Complaint about unnecessary efforts by librarians concerning NRIC verification

As of Apr 4, 2020, I haven't received a reply from the National Library Board. On Apr 4, it was announced that all public library would be temporarily closed until May 4. As a result, my complaint has become unnecessary because there is no access to the public library at all. 

From: Yan Jun
Sent: Thursday, April 02, 2020 11:53 AM
To: NLB Quality Service Manager
Cc: PDPC (qsm@imda.gov.sg); Straits Times (stforum@sph.com.sg); Lian He Zao Bao; AGC (AGC@agc.gov.sg); SPF Feedback Shared (SPF) (SPF_Feedback_Shared@spf.gov.sg)
Subject: Clause 23 of the PAPD and a reasonable effort

Dear Riza Rahman,

I refer to your email with regard to the legal basis for librarians’ collection of visitors’ NRIC number, or the Personal Data Protection Act (PDPA) 2012.

However, what I am complaining about is the unnecessarily duplicative efforts put in by the librarians to ensure the accuracy of visitors’ NRIC numbers. Such an action is against the Clause 23 of the PAPD and has caused serious inconveniences. Clause 23 requires a librarian to put in a reasonable effort but not extra efforts for the purpose of contract tracing.

I still wish to complain about Constance Lerh and Voanne Stewart in Bedok library. Although they were fully aware of my identity by checking my old NRIC, they still repeatedly asked for my NRIC and refused to accept my Passion Card that contained my accurate NRIC number.

The facts

On Mar 28, 2020, Constance Lerh refused to accept my Passion Card as a valid document for verifying my identity on the grounds that a Passion Card didn’t have a photo on it. While the bar code of a Passion Card did represent a person’s accurate NRIC number, Constance Lerh explained that she was unable to make an identity verification with my photo.  

However, she did accept the picture of a NRIC saved in a smartphone. When questioned what document should a visitor who has lost his NRIC produce, she answered a photocopy of the visitor’s NRIC.  In response to my reminder that a photocopy or a picture of a NRIC could be easily manipulated, she answered that act was a crime. I reminded her that the misuse of Passion Card in the current COVID-19 situation equally constituted a crime so she should accept the Passion Card, she didn’t reply. 

With regard to the legal basis for the production of NRIC, Constance Lerh was unable to give an answer. Later Sharon Heng, the manager of Bedok library, told me that the legal basis was the PDPA. Because she was unable to explain how PDPA had authorized the library to check visitors’ NRIC, Sharon Heng promised to email the answer to me later on.

Since the librarians in Bedok had already verified my identity by checking my old NRIC (an invalidated one), I asked whether I was allowed to use my Passion Card in the future. They firmly rejected my request. On Apr 1, librarians Constance Lerh and Voanne Stewart even threatened to stop me from entering the library if I refused to show them my old NRIC.

The issue and the analysis

The current issue is the standard of the care that libraries should apply to ensure the accuracy of visitors’ NRIC numbers.

Clause 23 of the PDPA deals with the accuracy obligation carried out by an organization. It provides that “An organization shall make a reasonable effort to ensure that personal data collected by or on behalf of the organization is accurate and complete, if the personal data (a) is likely to be used by the organization to make a decision that affects the individual to whom the personal data relates; or (b) likely to be disclosed by the organization to another organization.

If a librarian is fully aware of a visitor’s NRIC number, he is not in a position to conduct any verification procedure because he has already fulfilled his duty of care concerning the accuracy of this visitor’s identity. Under the PAPD, a visitor’s only duty is to provide his accurate personal data to a librarian. As for the final verification of a visitor’s NRIC number, it should be done by the police but a librarian in the strictest sense. It clear that most librarians have forgot about their duty to provide members of the public a place to read books. They exercise unnecessarily duplicative efforts for NRIC numbers has caused serious inconveniences.

In my opinion, a Passion Card is acceptable in this situation because most visitors are not liars and would not misuse their Passion Cards. Given the fact that the NRIC number isn’t written on a Passion Card, a librarian can make an identity verification by asking a visitor for his NRIC number instead of a photo verification. What the Personal Data Protection Commission asked for was visitors’ accurate NRIC numbers, which may not be taken from NRIC directly.

In line with my analysis is the requirement for visitors in other public places to fill out the health declaration form. While this requirement is also laid down in accordance the PAPD, visitors are not required to verify his particulars in the declaration form with his NRIC.

My request

I would appreciate it if the National Library Board takes my complaint seriously and reply to me. Please do forward my email and your reply to Bedok and Tampines library so I can avoid bitter arguments with them. Both managers and the librarian in Bedok and Tampines librarians are aware of me and my request.

I understand that the library management may not even think about the level of care librarians should exercise for collecting accurate visitors’ NRIC number. In fact, even police officers were unable to answer similar questions.

My intention

My intention is to eliminate unnecessary efforts made by librarians for the accuracy of NRIC numbers. NRIC certainly is the best option for identity verification but is not the only way.

I believe very few people would make reasonable effort to correct the librarians’ mistake. For that reason, I copy this letter to the PDPC, the Straits Times, Lian He Zao Bao, the AGC, and the Police. I think the Personal Data Protection Commission (PDPC) needs to pay attention to the issue raised in this email.

Thank you. I am looking forward to hearing from you soon.

Regards,

Yan Jun

(S7684361I)

From: NLB Quality Service Manager [mailto:qsm@nlb.gov.sg]
Sent: Thursday, April 02, 2020 10:51 AM
To: Medp1128@hotmail.com
Subject: RR2003005671: Feedback on PassionCard and PDPA NLB:0014005937

Dear Mr Yan Jun,

We refer to your feedback provided to staff during your visit to the Bedok Public Library on 28 March 2020. Your comments have also been shared with our management team. 

In view of the evolving COVID-19 situation, temperature taking and the taking down of personal particulars have been implemented as precautionary measures for the safety of our patrons. As contact tracing requires a high degree of accuracy, the NRIC or a photo ID is required.

Patrons are advised to present their photo ID cards to facilitate this and the information is displayed on our website www.nlb.gov.sg and social media platforms.

We would also like to share that it is stated on the Personal Data Protection Commission (PDPC) website (https://www.ifaq.gov.sg/PDPC/apps/Fcd_faqmain.aspx#FAQ_2110433), that organisations may collect personal data of visitors to premises for purposes of contact tracing and other response measures in the event of an emergency such as during the outbreak of the coronavirus disease 2019 (COVID-19). In the event of a COVID-19 case, personal data can be collected, used and disclosed without consent to carry out contact tracing and other response measures, pursuant to sections 1(b) of the Second, Third and Fourth Schedules to the PDPA, as this is necessary to respond to an emergency that threatens the life, health or safety of other individuals. As organisations may require national identification numbers to accurately identify individuals in the event of a COVID-19 case, organisations may collect visitors’ NRIC, FIN or passport numbers for this purpose. 

We seek your understanding and cooperation so that together, we can curb any further spread of the COVID-19 to the community, and make our libraries a safe environment for all.

Regards,

Riza Rahman

Officer

Quality Service Management

National Library Board.