Joint Statement: Say no to Aadhaar based Facial Recognition for Vaccination!


In a recent interview, the National Health Authority chief Dr. R.S. Sharma stated that facial recognition technology (FRT) would be used in conjunction with Aadhaar to authenticate the identity of people seeking vaccines. Working with Rethink Aadhaar and a team of volunteers, we have released a joint statement opposing this initiative, that is co-signed by more than 10 organisations and 158 individuals, many from the public health movement. In the statement, we highlight our concerns on the use of this inaccurate technology for access to vaccines and how it may lead to potentially life threatening exclusion. Sign on to the statement here!

Updated on April 19, 2021

As on April 19, 2021, the joint statement has been endorsed by 16 organisations and 505 individuals. We have sent this joint statement along with a brief covering letter to Dr. Ram Sewak Sharma and the National Health Authority. The endorsements have also been updated in the table below. We will continue to update you with regard to the next steps we take on the issue as we consider further advocacy actions depending on the response received from the authorities, which may immediately commence with measures towards transparency by filing Right to Information requests.

What happened?

In an interview to The Print, the CEO of the National Health Authority, Dr. R.S. Sharma, who is also the former Director General of the Unique Identification Authority of India (UIDAI), said that,

“Aadhaar-based facial recognition system could soon replace biometric fingerprint or iris scan machines at Covid-19 vaccination centres across the country in order to avoid infections”.

While currently the Government is using biometric fingerprint or iris scan machines for the purpose of authentication of identity at vaccination centres, they could soon be replaced with FRT by the Government which believes that use of FRT will help in avoiding infections. According to the interview, the pilot for the program has already been initiated in Jharkhand.

Following severe backlash from privacy as well as public health organisations, Dr. R.S. Sharma, on April 10, 2021, clarified that Aadhaar based FRT usage for access to vaccines is just a “proof of concept” at this stage, and won’t be made mandatory even if it is rolled out across the country. However, even non-mandatory use of Aadhaar based FRT is extremely problematic and should be immediately halted. We discuss our concerns on use of FRT in the next section.

The Ministry of Health and Family Welfare had earlier clarified in the Lok Sabha that Aadhaar was not mandatory to receive the vaccine, which was reflected in the ICMR’s guidelines on the vaccination process, which listed the multiple forms of ID that would be accepted. However, in fresh guidelines released in early April, Aadhaar was listed as the "preferred" mode of identity verification. However, a public interest technologist, Anivar Aravind has posted a screenshot from the COWIN platform which tells a different story. (Link to tweet included on the right)

Joint Statement by more than 10 organisations and 158 Individuals

The undersigned human rights and digital rights organisations and individuals, including those from the public health community express their deep concern on the National Health Authority’s plans to use facial recognition for “contactless” COVID-19 vaccine delivery. Facial recognition technologies (FRT) pose a grave threat to human rights, including privacy, and are being rolled out in the absence of a valid legal basis. We recognise that the timely and efficient delivery of vaccines is vital. However, the use of facial recognition for authentication does little to ensure this, and will in addition put in place rights-infringing technologies that enable mass surveillance and the erosion of fundamental rights.

The unchecked rollout of FRTs increases the risk of unchecked government surveillance, and mission creep. Evidence has shown that FRTs are not accurate and linking this untested technology to the vaccination roll-out will only exclude persons from the vaccine delivery system.

R.S. Sharma, the current head of the National Health Authority, and former chief of UIDAI said in a recent statement that the “Aadhaar-based facial recognition system could soon replace biometric fingerprint or iris scan machines at Covid-19 vaccination centres across the country in order to avoid infections.” This has given rise to considerable concern and anxiety for many who are yet to be vaccinated. FRT deployment would result in a drastic change in existing government policy for an inclusive rollout of the vaccination process. As per stated government policy, note that biometric authentication is not currently being used in the vaccination process. As the Ministry of Health and Family Welfare clarified in the Lok Sabha, Aadhaar is not mandatory to receive the vaccine, and the ICMR’s guidelines on the vaccination process are clear that multiple forms of ID will be accepted.

