
manages the state-level voter list.

In India, multi-context enrollment takes place with state-level registrars. States

are incentivized to enroll their people because they get to collect more
information than the basic four fields (name, birthdate, gender, and address)
required by the UIDAI “Know Your Resident” rules. Different states have added
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additional fields, such as marital status, house status , occupation, and VoterID
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number. This data was intended to be reserved for the state and is known as
“Know Your Resident Plus” [KYR+] data.

Indian residents, when they go through the process of getting their Aadhaar
number for the first time, are enrolled in the UIDAI Central Identity Repository
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and the State Resident Data Hub.

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 Figure 3: Flow of Data from Enrollment into the CIDR and SRDH by Anand
Venkatanarayanan [Link]
database-17a0f91e6a33

UIDAI created the software and required that states use this software if they
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wanted to get UID information and additional KYR information.

Several years into enrollment, problems surfaced. Some residents were bypassing
State enrollment agents by enrolling through banks and other registrars, and
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states did not have access to that data. In response, the UIDAI made a deal with
states to share the UID and demographic data from residents of their states that
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enrolled with other registrars.

It is claimed that this activity stopped with the passage of the Aadhaar Act in 2016
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and that all the State Resident Data Hubs were destroyed. However, there is
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evidence that these Hubs are still operating. Even if the data is no longer sent
directly from the UIDAI to SRDH, each of the states has agreements to access the
KYC API of the UIDAI CIDR, so when they interact with residents they can pull
the data from the UIDAI into their state-level databases (see Figure 5).

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 Figure 5: SRDH – State Adoption Strategy Document & State Resident Data Hub
(SRDH) Application Framework Adoption Guidelines by UIDAI

The State Resident Data Hubs use the UID as the anchor to integrate all data
from different state databases together. This happens in two ways. One is a
linking process where residents who are recipients of a particular subsidy,
benefit, or service go to the agency and assert their ID from a given system and
provide their Aadhaar number. They may be asked to authenticate via a thumb
559
print. This process is known as linking, or organic seeding.

Another process, known as inorganic seeding, combines data from SRDH and
UIDs together with existing databases from various subsidies, benefits, or
services. This process occurs without the awareness or consent of residents.
Authorities might check with residents/beneficiaries to see if they made the
correct link or to find beneficiaries who “did not match” any particular Aadhaar
number and ask them what their number was. This human resolution requires
more effort to complete.

The assumption is that only those with matching UID Aadhaar numbers are
“real” beneficiaries. Everyone else is a ghost or fake and can be eliminated.
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Indian naming conventions are very fluid, and the same people use different
561
names in different contexts. This strategy to address who is on different social
services programs is causing disruption to clients who have their benefits cut off
562
because their legitimate claims are not recognized by the system.

The State Resident Data Hubs have applied a computer science data modeling
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idea of “single source of truth” and sought to impose it on Indian society and

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 564
bureaucracy, deciding that whatever is recorded in the UIDAI database is the
single source of truth about an individual.

Rather than creating mass databases and integrating all data about citizens
across all contexts, the U.S. government is actively taking steps to stop or reduce
565
the use of the SSN, even in unlinked discrete databases. Currently, the use of
the number at the federal level is mandated for only a few agencies and services,
such as the Internal Revenue Service (tax authority), Social Security
Administration, passport applications, and for loans by any federal agency. Other
agencies that request the number must inform residents that sharing it is
voluntary, and they will not be denied services if they do not share the number.

This was not always the case. Beginning with an executive order by President
Eisenhower in 1953, there was a phase where using the SSN as a key to interact
566
with various services was encouraged and even mandated.

In 1961 the Internal Revenue Service required the use of SNNs when filing taxes.
Increased digitization of records in the 1960s drove the need for common
reference systems across government agencies and within the private sector, and
they chose the SSN as a way to do this.

