Taking another look at mobile SIM registration in Ghana

SIM registration is not a time-bound exercise as we sometimes make it look like; it is an ongoing unending process.  Everyone who buys a SIM card is still required by law to register using any of the five legally mandated ID cards – passport, driver license, voter ID, National Health Insurance card or the National Identification Card (Ghana card).

The Ghanaian attitude of waiting till the last minute to rush and fulfil their civic duties, make long-term processes look like they are short-term time-bound exercises. It was the same with mobile number portability – some thought it was some exercise that people needed to participate within a certain space of time or miss out, but MNP is here to stay and it is still ongoing; and so is SIM registration.

SIM registration is now backed by law, and would be ongoing until  a new law is enactto change or abolish it. To that extent, it is still relevant to raise issues about it and point to the possibility of taking a second look at aspects of it, particularly the ID requirements, verification and the type of information collected.

For the purposes SIM registration was implemented, one cannot deny that it is a necessary evil. Even though one would want to buy a SIM today and be able to use it in a matter of seconds, one cannot also ignore the security and criminal implications of not being able to identify who owns what SIM.

The several SIM-based criminal activities like SIM Box fraud, people using anonymous phone numbers to threaten and blackmail others through calls and text messages, and several other such anti-social SIM-based behaviours, are real.

The National Communication Authority (NCA) has even argued that with over 21 million mobile phone subscriptions in an estimated population of 24 million in Ghana, SIM registration promises to generate ‘the biggest  and authentic’ databases in the country. That is highly debatable, as this article would show.

The kind of IDs the law requires for SIM registration, and the ID verification process have led to the anxiety among subscribers, banter between telecom operators and the regulator (NCA), been a reason some civil society organisations threatened court action against telecom operators and the NCA, and could be a reason some subscribers may eventually take some telecom operators to court.

What is it about the ID requirement and verification that is causing so much hullabaloo, and why are the positions so entrenched on the question of making or not making adjustments; after all, the law is made for man, and not man for the law.

Ghana’s SIM Registration Regulation, LI 2006, 2011 requires all telecom operators to register all SIMs in phones, modems, tablets and other devices, and allow for verification before activating them for subscribers. The regulation only gives life to the Section 97 of the Electronic Communication Act, Act 775, which mandate the Minister of Communication to ensure that all telecom service providers keep records of their subscribers.

The argument has never been about whether or not, the particulars of subscribers should be kept by operators – because that is something the operators already do for their post-paid, mobile money and other groups of subscribers; the issues has been with what type of ID is valid for registration. And that argument can be taken further to what type of information should telcos extract from subscribers, particularly when the SIM registration is intended to, among others things, stem crime.

Identity Cards

The law is clear on the types of IDs that nationals, foreigners and corporate bodies can use to register SIMs. For nationals it is limited to any of five IDs – passport, driver’s license, voter ID, National ID or National Health Insurance card. For foreigners, it is limited to passport or ‘other travel document’ (not specified); and for corporate organisations, they are limited to certificate of incorporation.

In other words if you are Ghanaian and you don’t have a passport, you don’t drive, you don’t vote, you do not use national health insurance and your National ID is not ready, just like is the case for an overwhekming majority of Ghanaians, you cannot own an active SIM card, unless someone registers a SIM in his or her name for you to use.

Even when someone registers a SIM for you, the law requires that person to provide your particulars, including any of the mandated valid IDs, to the service provider in writing within a week of giving that SIM to you, then you also write to the operator saying that SIM is now yours and provide the ID to re-register it in your name.

That is very funny because what then is the point in someone registering a SIM in his or name for another person who does not have any of the valid IDs? In any case, of all the valid ID’s the only one legally mandatory for all people living in Ghana to have is the National ID, which is still not available to majority of Ghanaians and residents.

Biometrics

Secondly, if indeed the main purpose of the SIM registration is to stem crime and other anti-social activities people do with their SIM cards, why is the process allowing registration without a record of the picture of SIM owners and other biometric information like finger prints as done elsewhere in Africa? One would have thought that any serious process of collecting IDs aimed at stemming crime should focus mainly on bio data such as pictures and finger prints.

In the case of Ghana’s SIM registration, the process started with registration agents of the telcos scanning the photo IDs of SIM owners, but according to the telcos, they stopped because some of the ID cards, particularly, voter ID had black and white pictures, which are defaced and hard to tell the holder is the one in the picture.

