Final update on West Cheshire College RFID tagging students

Public Acc CommAfter nearly a year of being quiet about West Cheshire College tagging their students with RFID, a final update to round the story off as there have been some happenings behind the scenes.  The monetary spend of £1,050,242 on ultra wideband RFID that ‘failed’ in it’s job to monitor the students, despite it being used by the military, is the language that speaks to UK parliament.  The civil liberties lost and invasion of privacy the 14-19 year old, blissfully unaware, students suffered were ignored by the establishment.

The Information Commissioner’s Office (ICO) did their job well in ensuring the college met it obligations under the Freedom of Information Act.  It took time for me to get answers to my Freedom of Information requests but I got what information the college had in the end after involving the ICO.  There was a distinct change of attitude with regards to co-operation from the college when there was a change of Principal early in 2013, maybe that is coincidence.

In February 2014, Tom Watson MP asked three written questions in parliament to the Department of Education about West Cheshire College’s use of RFID tagging students.  As expected the Department of Education knew nothing about this.  Hansard references here: Feb 4th, Feb 6th and Feb 10th.

After learning, from Freedom of Information requests, that the college had spent over a million pounds on untested, uncosted, undocumented, unstandardised RFID I contacted the Public Accounts Committee to report the cost.  They passed the enquiry onto the National Audit Office who carried out an investigation into the unusual accounting of this spend.  On the 10th November 2014 I received a letter from Margaret Hodge MP who oversees the Public Accounts committee:

“Inquiries made by the National Audit Office of the Skills Funding Agency suggest that the Agency have no knowledge of student tracking systems in operation at further education colleges.  I understand from your previous communication that you have already received confirmation from the Department of Business Innovation and Skill and the Department of Education that they do not hold specific information on the tracking system in question and they they are not running and programmes to introduce such systems more widely in schools an colleges.

The National Audit Officer have highlighted to me previous weaknesses in the arrangements to access and manage capitol funding bids from further education colleges.  At about the same time that West Cheshire College would have made its bid for new buildings broader concerns began to emerge about the then Learning Skills Council’s (LSC) overall management of the capitol programme.  These concerns were brought to light in critical reports by Sir Andrew Foster and the Education Select Committee.

The LSC was disbanded in 2010 and it’s responsibilities, including management of further education capitol investment programme, were assumed by the Skills Funding Agency (SFA).  A Cabinet Office review of the SFA’s investment programme in 2013 reported that the criteria for distributing grants had been developed in a way which promoted value for money.

In the absence of any further evidence of a wider problem the National Audit Office is not planning to undertake any further inquiries at this time.

So a botched spend on flawed technology, mismanaged by the college and the government?  Or the RFID industry using UK students at West Cheshire College, wearing RFID supplied and pioneered by Zebra Technologies, for the IEEE 802.15 4f standard approved February 2012, which Tim Harrington, the Vice President of Zebra Technologies, sat on the IEEE 802.15.4f working group on?

Whatever it is or is not the sorry episode is done, with students and parents non the wiser it ever happened.  This practice of tagging students with RFID is common in the USA, let us hope the UK does not follow suit.

Missouri bans tracking RFID in schools

Missouri bans tracking RFID in schools.  In the first of its kind legislation, Missouri Senator Ed Emery‘s bill was passed last week.  Ksn.com reports that “The bill will take effect in October after lawmakers overrode Gov. Jay Nixon’s veto of the bill this past week, just barely getting the required two-thirds majority in both chambers.

The bill, SB523, simply reads:

1. No school district shall require a student to use an identification device that uses radio frequency identification
technology, or similar technology, to identify the student, transmit information regarding the student, or monitor or track the location of the student.
2. For purposes of this section, “radio frequency identification technology” shall mean a wireless identification system that uses an electromagnetic radio frequency signal to transmit data without physical contact between a card, badge, or tag and another device.