FRTs pose an alarming threat of exclusion, harms to privacy, with a high likelihood of function creep.

1. Exclusion and discriminatory outcomes

Linking welfare schemes to Aadhaar and its biometric verification system has caused mass exclusions, and has even led to starvation deaths. As Jan Swasthya Abhiyan and Rethink Aadhaar have warned before, conditioning access to healthcare on Aadhaar, or, as in this case, an untested facial recognition system, will increase the risk of exclusion. Introducing this technology will only impede the process of vaccine delivery. Facial recognition is not an accurate mode of identification - as IFF has noted, “no FRT has been found to have a 100% success rate. Implementation of an error-prone system without adequate legislation containing mandatory safeguards, would deprive citizens of essential services.” Even the UIDAI’s 2018 circular, that introduced facial recognition as a mode of authentication for Aadhaar, noted that it was to be used “in fusion mode,” as an additional mode of identification. In the absence of any national standards to regulate this technology, the possibility of adopting inaccurate or faulty systems increases. An error-prone FRT system, as the only mode of identification, would lead to false negatives, as the system will not be able to correctly identify individuals, and arbitrarily deprive them of access to essential government schemes, in this case, COVID-19 vaccines.

2. Harms to privacy

The use of this technology violates our fundamental and constitutional right to privacy, a right affirmed by the Supreme Court in Justice Puttaswamy v/s Union of India. Any infringements of this right must be necessary and proportionate, in accordance with procedure established under the law, and subject to strict oversight. The proposal to introduce facial recognition for vaccine delivery meets none of these standards. Function creep: Available evidence indicates several instances where FRTs when initially deployed to a specific purpose are then extended to others. For eg. in December 2019, IFF sent a representation to the Delhi Police in response to reports that it was using an Advanced Facial Recognition Software to identify protestors, which was initially obtained to reunite missing children with their families. In July 2020, IFF sent a legal notice to the National Crime Records Bureau, against their development of the National Automated Facial Recognition System, reportedly the world’s largest FRT system.

As India careens into a “second wave” of COVID-19, it is crucial that the government’s focus stays on increasing the speed, range and efficacy of vaccine delivery, and not use it to test out privacy harming technologies. The pandemic offers the Centre and State governments an opportunity to expand peoples’ access to healthcare as a matter of right, ensure healthcare is accessible and affordable, and that accessibility is not limited by imposing conditionalities such as enrolment in digital identification projects, or being coerced to use privacy harming technologies.

Our demands are direct with the shared intent of ensuring the prompt and universal delivery of vaccines in a rights respecting manner to mitigate the tremendous harm resulting each day to thousands of Indians due to this pandemic. We call on the Government of India and public officials, specifically Shri R.S. Sharma to :

  1. Issue a public statement clearly stating that compliance will be ensured with existing government policies for vaccination that focus on universal and inclusive delivery rather than making Aadhaar and FRT based authentication as a basis, or pre-condition for availing it.

  2. Transparently disclosing all technical and financial details of the FRT based system, whether any pilot studies are being conducted or being considered for the rollout of FRT based system. We urge that such necessary disclosure must be facilitated with open sourcing the algorithm for the proposed FRT based system.

  3. As part of any potential pilot programme, conduct an independent human rights and equity audit that includes a privacy impact assessment of the FRT based system.

We urge for consideration and reflection as India stands at a critical juncture in its fight against COVID-19. Here, we need to follow the path of constitutionalism through a respect for rights and advance social justice rather than restrict it by risky, experimental and harmful technology deployments of Aadhaar based FRT systems.

We all need to remain vigilant on FRT System deployments

FRT is an Artificial Intelligence (AI) based technology system which learns to recognize faces on the basis of the data sets that are fed to it. Research has shown that FRT shows high levels of inaccuracy in correctly identifying faces due to the use of biased datasets. Existing bias creeps into these datasets through the people who design them and is reinforced. (Read our review of the Coded Bias documentary which beautifully highlights the work of the women leading the charge against FRT)

This inaccuracy, which is inbuilt into the system, leads to false negative results. A false negative result occurs when the FRT fails to correctly identify the person. This will result in exclusion of the people from access to the schemes for which the authentication of identity was being carried out. We have already seen this occur in the case of Aadhaar to the extent that exclusion led to starvation deaths. Combining these two inaccurate systems will only lead to compounding the existent exclusion.