In 1965, there was a proposal to create a National Data Center that would pool
statistical information held by the Census Bureau, the Internal Revenue Service,
the Bureau of Labor Statistics, the Social Security Administration, the Federal
567
Reserve Board as well as a dozen other federal agencies. The public reaction to
merging all of these bureaucratic records caught proponents off guard because
they thought that the composite data were necessary for a well-ordered society,
568
and the benefits were self-evident. But the reaction by the public was hostile
and sustained when the proposal was floated in 1967, and again in 1970 when it
was finally rejected. There was widespread press coverage that looked at the
implications for the present and future by creating such databases (see Figure 8).

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 Figure 8: (c) 1967 The Atlantic Media Co., as first published on the cover of The
Atlantic Magazine.

All rights reserved. Distributed by Tribune Content Agency, LLC

Today, India has the type of database the American public rejected in the 1960s
and 1970s. The process was started by the UIDAI and their approved consultants
(among them Accenture, Ernst and Young, KPMG, PwC, Wipro, and Deloitte)
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with the software they developed and supported. This is particularly true in

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 Andhra Pradesh and Telangana, which have recently become separate states.
They did intense surveys of their residents, linking all the data collected to a
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citizen’s Aadhaar number. Andhra Pradesh used The People Hub (see Figure 9)
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to combine 29 different department databases.

Figure 9: Screenshot of Andhra Pradesh online state survey http://

[Link]/PSS2017/[Link] [this link is not live]. It is
from this

How did the United States move from public outcry against a National Data
Center to developing actual laws and regulation that helped citizens accept the
same data being collected by discrete agencies to guard against information
sharing between agencies? While India adopted the use of Aadhaar across
several agencies to deliver services, the U.S. was slower to move in that direction
with the SSN, but did get there eventually.

In this time period the late 1960s and early 1970s there were multiple hearings,
task forces, and committees convened by various agencies of the federal
government and committees in United States Congress. These included The
573
Social Security Number Task Force in 1970. In 1973, the Secretary of Health
Education and Welfare Advisory Committee on Automated Personal Data
Systems issued a report entitled, “Records, Computers and the Rights of
574
Citizens.” The committee developed a code of fair information practices,
inspired by the code of fair labor practices.

Below is the Committee’s original formulation of the Code:

• Safeguards for personal privacy based on our concept of mutuality in

record keeping would require adherence by record-keeping organizations
to certain fundamental principles of fair information practice.

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 • There must be no personal data record-keeping systems whose very
existence is secret.

• There must be a way for an individual to find out what information about
him is in a record and how it is used.

• There must be a way for an individual to prevent information about him

obtained for one purpose from being used or made available for other
purposes without his consent.

• There must be a way for an individual to correct or amend a record of

identifiable information about himself.

• Any organization creating, maintaining, using, or disseminating records

of identifiable personal data must assure the reliability of the data for their
intended use and must take reasonable precautions to prevent misuse of
the data.

These were the starting points of what evolved to be the Fair Information
575 576
Practices and Principles, and later evolved into the Privacy Act of 1974, that
prohibits data sharing between government agencies. It states:

No governmental agency can "deny to any individual any right, benefit,

or privilege provided by law because of such individual's refusal to
disclose his social security account number" except refusal to disclose
after a request pursuant to requirements of federal statutes or pursuant
to pre-existing federal or state statutes or regulations through which a
system of records had already (before January 1, 1975) been set up. (5
U.S.C. § 552a) (note, Section 7 Disclosure of Social Security Number)

Over the next several years, the U.S. government began to move in a direction
that would result in expanded use of the SSN. In 1976, the Tax Reform Act
expanded the use of the SNN outside of Federal Agencies, by authorizing the
577
direct use of the SSN in state and local government programs. In 1977,
Personal Privacy in an Information Society by the Privacy Protection Study
578
Commission was delivered to President Carter. It covered the relationships
among government agencies across a broad range of services and had a special
579
chapter on the SSN. The Debt Collections Act of 1982 required that the SSN be
collected as part of the applications for all federal loans (student, agriculture,
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small business—each administered by different departments) as a standard
practice.

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 It is important to keep in mind that mandating the use of the SSN for privacy
protection meant that each of these departments could not share data about
residents with each other without consent. Many government departments that
encompass workforces and programs like the military or Medicare (healthcare
for the elderly), that relied heavily on the SSN as “the identifier,”made significant
581
changes to their system and stopped using it altogether.