SB523Many schools in the USA track their students using active RFID which is a chip powered by a small battery and emits a regular pulsed radio frequency signal.  Readers then pinpoint the location of chip, thereby identifying the child’s whereabouts.  Wearing such a device is huge invasion of privacy of the children potentially being able to be seen in sensitive areas such as washrooms, school nurse, etc.

The technology is not without controversy.  One student, Andrea Hernandez in San Antonio, refused to wear the chip on religious grounds and was excluded from her high school as a result.  The somewhat extreme action by the school gained international exposure and support from privacy groups.  After a year of running the RFID locator programme the scheme was scrapped.

The excellent ‘Position Paper on the Use of RFID in Schools‘ sets out the concerns with using this technology with children and heartening to see that Missouri have taken this on board and banned tracking RFID in schools.

4 mile tracking RFID to be piloted on children in US school distict

The RFID Journal reports that a company in California, Iotera, is developing a 900MHz RFID tag that has a 4 mile range and that “a school district will use it to track students arriving on campus or traveling to and from school“.  Rather than just being able to track students on campus this new geographical tracking takes tagging children one step further.
Iotera child case study
Iotera have visions of smart cities with the Internet of Things (IoT) long-range “sensors to increase safety and efficiency” – in this company’s eyes this involves tagging humans.

The figures on how dangerous it is for children attending school are unknown but it seems that participating in the activity of schooling is relatively safe otherwise why would governments insist children attend school and parents willingly send them?  There is inherent risk in all activities humans do and carrying RFID chips, emitting frequencies that have unquantifiable health effects and “smart”ing cities up, bathing us all in electrosmog does not sound any safer than the situation we have now – where children are free of RFID tags.

With the possible risk to health of carrying emitting RFID and the added risk of other people tracking RFID tags that children carry, by hacking into their RFID emitting signal, the “increase safety” that Iotera claim is disputable.

But yet again we see the next generation via school being conditioned to use technology and be advised it is for their safety/convenience and learn that it is perfecting acceptable for others to track their whereabouts.  Apart from the risks mentioned above associated with carrying RFID technology, a recent article by Slyck NewsStudent Monitoring by Schools, is it Really Necessary or Far Too Controlling?” addresses the glaring privacy issues that surveilling the next generation raises.

With companies gearing up for the Internet of Things another company DecaWave also are preparing themselves with ultra wideband (UWB) RFID chips to monitor humans, stating that “children and infirm adults will be monitored for their safety and security“.  Their website goes on to say:  “And in the future, DecaWave’s chip will be incorporated into cell phones, tablets, and other mobile devices not yet thought of, to interact with our surroundings in ways not yet imagined.”

Many will embrace this ubiquitous living as convenient but as our privacy quickly becomes eroded so does the erosion of any form of freedom to protest against corrupt systems.  Do we have a right to refuse to use or would our anomalous behaviour flag us up non compliant citizens?

OBE for ‘RFID tagging’ ex college principal

Sara Mogel RFID taggin students

Sara Mogel OBE – was Principal at the first UK school, West Cheshire College, to use active RFID tags to track students on campus

Sara Mogel, ex principal of West Cheshire College.  The woman who thought it was a good idea to spend over £1million of taxpayers money on RFID tags to hang round students neck to track them in real time, gets an OBE for ‘for services to vocational education‘.

I think it is fair to say her contribution to UK education and the RFID industry is certainly unique, though whether it deserves an OBE is debatable.  She is responsible for the decision to hang microwave radio frequency devices around children’s necks in a ground breaking trial of ultra wideband RFID, tracking the children on campus every second.  The first instance of a school in the UK using RFID technology to track individual children’s every movements…  that was scrapped in February 2013 just before she left. (I wonder if the college got a £1,000,000 refund for this?)