India is currently at an extremely crucial juncture in its fight against this pandemic and the COVID-19 vaccine is essential to this fight. The foremost way of mitigating the harms of this deadly disease is to ensure that vaccination against COVID-19 is prioritised. The Government has a duty to ensure that any unnecessary hurdles to access to the vaccine are removed. However, with the introduction of this new policy initiative, the Government is increasing them without cause.

In addition to this, under our Project Panoptic, we have been warning against the function creep of this harmful technology since last year. Function creep occurs when a technology or system gradually widens its scope from its original purpose to encompass and to fulfill wider functions. This is the major concern among many privacy experts with regard to the use of FRT wherein they are worried that its use will exceed the indicated purpose of authentication of identity and will end up facilitating state-sponsored mass surveillance.

List of existing signatories (Organisations and Individuals)

Centre for Financial Accountability (CFA)
Health, Ethics, and Law Institute of Forum for Medical Ethics Society
Indian Kanoon
Indian Social Action Forum - INSAF
Indusviva HealthSciences pvt LTD
Internet Freedom Foundation
Jan Swasthya Abhiyan, Chhattisgarh
Jan Swasthya Abhiyan, India
Jan Swasthya Abhiyan-Mumbai
Jharkhand Nagrik Prayas
National Alliance for Maternal Health and Human Rights
Punjab Women Collective
Rethink Aadhaar
Swathanthra Malayalam Computing
The Bachchao Project
Dr Mira Shiva
Aakash Puttige
Aarushi Chadha
Aayomi Sharma
Abdul Kalam
Abhay Rana
Abhimanyu Chandra
Abhinav Badola
Abhinav M
Abhinav Sahai
Abhradip Acharya
Abin Alikunju
Adarsh M Madhu
Adarsh Ranjan
Adhil Ameen P J
Aditi Mittal
Adrija Chaudhuri
Adv. Rohan Babu Joseph
Advait Phadnis
Afsal Y S
Ahad Malkani
Ajinkya dayanand thorawat
Ajmal Hussain
Ajmal V
Akshay Bhalotia
Akshay Parameshwaran
Alpana Andrews
Amal Barman
Ambika Tandon
Ameet Madgavkar
Amit Bhatia
Amitadyuti Kumar
Amith V Purushothaman
Amjad M
Amogh Barakol
Amrithanath Manoharan
Anadish Kumar Pal
Anamitra Saha
Anand Prince
Ananthanarayanan K Subramanian
Aneesha Dsouza
Anirban Sinha
Anita V
Anivar Aravind
Ankit Kumar
Ankit Sharma
Ankur Singh
Ankur Srivastava
Ankur Tyagi
Anshu kaura
Anshumaan Sathe
Antara Mohan
Anurag Ashok
Anushka Trakroo
Anwesha Sengupta
Apu Raj
Apurv Kashyap
Aravind KP
Arijit Sarkar
Arjun kolady
Arkoprovo Ghosh
Arnav Andrew Jose
Arpit Sharma
Arpitha S. Desai
Arsh Rampal
Arun K. P.
Arun Katiyar
Arun Raghavan
Aruna Borhade
Arvind Prasad
Ashik Sorake
Ashish Asgekar
Ashish Sood
Ashiya Ghosh
Ashok V
Ashwin S
Ashwin Srivastava
