Digital Identification Cards: What Are the Privacy, Safety, and Security Risks When Provincial Governments Replace Physical Identification?
Caveat - With Ontario’s recent announcement that it will begin a limited rollout of digital identification cards (1), and following similar initiatives already being tested in British Columbia (2)(3), we have received questions about our perspective on this emerging technology, particularly when it comes to privacy, safety, and security.
From a digital safety, cybersecurity, privacy, and civil liberties perspective, there are several legitimate concerns surrounding a provincial government’s decision to replace traditional physical identification cards, such as driver’s licences, provincial identification cards, and health cards, with digital identification stored on smartphones. While digital identification can offer convenience, improved authentication, and more efficient access to government services, it also introduces risks that do not exist, or exist to a lesser degree, with traditional physical identification.
One important distinction is whether a government is introducing digital identification as an optional alternative to physical identification or intends to make it the primary or exclusive form of identification. These are two very different public policy decisions. For context, British Columbia already has a Digital Services Card program. According to the province, the digital credential is currently limited to selected pilot projects, remains optional, and does not replace the physical BC Services Card. The province also states that the credential is encrypted, stored on the user’s device, and designed to limit information sharing.
However, if a province were to move toward replacing physical identification altogether, several important issues would need to be addressed.
1/ A Smartphone Becomes a Single Point of Failure
We believe that one of the most immediate concerns is that a person’s ability to prove their identity becomes dependent on a functioning electronic device. Consider the following situations:
A person’s smartphone battery dies.
Their phone is lost or stolen.
Their device is damaged in an accident.
The operating system becomes corrupted.
A software update causes the digital ID application to malfunction.
The individual cannot afford to replace an aging smartphone.
The government authentication system experiences an outage.
A person is travelling in an area without reliable internet access.
With a physical driver’s licence or provincial identification card, individuals can generally continue to establish their identity regardless of whether they have access to electricity, cellular service, or a functioning smartphone. Although well designed digital credentials can support offline verification, this capability is not universal.
The concern: Should a person’s ability to establish their legal identity depend on whether they own, maintain, and can operate a compatible electronic device? This becomes particularly important during emergencies, natural disasters, evacuations, and prolonged power outages.
2/ Increased Exposure to Cybercrime and Identity Theft
A traditional physical identification card can be stolen, photographed, copied, or counterfeited. However, digital identification introduces additional opportunities for cybercriminals. These include phishing, malicious applications, account takeover, credential theft, and attacks against the infrastructure used to issue or verify identification. For example, a cybercriminal might send a fraudulent text message claiming, “Your Provincial Digital ID has expired. Click here to reactivate your identification.” The victim could then be directed to a convincing government impersonation website designed to capture personal information or authentication credentials. A more sophisticated attack could involve tricking someone into authorizing the transfer or re-issuance of their digital identity credential to a device controlled by the criminal.
The potential consequences become more serious when the same digital identity is used to access multiple government services, including healthcare, taxation, licensing, and financial assistance. British Columbia’s own BC Services Card security guidance recognizes the importance of protecting against impersonation and unauthorized access to sensitive government services.
The concern: A compromised digital identity could potentially provide criminals with access to several services rather than exposing only the information printed on a stolen physical card. The extent of that risk depends on how the digital identification system is designed, what services are connected, and what additional authentication safeguards exist.
3/ Government Surveillance and the Potential to Track Citizens
This is one of the most significant privacy questions surrounding digital identification. When someone presents a physical driver’s licence to establish their age or identity, the government does not ordinarily receive an electronic notification that the card was presented. Digital identification can work differently, and depending on its architecture, a digital identity system could generate records showing:
When identification was presented.
Where it was presented.
Which organization requested verification.
What information was shared.
Which government or commercial service was accessed.
If these records are centrally collected, retained, or linked, they could potentially create a detailed picture of an individual’s activities. For example, imagine a future where digital identification is used to enter licensed establishments, purchase age-restricted products, access healthcare, register for government services, or verify identity online. If the system records and correlates these transactions, it could create a significant new source of information about citizen’s daily lives.
However, digital identification does not inherently mean government surveillance. Privacy preserving systems can be designed to prevent the issuer from learning when or where credentials are presented. In fact, British Columbia states that its Digital Services Card is designed so the province does not know when or where it is used, except when the individual is interacting with the province itself.