No reporting in the local press.  No communication with parents.  The college had no idea of the specification of the RFID, worryingly therefore no information on the specific absorption rate (SAR) of the radio frequencies on the human body.  The health effects of radio frequencies (RF) on the human body are seemingly unquantifiable at present but as more research is done on this topic it is becoming more apparent that caution should be taken and prudencey exercised to limit our bodies to RF exposure.  The RFID journal themselves suggest distancing the human body 1 meter from a reader/antenna.

Let us sincerely hope that there will be no ill health effects from the students wearing RFID tags under Sara Mogel OBE’s watch at West Cheshire College and this does not come and bite her back in the future.

Ultra wideband RFID tracking children in the UK – an invasion of privacy?

West Cheshire College and its tagging of students with active RFID was reported in the The Guardian’s article from 19th November 2013 ‘Is UK college’s RFID chip tracking of pupils an invasion of privacy?

RFID tracking at West Cheshire College taken from the video made of the system by the supplier, Zebra Technologies

RFID tracking pupils at West Cheshire College taken from the video made of the system by the supplier, Zebra Technologies

It is only an invasion of privacy if one is fully aware of being tracked.  If the data subject is blissfully unaware of the ubiquitous technology it carries, then there is an ignorance of the invasion of privacy the RFID tag is perpetrating.

Parents of the students tagged with RFID at West Cheshire College had no knowledge their children were being tracked every second by an active RFID chip.  The college can provide no literature given to students about this and no privacy impact assessment was done.  The college can only “assume that information about RFID was also communicated verbally to studentsduring induction in which “the induction process is covered verbally with students”.

An adult pops a RFID tag round a child’s neck and assumes that this second by second tracking was communicated effectively, verbally during an induction?  The fact that not one student or parent objected to this rings warning bells.

Did no intelligent thinking adult at the college think that possibly, just quite possibly, that verbally informing students about electronically tagging them may bring up issues of consent from a minor and that perhaps this level of communication may leave the college vulnerable to criticism and, at the very worst, possible litigation.  And did no one there consider that electronically RFID tagging another human and viewing their location in real time is compromising their privacy, maybe even just a tiddy-widdy bit?

Apart from the invasive intrusion of an adult peering into where children are –  who they hang out with, when they are visiting the toilet, shower, school nurse – no privacy checks or advice from Department for Education, Information Commissioner’s Office (ICO), Children’s Commissioner or any legal body (see question 1 and 2) was undertaken by the college.

On top of the lack of regard to procedures concerning consent and privacy considerations, the college did not know when they started RFID tagging the children.  Really? – yes really.  Asked about when they started RFID tagging children, under a Freedom of Information Act request, the college replied that no information was held on this at all.  As this was a fairly surprising answer from the college, the Information Commissioner’s Office (ICO) who oversees the Freedom of Information Act, was asked to intervene.  Indeed, amazingly, West Cheshire College also confirmed to the ICO that they really did not (honest guv) have any information about when they started RFID tagging children there.

Bearing in mind that lying under the Freedom of Information Act is an offence and that “A person guilty of an offence under this section is liable on summary conviction to a fine“, we must take these answers from the college as gospel.

The Guardian article failed to mention cost which came in at £1,050,242 (ex VAT).  Over a million pounds of public money spent on a RFID human tracking system that there is no information about and that the college has now scrapped due to thesoftware would not communicate effectively to the current register system” and “escalating costs“.  A million pound spent on a RFID system the college cannot not even recall when implemented?

What an amazing, jawdropping sequence of events.  This could almost be made into the perfect example of a ‘what not to do when RFID tagging children in education’ handbook.  A truely epic fail.

So back to the question ‘Is UK college’s RFID chip tracking of pupils an invasion of privacy?‘ – most probably.  Here is the video of the system on Youtube – you decide.

RFID Journal – People should remain at least 1 meter (3.3 feet) from a RFID reader/antenna

RFID reader definitionThe RFID Journal is one of the world’s foremost sources of RFID news globally and has reported positively on the benfits of RFID tagging children and teachers in schools with active RFID.   On the 4th November 2013 this question was asked on their ‘Ask the Experts Forum’ – Are there any health risks with prolonged exposure to ultra high frequency (UHF) radio frequency (RF) fields?  