Asiya Sulthana A
Atul Bhagwat
Avani Chokshi
Avik Dhupar
Avnish Bhagwate
Aziz Khambati
Azra Saman
Barbara Leivang
Bharathi prasad
Bhavin Gandhi
Bhavna Verma
Bhoomika D Pandhare
Bikramjeet Singh
Binu Karunakaran
Boris Poonia
Brindaalakshmi K
Chandan Maheshwari
Chetan Shetty
Darshan R
Dax Pandhi
Deep Dave
Deepanshu Arora
Deepika Joshi
Dheeraj Kushawaha
Dinesh Gopinath
Dinkar Kalra
Disha A Ravi
Divya Kashyap
Divya Sornaraja
Dr Himmat Singh Ratnoo
Dr R.S.Dahiya
Dr. Chinchu. C
Dr. Subrata Sinha
Dr. Sudhir Vombatkere
Dr. V. Visvanathan
Eesha Mullick
Ekta Rathore
Emma Dcruz
Faisal Ali
Faisal Liyakath
Faisal Puthuparackat
Faiz Masi
Feyha Tejani
Francis Jose
Gaurav Chaturvedi
Geeta Seshu
George Jose
Greeshma Gireesh
Gulal Salil
Gurpreet Singh
Gyan Prakash Tripathi
Hanniyah Shabir
Harikrishnan NP
Harjas Singh Bhatia
Harkirat Singh
Harshvardhan Sharma
Hemakshi Motwani
Himanshu Rai
Himanshu garg
Indira C
Irene Vettiyadan
Irshad Muhammad
Isha Gupta
Isha Saxena
Ishita Mondal
Jade Jeremiah Lyngdoh
Jagannath Chatterjee
Jaideep Datta
Jaswitha Reddy G
Jawharali P S
Jayati Ghosh
Jayesh Rajan Krishnan
Jeel Patel
Jeffin Jacob Mathew
Jibeesh GV
Jims George
Jinesh N S
Jishnu Dasgupta
Jishnuraj M
John Varghese
Jomon Thomas Lobo
Joseph Johnson
Joy Bhattacherjee
Justin Jacob
K Biswas
K.A. Verghese
Kabir Nagpal
Karan Garg
Karan Giresh Khetwani
Karan Jeyakumar Nadar
Karthik Yelchuru
Kartikeya Jain
Kashyap Raibagi
Ketaki Mahale
Ketho Rikha
Kinshuk Goyal
Kiran Jonnalagadda
Kiran Kumbhar
Kishan chander Kafaltiya
Krina Shah
Krishanu Chakraborty
Krishna J
Kshitij Chauhan
Kuresh Behreinwala
Kush Saraiya
Kushal Das
Lavanya R
Lavneet Bansal
Leon Morenas
Likhita Banerji
M. Hamza kapadia
Madhav Mehta
Madhura Padhye
Madhuri Mehta
Mallika Muralidharan
Malwika Chitale
Manali Joshi
Manan Mehta
Manav Mander
Mangharam Siddharth
Manoj K
Mansi Rathore
Manuraj Rajamanikandan
Mary Mathai
Mehak Raipancholia
Melroy C.F.Fernandes
Midhun Mukundan
Miki Malik
Mithila R
Mohammad Adil Hussain
Mohit Soni
Mrigank Dhaniwala
Muhammad usman a h
Muhammed Yaseen
Mujeeb Rahman K
Nabisa Chowdhury
Nachiket Udupa
Nadeem Akhtar
Nadika Nadja
Nandhini anand
Narasimha Reddy Donthi
Nasruddin Shaikh
Naveen Bagalkot
Nedra Pereira
Nevaj Rajpurohit
Nihal saeed
Nikhil Malla
Nilanjana Dey
Ninad Limaye
Nishant Gupta
Nishu Gupta
Noor Mohammed
Panangattukara KrishnaIyer Mahesh
Paramdeep Singh Obheroi
Paras Bhandari
Parth Nimkar
Paul Rajaguru
Poonam Sharma
Prachi Lohia
Pradeep E
Prajval Shastri
Prakash Narayan
Prakriti Panthi
Pratham B C
Prerit Srivastava
Priti Patnaik
Priyam Cherian
Priyanka Chattopadhyay
Prof Ritu Dewan
Prof.Mohan Rao
Pushkar Anand
RZ Tharakan
Rachita Taneja
Radha Holla Bhar
Raj Joshi
