Telangana’s Government Examinations Conducting Agencies (GECA) has floated a tender to acquire 500-6000 Biometric Registration devices for Attendance of Candidates at Examination Centers for a year. These devices will scan candidates’ fingerprints and carry out biometric authentication to ensure “transparency and accountability in examination process.”
As per the tender, at least one handheld/ tablet device, equipped with fingerprint registration and verification, face recognition, bar or QR code reader, will be deployed per every 150 candidates during different examination stages. Further, the identified bidder will have to maintain at least 10 percent spare devices in case of emergencies.
The GECA will also conduct a physical verification of the devices for which the selected bidder has to show minimum 2,000 biometric devices or required devices for exams where candidates are above one lakh at their local office.
What kind of data will be collected by the devices? Under the attendance requirement, an assigned ‘Biometric Officer’ or ‘Assistant Biometric Officer’ will register candidates’ index finger fingerprints of both hands, take their photograph and verify it against the preloaded candidates’ data for verification.
Data belongs to the GECA: Under the data privacy section of the tender, the government said, “All created, stored, database, processed, archived etc. data will be the property of Government Exam Conducting Agency. The data must not be used/transfer in any format without written permission /authorization from Government Exam Conducting Agency.” Similarly, the bidder is also directed to carry out all device-related work within the designated exam centres.
However, it does not mention how long the GECA will be allowed to retain this data. Under the Digital Personal Data Protection Act, 2023, there are only eight situations where the government can take the call of processing personal data, none of which include processing of data for examination purposes. As such, it is also unclear how the authorities intend to obtain consent of the candidates to collect their biometric data. The document also does not specify what measures candidates can take if they want the data erased – all of which should be specified in a privacy notice sent to candidates in advance.
Verification dubbed “impersonation control”: Branding the biometric-based verification as a form of ‘impersonation control’ during exams, the GECA laid down the following procedure:
The GECA will prepare a list of examination centres, dates and provide it to bidder 10 – 15 days in advance. Along with the exam date, the GECA will also provide centre-wise data like roll numbers, photos, names, exam shift, etc. of all registered candidates at least 7 – 10 days before the exam. During this time, the Regional Coordinator / District Coordinator in-charge of the devices will also provide a list of consolidated Biometric Invigilators to the GECA. One Invigilator will be assigned per 150 candidates. The Coordinator will also hand over the devices to the respective test centres at least a day before the exam.
On the day of the exam, the designated authority will scan the QR code and bar code on the candidate’s hall ticket to auto- fetch their details from the application database. If the QR/bar code is missing on the hall ticket, then the person will have to manually feed in the candidate’s information.
“Thereafter, Fingerprint/Photograph capturing of candidates by the device shall be done during the examination. All activities should be completed before conclusion of examination,” said the GECA, stating that these biometrics collected at the examination centre for the first Level-1 examination will be stored in the GECA application as well.
The candidates appearing in the second examination will be verified with already captured biometrics at first examination. Further, it will be the bidder’s responsibility to ensure a de-duplication algorithm across the database to avoid the duplicity of enrollment records.
Once the exam is over, the Regional Coordinator / District Coordinator will receive the biometric devices and send the same to the GECA along with confidential material.
Telangana’s penchant for biometric authentication during exams
A year ago in September 2022, the Telangana government had come up with a very similar tender that called for over 43 thousand biometric devices alongside more than a lakh CCTV cameras to monitor activities of Telangana Public Service Commission aspirants. As with the GECA tender, the tender had called such verification ‘impersonation control’ to “make the process robust.” Moreover, a comparison of the data privacy clauses in the two tenders will show that although a national data protection law was passed between the release of these two tenders, the state government has taken no extra measures to protect personal data like biometrics.
Instead, we have seen a growing enthusiasm for such surveillance technology in education. In April, 2023 the government floated a tender to replace oral roll-calling with a facial recognition system for school attendance. The technology will be used for students and teachers alike with the system collecting a database of ‘facial templates’ of the persons being scanned at the time of user enrolment. What’s concerning is that while these measures are being taken to allegedly ease the administrative side of the education system, it is being done in the absence of any data or privacy awareness.
Children and government exam aspirants alike are unaware of the manner in which their data is collected and which databases it may be integrated in. For example, attendance data may easily be integrated into the ‘Education Ecosystem Registry’ by the Education Ministry that seeks a unified system to track learner outcomes. Until the government ensures adequate awareness among these data subjects, such tenders should have more details on the data security ad data privacy clauses.
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