The concern: What technical, legislative, and independent oversight mechanisms prevent a digital identification system from becoming a tool for tracking citizens? A government’s promise not to monitor people is different from a system that is technically designed to prevent such monitoring.
4/ Function Creep: When Digital ID Becomes a Requirement for Everyday Life
Another concern is something privacy professionals often describe as function creep. This occurs when technology introduced for one legitimate purpose gradually expands into other areas without the same level of public scrutiny or informed consent. For example, a digital identification system might initially be introduced to make accessing government services more convenient. Over time, it could expand to include:
Driver’s licences and provincial identification.
Healthcare services.
Banking and financial verification.
Employment eligibility.
Age verification for online platforms.
Access to government benefits.
Commercial transactions.
Each additional application may appear reasonable when considered individually. However, collectively, these applications could make digital identification increasingly difficult to avoid. A system initially described as voluntary could become effectively mandatory if essential services stop accepting other forms of identification.
The concern: Who decides how digital identification can be used in the future, and what prevents its expansion beyond its original purpose? Strong legislative restrictions, independent oversight, and meaningful public consultation become important safeguards.
5/ Digital Exclusion and Discrimination
One of the most overlooked concerns is that not everyone owns a smartphone or has the technical knowledge necessary to use digital identification. This can disproportionately affect:
Seniors who are uncomfortable using smartphones.
People with disabilities who experience accessibility barriers.
Individuals living in poverty.
People experiencing homelessness.
Residents of rural and remote communities.
People who cannot afford current smartphones or reliable internet access.
Individuals who have difficulty navigating digital authentication systems.
There are also legitimate concerns involving people who have lost access to their devices because of domestic violence, theft, or financial hardship. Imagine a senior who has used a physical identification card for decades suddenly being told that identification must now be presented through a smartphone application, or consider someone experiencing homelessness whose phone has been stolen and who needs identification to access emergency housing or government assistance. These are not simply matters of convenience, they raise questions about equitable access to essential services.
The concern: Should a person’s ability to access government services depend on their financial capacity, digital literacy, or ability to maintain a smartphone? The federal government’s digital credentials guidance emphasizes voluntary participation and alternative ways of accessing services.
6/ The Risk of Centralized Data Breaches
A digital identification system may require infrastructure to verify identity, issue credentials, revoke compromised credentials, and authenticate users. Depending on how that infrastructure is designed, it may create attractive targets for cybercriminals. If a centralized identity database were compromised, attackers could potentially obtain sensitive personal information relating to large numbers of citizens. The information exposed might include names, dates of birth, addresses, photographs, or other identity attributes, depending on what the system stores.
It is important to recognize that governments already maintain substantial identity databases for physical identification systems. Digital ID does not automatically create centralized storage, and some systems deliberately minimize the information held centrally. However, integrating identity verification across multiple services can increase the consequences of security failures.
The concern: Does the proposed digital identification system reduce the amount of personal information being stored and shared, or does it create additional connections between databases that increase the potential impact of a breach?
7/ Biometric Information and Facial Recognition
Some digital identification systems use facial recognition, fingerprint authentication, or other biometric technologies. Biometrics can provide useful security benefits, particularly when authentication occurs locally on a smartphone. However, biometric information presents a distinctive privacy challenge. A compromised password can be changed, where as a person’s face and fingerprints cannot be replaced in the same way.
There is also an important difference between a smartphone using facial recognition locally to unlock an encrypted credential and a government maintaining a centralized biometric database. These two approaches present different levels of privacy risk.
British Columbia already uses facial recognition in aspects of its physical identification issuance process, according to ICBC's identification security information. Consequently, biometric privacy is not an entirely new issue introduced by digital ID.
NOTE: Police already have lawful mechanisms to obtain government held identification photographs. The introduction of digital identification does not, by itself, create that authority. However, digital identification systems can introduce additional privacy considerations, particularly if they involve centralized identity verification, biometric matching, transaction records or expanded information-sharing capabilities. The important questions are not simply whether police can obtain a person’s identification photograph, but also what information is collected, how it is stored, who can access it, and what legal authorization is required.
The concern: What biometric information is collected, where is it stored, who can access it, and can it be used for purposes beyond identity verification?