Rajinder Chaudhary
Rajiva Bhushan Sahay
Ramnik Mohan
Ravi Arora
Ravi Duggal
Rayan Das
Razin Keelath
Rekha raghunathan
Rhea C
Richa kumar
Richa n
Richard Fernandes
Rithwik Cherian
Robot Boy
Rohan Jacob
Rohin Mathew Thomas
Rohini Lakshané
Roshnee Kumar
Rubik Barar
Ruchi Mulye
Rutuja Pawar
S Adarsh Rao
S Bharatwaj
S G Price
Sajida Khan
Salu S
Samata Biswas
Samir J Gosai
Sana Parakh
Sanchet Devlekar
Sandeep Kumar
Sandeep Massey
Sandeep Shukla
Sangram V. Jagtap
Sanjana A
Sanjana Harikumar
Sanket Tambare
Sanket j
Sanoob Pattanath
Santhosh Kumar
Sarada Mahesh
Saranya C
Sarath P
Sarath krishnan K
Sarbeshwar Singh
Sarojini N
Sarvagya Kumar
Saumya Rastogi
Saurav Kothari
Sayali Tekawade
Sayantan Chaudhuri
Sayanth pk
Setu Bandh Upadhyay
Shailly Shrimali
Shaleen Jain
Shalini Gera
Shalmali Guttal
Shameem Mukrikkandiyil
Shamita Sharma
Shantanu Singh
Sharad Lele
Shashank B
Shaurya Sood
Sheheer Ali
Shimyu Manikkoth
Shivam Kaushik
Shivangi Dubey
Shivangi Malhotra
Shivani Chaudhary
Shivani Thapa
Shounak Kelkar
Shrenik Mutha
Shreya Agarwal
Shreya Munoth
Shreyan Chanda
Shriya malhotra
Shubh Agarwal
Shuv Mukherjee
Siddharth Jaiswal
Siddharth Joshi
Siddharth Rajiv
Sijo James John
Siva S
Sneh Sharma
Snehan Kekre
Soumya Dutra
Soumyadeep Mukherjee
Sourav Bhowmik
Souvik Roy
Spondona Chattopadhyay
Sraman Majumdar
Sreeharsha t
Sri S
Sridhar Venkiteswaran
Srijeet Paul
Srikanth Lakshmanan
Srinivas Kodali
Srinivasan G
Subhashis Banerjee
Subhiksha Kannan
Sudesh M Raghu
Sudipta Sarkar
Sudipto Ghosh
Sujata Patel
Sujeesh Babu
Sujitha Kannan
Sukanya Prakash
Sulakshana Nandi
Suma E P
Sumesh Marar
Sumod Hajela
Sunil S
Suranjan Sinha
Suresh chàndra joshi
Surfuddin A.M
Susan Dhavle
Susan Dhavle
Sushant Rao
Suvir Kaul
Swarneeka Rajeev Iyer
Swati Nirwal
Sweta Dash
Swetha Sritharan
Tanya Mahajan
Tapan Malhotra
Tara Murali
Tariq Qureshi
Tia Zakki
Vaibhav Mehta
Varsha Mehta
Vasundhar Boddapati
Venkateshan K
Venu Madhav Govindu
Venu Madhav Govindu
Vickram Crishna
Vidhya S
Vidhya S
Vidushi Marda
Vidya Subramanian
Vidyut Gore
Vignesh Balaji V
Vijay Dhama
Vinod Chemmat
Vinod Kumar.M
Vipin Nair
Vishaal Bhatnagar
Vishnu MV Nair
Vivek Ananth
Vivek N Mohan
Wg Cdr Kartar Sainani
Yash Aggarwal
Yash Suryawanshi
Yesha Tshering Paul
Zaina Kaif
amit singh
aruna rodrigues
harshika gupta
jatin gupta
joseph ND
mithun pk
ravi srinivasan
sam v
sana s
sanal v v
shaunak phadnis
vinay sreenivasa

We earnestly share the hope of all these signatories for a positive governmental response. It is crucial at the present time, when we are in this health emergency, that the government prioritizes easy access to vaccines.

Published By
Anushka Jain

Anushka Jain

Policy Counsel, IFF

Share this Update