Deployment of automated face comparison

Municipality of Arnhem

Automated facial comparison for first registration in the Basic Registry of Persons (BRP), resettlement applications and naturalisation applications for persons over 18 years old. This algorithm helps the registrant prevent "look-alike fraud". Sourced from the Rijksdienst voor Identiteitsgegevens (RvIG).

Last change on 20th of August 2024, at 7:18 (CET) | Publication Standard 1.0

• Publication category: Impactful algorithms
• Impact assessment: Field not filled in.
• Status: In use

General information

Theme

Organisation and business operations

Begin date

06-2019

Contact information

[e-mail]

Responsible use

Goal and impact

''The automated face comparison serves two purposes, namely:

1. Establishing the identity of an identity card applicant to prevent identity fraud; and

2. Keeping the information in the Basic Registration of Persons (BRP) reliable.

A desk clerk does the checking. If the application using the algorithm indicates that the person whose face has been compared is not the person standing at the counter, the counter employee engages a colleague (as a second line) to verify this finding.

These staff apply the 'four-eye principle' when in doubt about the face comparison finding. If they conclude, partly on the basis of their own assessment and observation, that the finding of the face comparator is correct and the identity of the applicant does not match the identity in the photograph, the application for a first registration/resettlement in the BRP or naturalisation will not be processed. This may indicate whether fraud is suspected. If fraud is suspected, 112 is called and the police are called in for further investigation. In this context, Civil Affairs, Public Affairs Department, acts in accordance with the model working instruction on identity fraud issued by the WTI (Working Group on Countering Identity Fraud).

Considerations

The deployment of this algorithm helps employees of the Public Affairs Department determine the identity of the resident at the counter. The facial comparator can determine the biometric features in the face more accurately than the human eye.

Human intervention

The face comparator is a tool, the final assessment is made by a staff member. As mentioned, the 'four-eye principle' is applied if the finding of the facial comparator is negative.

Risk management

Using the facial comparator when registering for the BRP or applying for resettlement or naturalisation eliminates the risk of potential profiling in advance.

The next risk is that the facial comparator leads to an automated decision. This risk is overcome because the finding is always tested by an employee. In case of doubt by at least 2 employees.

Legal basis

- Legal obligation to establish proper identity: Art. 2.67(4) BRP Act

- Admissibility of biometrics: art. 29 UAVG, in the present situation authentication is necessary

Links to legal bases

• Wet basisregistratie personen: https://wetten.overheid.nl/BWBR0033715/2023-01-01
• Uitvoeringswet Algemene Verordening Gegevensbescherming: https://wetten.overheid.nl/BWBR0040940/2021-07-01/0

Operations

Data

Biometric features in the face

Technical design

Deep learning. Advanced face recognition APIs: C++, Java, Microsoft .NET, BioAPI 2.0 Verification Engine (C API). Documented examples for key use cases and specific implementations. Tools for biometric evaluations, including generation of 'identification match' views and 'similarity matrix' data.

External provider

Oribi B.V.