The telcos therefore resorted to just taking the ID numbers on the cards submitted for registration, and the regulator, NCA allowed it to go on without insisting. The process does not also take the finger print of SIM owners; and that defeats the purpose of the exercise, because even if one commits a crime with a SIM card, the only thing that can be done is to deactivate the SIM, but tracing that person becomes difficult because his or her picture and finger print is not available.

The NCA, the telcos and every Ghanaian knows that Ghana’s address system is in as much shambles as the ID system, so it is difficult to trace people with their addresses. Moreover the ID cards the NCA insist on people using to register SIMs are being faced out in favour of biometric IDs. The Passport Office has started issuing biometric passports, and the electoral commission is starting biometric registration March 24, 2012.

Clearly, this shows that Ghana is moving away from the porous, unreliable non-biometric ID systems, which the NCA seem to trust so much and believe they can generate ‘the biggest authentic database’ from – that sounds like a big joke.

In Nigeria, I personally registered an MTN SIM and they took my photo ID, finger print and other details, so I can easily be tracked if I used that SIM for a crime and throw it away and register another SIM even in another name. Even roadside registration agents had devices for taking finger prints, why not Ghana?

It is still not clear why in Ghana, other picture IDs such as student ID and employment ID are not allowed for SIM registration. In Kenya and Uganda such IDs are allowed, and even some other work-related documents, once they have the SIM owners picture on it – the focus is the photo, then the service provider takes the rest of the details, including finger print. (very important).

One interesting thing about Uganda in particular is that they even allow a common passport picture for both nationals and foreigners as an ID for registration. Again the rationale is that the person’s bio-data will be taken so what is the point in demanding some ready-made ID card. Even when one  goes to register without a photo, the agents have a camera and they will take one’s picture before taking one’s other details.

Demanding IDs like voter ID, driver license, passport and the rest, without taking the biometric data of the SIM owner, is worse than requiring a simple passport photo plus the bio-data. The NCA should know better.

Even in collecting data for voters’ registration, through which Ghana elects national leaders, we did not insist on verifying the identities of the persons on the electoral roll, and yet the NCA is so adamant on verifying the IDs of persons before they can own a SIM, which may be fair, but the NCA is obviously going about it in a way that defeats the very purpose of the process.

The bane of this whole process is that the various ID data the NCA is insisting on using as the basis for verifying people’s IDs are themselves not very reliable, not to talk of the manual procedure that NCA is employing and its resultant human error.

Non-Ghanaians

It was also interesting to find that for non-Ghanaians, the law limits the ID required to passport or other travel documents; and the NCA interprets that to mean lasse passe for ECOWAS citizens, but strictly passport for all other nationals. The question is whether it is up to the NCA to interpret the law or the courts to do so.

In Kenya, Nigeria and Uganda, for instance, work permit, passport, alien card, nation ID from the SIM owners own country, and drivers license are allowed, even for non-ECOWAS citizens, but in Ghana, where ECOWAS citizens are allowed into the country with the ID’s of their original countries, the NCA insists the national ID’s of ECOWAS citizens are not valid for SIM registration.

The question then is whether we as a country are serious about ratifying regional integration protocols, or we just do so for the cameras and then institutions like the NCA rubbish those agreements. The NCA says to the extent that it does not allow Ghanaians to use other IDs like staff or student ID, it cannot allow other nationals to use their national ID. But why not student IDs and staff IDs in the first place, if the focus is on the photo – to easily identify the owner of the SIM?

As pointed out at the start of this article, SIM registration is not a time-bound exercise; it is a continuum, and it is not too late to make adjustments – particularly with the types of IDs required, and the kind of data collected from the SIM owners. Indeed the law make room for additions to the list of IDs. As for verification, it is necessary, but the way it is being done now leaves room for a great deal of human error. If my bio-data is available with the various ID agencies, it does not matter what name I give, all they need to do is to run my finger print through the system and the real me will show up.

We need to fix our entire ID system before we can trust the data collected from the SIM registration, otherwise this claim by the NCA that the data from SIM registration would be the biggest authentic database in the country, is flawed big time because it may be a big database in terms of volume, but in terms of quality, it is just as porous and unreliable as the others. That data can hardly be used to arrest any criminal, save deactivating the SIM involved in the crime.

By Samuel Nii Narku Dowuona