8/ Identity Theft Could Become More Difficult to Resolve
When a physical identification card is lost or stolen, an individual can report the loss and request a replacement. With digital identification, the recovery process may be more complicated. For example, what happens if a criminal gains control of someone’s digital identity account and changes the associated authentication methods? The legitimate owner may then need to prove their identity to recover access to the very system used to establish that identity. This creates a potential circular problem.
The risk is particularly important when a single digital credential provides access to multiple government services. The National Institute of Standards and Technology's Digital Identity Guidelines address identity proofing, authentication, and credential management, all of which are important components of secure digital identity systems (4).
The concern: What happens when a digital identity is compromised, and how quickly can the legitimate owner restore access without being excluded from essential services?
9/ Increased Opportunities for Coercion and Domestic Abuse
Digital identification can also create concerns in situations involving controlling or abusive relationships. For example, an abusive partner may have access to another person’s smartphone, know their device passcode, or pressure them to unlock their digital identity. Depending on how the system works, this could expose sensitive personal information or allow unauthorized transactions. There are also concerns about situations in which a person is pressured to present digital identification or disclose information that would not ordinarily be visible on a physical card.
Digital systems can offer protections against these threats, including selective disclosure, separate authentication requirements, and restrictions on what information can be requested. However, these safeguards must be incorporated into the design.
The concern: Has the government considered how digital identification might affect individuals experiencing domestic violence, coercive control, or financial exploitation?
10/ Police Interactions and the Privacy of Personal Smartphones
This is an especially interesting issue from a law enforcement and civil liberties perspective. Consider a driver who is stopped by police and asked to produce their driver’s licence. With a physical licence, the driver can hand over the card without providing access to their personal electronic device.
With a digital licence, the individual may need to unlock their smartphone to present identification, which raises several questions.
Does the person need to physically hand their smartphone to the officer?
Can identification be verified without unlocking the entire device?
What happens if the officer asks to take the phone to a patrol vehicle?
Could notifications, photographs, messages, or other private information become visible during the interaction?
Would the individual have the ability to present their identification without exposing unrelated personal information?
A properly designed digital identification system can reduce these risks by using secure, limited-information verification methods that do not require surrendering an unlocked phone. However, the ability to present identification should not automatically become an opportunity for unrelated access to personal digital information. This is an area where clear legislation, operational policies, and police training would be essential.
11/ Digital ID Could Become a Tool for Commercial Data Collection
Another concern is the potential involvement of private companies in digital identity verification. If businesses begin using digital identification to verify age or identity, questions arise about what information they receive and retain. For example, a business verifying that someone is over 19 should not ordinarily need to collect their full legal name, home address, or complete date of birth.
A well-designed digital credential could actually improve privacy by allowing someone to prove they meet an age requirement without disclosing their precise birthdate. This is called selective disclosure. However, if businesses collect more information than necessary, digital identification could create additional opportunities for profiling, data retention, and commercial tracking.
The concern: Will businesses be legally and technically restricted to collecting only the minimum information necessary for a transaction?
12/ The Risk of System-Wide Disruption
Physical identification cards operate largely independently of centralized electronic systems when used for visual inspection. Digital identification systems may depend on applications, cryptographic certificates, verification infrastructure, software updates, and other technical components. If a critical component fails, a large number of people could potentially experience difficulties proving their identity. Possible causes include:
Cyberattacks.
Software defects.
Authentication server failures.
Expired or incorrectly configured digital certificates.
Cloud infrastructure outages.
Errors during major system upgrades.
A well-designed digital identity system can reduce these risks through offline verification, redundancy, and alternative authentication methods. Nevertheless, governments need to plan for circumstances in which the technology fails.
The concern: What contingency plans ensure citizens can continue proving their identity during prolonged technical outages?
So the next logical question is, “Are there advantages to digital identification? We think the answer is, “Yes”. It is important not to overlook the potential benefits. Digital identification can offer meaningful improvements over physical cards when implemented properly, and these benefits are legitimate. In some circumstances, a properly designed digital identification system may provide stronger security and privacy protections than a traditional physical card. The critical issue is how the system is implemented and what protections are established before it becomes widely adopted.
10 Questions Every Provincial Government Should Answer Before Replacing Physical ID
From a digital literacy, cybersecurity, privacy, and public accountability perspective, I believe these are reasonable questions citizens should be asking:
1/ Will physical identification remain available?
Will residents have a permanent right to obtain and use physical identification without additional fees or restrictions?
2/ Can digital identification be used without an internet connection?
