A/HRC/43/29 31. In recent years, many States and international organizations have moved towards adopting comprehensive digital identity systems. Often, new digitized identity systems are accompanied by legal obligations to enrol; in other cases, enrolment is made a requirement for accessing services, including public services, social security and food aid. The World Bank, with its Identification for Development campaign, and other organizations have launched broad programmes to promote access to identity documents, with a strong focus on digital technologies. Such initiatives are often designed as a response to the target 16.9 of the Sustainable Development Goals, under which States have committed to providing legal identity for all, including birth registration. 32. While implementing such systems may help tackle many challenges, it is important to carefully consider their potential and actual impact on the enjoyment of human rights, both positive and negative. 33. One major concern linked to comprehensive digital identification systems is that these systems can themselves be sources of exclusion, contrary to their purpose. Costly or difficult registration requirements, for example, may prevent poor and disadvantaged populations from fully participating in an identity system. Women in some regions face legal or customary barriers to obtaining official identification. A lack of Internet connectivity, needed for online authentication, also can contribute to exclusion. Older persons and members of some occupational groups performing mostly manual labour may have difficulties providing fingerprints that are clear enough for the purposes of the identify systems. Services that require authentication at the point of delivery create problems for older persons or persons with disabilities who may not be able to travel. Difficulties also arise when the name and gender in identity documentation are not properly reflected in the identity system, exposing people with non-binary gender identity to particular risks. Lastly, exclusion can also result from a particular group being given identity documents that are different from those of others. 18 34. Comprehensive identity systems can also have a significant impact on the right to privacy, which in turn may lead to adverse impacts on a broad range of human rights and sustainable development. Digitized identity systems face great challenges regarding the security of the personal data collected, stored, shared and otherwise processed. Databases with information on millions of people are highly sensitive and attractive targets for attacks by criminal actors. Data breaches of any kind can facilitate identity theft, the consequences of which can be dire for the individuals concerned (A/HRC/39/29, para. 14). If the data collected contains biometric information, which is inseparably linked to a particular person and that person’s life, the harms of data breaches can be irreparable. 35. When not properly designed, implemented and run, digitized identity systems tend to collect, analyse, share, merge and otherwise process more data than may be strictly necessary for legitimate system purposes. The accessibility of personal data to a range of government entities (and possibly other actors) may pose certain risks. Integrated identity management systems can facilitate access to personal information across the Government and enable the linking of individual records across disparate data registers, potentially facilitating tracking and monitoring of individuals without sufficient legal justification in violation of the rights to privacy and to freedom of association. 36. The Human Rights Council has called upon States to take appropriate measures to ensure that digital or biometric identity programmes are designed, implemented and operated with appropriate legal and technical safeguards in place and in full compliance with international human rights law (Council resolution 42/15, para. 6 (m)). The World Bank has provided guidance for designing digital identity systems and implementing the required technical, legal and institutional framework, the key principles of which include universal coverage and accessibility, robust and secure design that protects privacy, and 18 8 See, for example, Alan Gelb and Anna Diofasi Metz, Identification Revolution: Can Digital ID Be Harnessed for Development?, (Washington, D.C., Center for Global Development, 2018, pp. 127– 134.