The Driver’s License Protection Act of 1994 places strict limits on who can access
582
the Department of Motor Vehicles’ data, and under what circumstances. The
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e-Government Act of 2002 requires agencies that collect data about citizens to
complete a Privacy Impact Assessment (PIA) for electronic information systems
and to make the results public. The PIA must be conducted before developing or
procuring an ID system that will collect, maintain, or disseminate information in
an identifiable form or about members of the public. They must also conduct this
assessment when merging databases, or when business processes change
significantly by adding new uses or disclosures of information. Here is what the
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PIAs must analyze and describe:

Conducting a PIA.

PIAs must analyze and describe:

1. what information is to be collected (e.g., nature and source);

2. why the information is being collected (e.g., to determine eligibility);

3. intended use of the information (e.g., to verify existing data);

4. with whom the information will be shared (e.g., another agency for a
specified programmatic purpose);

5. what opportunities individuals have to decline to provide information (i.e.,

where providing information is voluntary) or to consent to particular uses
of the information (other than required or authorized uses), and how
individuals can grant consent;

6. how the information will be secured (e.g., administrative and

technological controls7); and

7. whether a system of records is being created under the Privacy Act, 5

U.S.C. 552a.

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 Major information systems. PIAs conducted for these systems should reflect
more extensive analyses of:

1. the consequences of collection and flow of information;

2. the alternatives to collection and handling as designed; and

3. the appropriate measures to mitigate risks identified for each alternative.

Throughout the last two decades, there have been more reports by the federal
585
government about the SSN.

Today, in the United States the use of the SSN is strictly regulated and culturally
limited, while, in India, there is currently no privacy protection bill of any kind
586
that applies to the government or the private sector.

Commercial Sector Enrollment and Use

In the United States, several federal government statutes mandate the use of the
SSN for particular financial service transactions, such as opening a bank account,
587
cashing a check over $3,000 USD, being the beneficial owner of businesses, or
applying for a home loan. Because the SSN card is literally just a paper card with a
name and number on it, agencies also conduct Know Your Customer (KYC)
checks with identity documents that have photographs, such as driver’s licenses,
passports, military IDs, and permanent resident cards. Laws require the
collection of this type of data, but they also mandate the protection of this
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information.

India, like the United States, has a KYC requirement driven by international
589
requirements mandated by the Financial Action Task Force (FATF) that put
these requirements in place after the September 11, 2001 terrorist attacks. The
original design of the UIDAI database would permit residents to do
authentication of their name and address. This process would start with a
resident sharing personal information with a bank. The bank would then send it
to the UIDAI which would send back an affirmative or negative answer to
whether it matched. While this design is commonly used to preserve individual
privacy, it also limits the amount of information that leaves the database.

Indian addresses are much more complex than U.S. addresses: each building has
590
a name or number, within a block, within a district, and then a city. In addition
to this complexity, India has 22 official languages. Its administration uses English,
which most residents do not read or speak. Language barriers make it difficult to
get an accurate answer from the UIDAI database. Lastly, regulated banks require
a copy of an identity document, and many people do not have an appropriate one.

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 In 2014, the UIDAI made a significant design change and created a process
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known as eKYC, where banks and telecommunications companies could ask
people for their Aadhaar number on enrollment, do a biometric authentication
with a fingerprint on a device, and the UIDAI would send the business a digital
document with their name, birth date, Aadhaar number, and physical address.
They could then use this address to populate their database and keep the digital
copy on file.

In the United States, there are very few services offered by any government that
allows private companies to connect with a government database and extract
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private citizen data. The Social Security Administration has set up a system
known as Consent Based SSN Verification (CBSV). Various private companies
have been granted a special license for $5,000 USD to connect to the
government agency to do this type of check (CBSV).

Businesses use one of these agencies to check against the database with the
consent of the person whose information is being checked. They share the name,
SSN, and date of birth. These are sent to the government, checked against the
SSN Master File, and a Yes/No indicator is sent back to the business.