What happens when someone loses cellular connectivity, experiences a power outage, or cannot access their smartphone?
3/ Can the government track when and where digital identification is used?
What technical safeguards prevent the collection of identification transaction histories?
4/ What information will businesses and government agencies receive?
Will organizations receive only the information necessary to complete a transaction?
5/ What happens if someone’s digital identity is stolen?
How quickly can credentials be revoked, and what procedures exist to restore access?
6/ Will biometric information be collected or stored centrally?
What restrictions will apply to facial recognition and other biometric technologies?
7/ Who will independently audit the system?
Will security assessments, privacy impact assessments, and independent audits be made publicly available?
8/ Can police require someone to surrender or unlock their smartphone to present identification?
What legal protections prevent unrelated searches of personal devices?
9/ Can digital identification become mandatory for other services?
What legislative protections prevent future expansion without public consultation and oversight?
10/ What happens to people who cannot or do not want to use digital identification?
Will meaningful alternatives remain available to seniors, people with disabilities, low-income residents, and others?
An Important Consideration: Privacy by Policy Versus Privacy by Design
One distinction deserves particular attention. There is a significant difference between a government stating, “We will not track when citizens use their digital identification.”, and a government implementing a system in which, “The technology is designed so that the government cannot track when citizens use their digital identification.” The first is a policy commitment, while the second is a technical safeguard, and ideally, both should exist.
Privacy legislation can establish restrictions on how information is collected and used. Privacy preserving technical architecture can reduce the ability to collect that information in the first place, and independent oversight provides an additional layer of accountability. In British Columbia, government guidance already recognizes the importance of privacy impact assessments and security threat and risk assessments when developing digital services. The important question is whether those assessments sufficiently address the long-term implications of expanding digital identification across government and commercial services.
The Question Is Not Whether Digital ID Is Good or Bad
From The White Hatter’s perspective, the introduction of digital identification should not automatically be viewed as either a technological advancement that everyone must embrace or a threat that everyone should fear. Like many technologies, digital identification can create opportunities while introducing new risks. The benefits of convenience, improved verification, and reduced fraud are worth examining, but so are the implications for privacy, cybersecurity, accessibility, and individual autonomy.
However, there is one distinction that we believe deserves particular attention, giving citizens the option to use digital identification is fundamentally different from requiring citizens to depend on digital identification. When digital identification is optional, people can decide whether its benefits outweigh their personal concerns. When digital identification becomes mandatory, those concerns become matters of public policy, accessibility, and civil liberties. For this reason, an important measure of a provincial digital identification program is not simply how convenient or technologically advanced it is, but whether it preserves meaningful choices, protects personal information, and ensures that citizens are not excluded from essential services.
One Additional Concern Worth Considering
There is also a broader question about the relationship between digital identity and digital autonomy. As governments, financial institutions, employers, and commercial platforms increasingly rely on digital verification, a person’s ability to participate in everyday life could become more dependent on maintaining access to a single digital identity infrastructure.
This does not mean governments intend to restrict participation or monitor citizens. It does mean the architecture, governance, and legal protections surrounding digital identity deserve careful examination. A system that becomes essential to everyday life should have clear safeguards against wrongful suspension, administrative errors, misuse, and the loss of access to essential services.
The central question is not simply whether governments can make identification digital. It is whether they can do so while preserving the privacy, security, accessibility, and individual freedoms that physical identification currently helps support. For us here at The White Hatter, that is a discussion worth having before digital identification becomes the expected standard rather than an available choice.
Now, we know what many of our followers are likely wondering, “Given everything outlined above, will The White Hatter be adopting digital identification?” At this point, our answer is NO. As with any emerging technology, we believe there is value in taking a measured, evidence informed approach rather than rushing to become an early adopter. We intend to allow digital identification systems time to mature, observe how they perform in real world situations, and assess any emerging safety, security, and privacy concerns before deciding whether the benefits outweigh the potential risks. This does not mean we are opposed to digital identification. Rather, we believe that convenience alone should never be the deciding factor when it comes to protecting our personal information.
Besides, our current phone cases already allow us to conveniently carry a physical driver’s licence or other identification alongside our phones. For now, that solution works just fine for us, without introducing another layer of digital complexity or potential privacy concerns.
Digital Food For Thought
The White Hatter
Facts Not Fear, Facts Not Emotions, Enlighten Not Frighten, Know Tech Not No Tech
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