Interesting then when Mark Roberti, the Founder and Editor of the RFID Journal, then advises in his response that:

people should remain at least 1 meter (3.3 feet) from a reader.


Really.  How is it okay for the RFID Journal to report 
positively about schools tagging children and teachers wearing ultra high frequency (UHF) active RFID tags, effectively endorsing the wearing of active RFID chips, when they also comment on the very potential health hazards of radio frequencies?

RFID Active definitionIn the USA Northside Independant School District RFID tagged their student population with active 433MHz RFID tags from 2012 until 2013.  In Germany students and teachers wear active RFID tags compatible with wifi 2.45GHz, in the US the same tag is being worn by teachers.  West Cheshire College students in the UK wore ultra wideband (UWB) active RFID tags around their neck in a lanyard, emitting a 6.35-6.75GHz radio frequency every second, from 2010 until 2013.  West Cheshire College admitted to viewing students in “peer groups” with their RFID real time location system  – so not just for registration or safety reasons then?

Daniel Engels, “Director of the University of Texas at Arlington‘s Radio Frequency Innovation and Technology Center, and an associate professor in the college’s Department of Electrical Engineering” was quoted in a previous RFID Journal article from June 2009 entitled ‘Can RFID be harmful to the human body‘ stated that:

“The basic result of all of our work is that really close proximity to UHF [ultrahigh-frequency] RFID readers  [antennas] has potential health issues”

Should we be tagging children and teachers with active RFID when the  International Agency for Research on Cancer/World Health Organisation (WHO) has classified radio frequency electromagnetic fields as a possible carcinogen to humans, causing cancers and tumors?  Erm… I think that would be a no!

Maybe schools be prudent and ready themselves for possible litigation claims in the future…

RFID UHF definition   RFID Interrogater definition

A child consenting to be tracked should be given a choice, and what about the parents right to know who is tracking their children?

Against RFID in schools

Tracking capabilities as shown in their supplier’s video ‘Optimizing the Learning Experience with a Zebra Tracking Solution”

When a UK college recently used a RFID real time location system to track students on their campuses in Chester and Ellesmere Port from 2010 – 2013.  Apart from whoever thought this was a good idea somewhere in the tiers of the college management, how did the college manage to persuade the thousands of students it tracked, that this was a good idea too?  How did the students consent to staff being able to “… look at them [students and staff] in groups, such as peer groups.”  Locations being seen in, possibly toilets, showers, school nurse, etc?

In a reply to a Freedom of Information request, this is how the college gained fully informed consent – apparently “Information relating to the RFID tags and their purpose was covered during College induction/ enrolment.”

When pressed further on this consent gaining process the college refuses to answer questions.  Only when the Information Commissioner’s Office intervenes it is revealed quite how the college considers meaningful consent is gained from students to be tracked by an RFID tag ‘bleeping’ it’s whereabouts every second“we can confirm that the induction process is covered verbally with students. It is fair to assume that information about RFID was also communicated verbally to students”.

Erm, is that consent?

The college refused to answer a Freedom of Information request, December 2012, and upon an internal review *still* could not answer one question, which was a simply yes/no answer, as to whether or not staff were RFID tagged – astonishing.  Yet when pressed by the Information Commissioner’s Office, in July 2013 (full report here) the college replied, ‘staff badge tags remained inactive and were not in active use for any purpose. Staff who had a RFID badge for first aid purposes also had inactive badges’  (why would staff carry an inactive RFID for first aid? and why not state that initially?)

RTLS Mapping West Cheshire College

It’s difficult to see what is happening here – either a shocking inability of knowledge or lack of awareness of  responsibility to answer basic questions under the Freedom of Information Act.  But when children are tracked in this manner, literally their every move with the potential to be scrutinized, there should be absolute transparency.