Since it is uncommon in everyday life to have one’s SSN information checked by

businesses, banks doing large numbers of transactions with people require a
different license to participate in this system.

In contrast, in India residents are regularly asked to show their Aadhaar “card”
and this document is regularly photocopied. As a result of this process, a new
convention has arisen where individuals take a photocopy of their card and write
the purpose for which it was made across the image. This, users hope, is a way to
prevent the photo copy from being used by someone else to open an account or to
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obtain a service in their name.

Employment Enrollment and Use

When people seek employment in the United States, they are required to share
their SSN with their employer. Employers are required by law to verify that the
people they are hiring have valid SSNs. The CBSV is used for employee SSN
verifications.

Individuals can also self-check via the e-Verify system set up by the Department
of Homeland Security on an online portal. Individuals can enter their SSN with
their current citizenship status and receive a report about their current eligibility
to work.

Employers can enroll to use the e-Verify system too. They log into the system
every time they want to check a potential employee’s status by using information

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 listed in the I-9 form (legal name, SSN, date of birth, and current citizenship
status). The employer will then receive a report about the applicant’s current
eligibility to work.

Employers who want to check if an SSN is valid for the purposes of tax
withholding can register with the Social Security Number Verification System
(SSNVS) to do so. Employers enter the names and SSN of employees that they
want to check. The system reports back if they match a person in the system.
Employers do this is to ensure that the taxes they are withholding from their
employees actually lines up with records at the Social Security Administration.

At the end of every quarter, employers send the government income taxes that
they withhold from their employees along with the name and SSN. The
government uses the SSN as an index to tax records and social benefit schemes
into which they pay social security and Medicare.

While these systems can potentially be used to extract information for other
594
purposes, this is explicitly prohibited.

In India, the Employees Provident Fund Organization requires Aadhaar (EPFO)

595
to open an account, and participation in PF is mandatory, so employees do not
have a choice as to whether or not they want to share their Aadhaar number with
their employer who will then pass it along to the EPFO.

In India, several employers, particularly the government, connect to the Aadhaar

596
Enabled Biometric Attendance System. This means that every day, when an
employee arrives to work, they are required to enter their Aadhaar number but it
is authenticated with a fingerprint. The biometric template is sent to the CIDR
and the authentication event is logged. This means the government not only has
a record of what an employee earned and tax deductions they submitted
quarterly, it also knows when the employee was at work in any given day.

Figure 11: Authentication Process of Matrix that Integrates with the AEBAS
server. [Link]
[Link].

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 Conclusion

The framing of how a national identity number can and must be used, along with
the regulation of its use, often determines how companies, other governments,
and citizens all use national identity numbers. It is vital that a global dialogue
continues about the specifics of how the identity systems work in the two largest
democracies.

While in India I learned there were a lot of assumptions made about how the U.S.
system works that are actually incorrect. I hope that this paper provides a starting
point to understand the key differences between the U.S. and Indian systems and
made clear to readers from both countries about how the systems work.

In the United States, there is significant regulation around the use of SSNs, and
extensive privacy protection rules about any personally identifiable information.
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There is public dialogue, which has been ongoing since the creation of the
SSN, about how much information is appropriate for the U.S. government to have
on residents in order to provide them with services.

The Aadhar system is more exclusively digital because it was created in the last
10 years. There are no privacy or data protection laws in place in India. The
creators of the Aadhaar system chose to expand the features of the system
without public input and feedback, and because they are their own regulator.

In my research, I have not found any comprehensive government-led privacy

impact assessments or evaluations about the use of Aadhaar in any context.
Aadhaar proponents see it as having the potential to “solve” a vast range of
problems. Yet, there tends to be insufficient consideration of the ways in which
the proposed solutions that use Aadhaar might create risks for those individuals
and institutions it intends to serve

Identity systems are powerful tools that have the potential for good, but also for
great harm. Those highlighting legitimate concerns in democracies should not be
fearful that their criticism will be criminalized. Public engagement and robust
public dialogue about identity systems in all countries should continue and be
supported.

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