Category Archives: UK

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.

West Cheshire College. Nothing to hide? Then nothing to fear, surely?

Youtube banning video Aug 8th 2013Well, it had to happen at some point.  West Cheshire College have joined the RFID Journal and Zebra Technologies in the need to erase evidence of their part in tracking children, using a real time location system, at West Cheshire College with active RFID for 3 years since 2010.

West Cheshire College contacted Youtube about ‘copyright infringement’ on the video posted on our channel detailing their RFID tagging of students.  Presumably any copyright infringement is on images of the college not the content of RFID tagging the kids, as the college never claims to have ‘accepted‘ the technology stating they were only trialing tracking students (for whom?) with RFID that they used for 3 years.

Does West Cheshire College’s intervention in yet more removal of evidence from the internet of RFID tagging children at the college fan the fire of an attempted cover up?  Along with the of removal of press releases, articles and video by the RFID Journal and Zebra Technologies on the same topic, I’m not quite sure what else it does suggest really.

What is the cost of active RFID UWB tagging students at West Cheshire College?

You’d have though some simple questions on cost and funding may have been easy to answer, especially when you are investing in a state of the art, military standard, ultra wideband RFID tagging system for tracking children in real time?   It would seem not.

UWB RFID tracking students at West Cheshire College

West Cheshire College, according to the RFID Journal, started tracking students in 2010 with active RFID tags emitting a radio frequency signal, over 300 feet every second, to sensors around the college to pinpoint the students position to an accuracy within 1 meter – featuring some of most sophisticated RFID capabilities on the market. 

According to the college, the Chief Executive/Principal, a role held by Sara Mogel, was responsible for the New Buildings project at the College under which the RFID tracking system was installed.   So great a return on investment the RFID system proved to be, that the college’s Business Area Services Manager, Kevin Francis, went to Florida, USA, in April 2012 to give a presentation at an international RFID conference of how successful UWB RFID was at tracking kids.

So how much does this cost the British tax payer and how was the RFID and was funded?   To cut a very long exchange of  Freedom of Information Request (FOIR) and West Cheshire College’s replies short (which can be read here) apparently this is how a state of the art RFID student tracking system is procured at one of the UK’s largest Further Education colleges: 

Finance – West Cheshire college cannot be clear if the system was purchased, if it was purchased they cannot  find the cost.  The word “impossible” was used.

Implementation  – The college does not hold nor can provide any documents or records whatsoever on any discussions about the implementation of the RFID system.

Supplier – The college claim they have had no contact with the supplier,  Zebra Technologies, at all.   Zebra had on their website a videoOptimising the learning experience with a Zebra Location Solution” of the college, staff and students promoting the real time student tracking system.   This would seem to highlight that a company can film the college, staff and students without contact with the college at all.

Lack of Information – Members of staff that have left have been cited as a reason for the college not being able to provide information under its obligation to the Freedom of Information Act.  

Staff trip to Florida – West Cheshire College hold no documents or records about sending a member of staff to another continent to present the college’s use of UWB RFID to the RFID industry.  The college states that “In such cases there are no costs presented to the college and all matters are settled by the sponsors.”   Does this apply to this case/trip?  They have no documents on it either way, so maybe not?  Who knows?

Against RFID in schools

Student Consent and privacy -The college cannot be clear on how consent from students has been gained, whether any privacy impact assessments have been carried out.  They could not be clear on the specification of the RFID used to track the students.  These unanswered questions on consent and privacy, asked under the Freedom of Information Act, are now lodged  as an official complaint with the Information Commissioner’s Office.

Either West Cheshire College’s understanding of the Freedom of Information Act is extremely poor or the college’s answers under the Freedom of information Act raise some serious questions about what is going on at the college as a whole.  If West Cheshire College’s responses under the Freedom of Information Act are to be believed – which they must as the college has obligation under the law to respond truthfully – then practices at the college appear to highlight serious breaches of student consent, privacy, audit trails, accountability, transparency and security.  This would be quite astonishing.

The seriousness of child/student welfare should be of absolute paramount concern to any educational establishment acting in parentis locus and replies given under the Freedom of Information Act must be taken seriously – to this extent the Information Commissioner’s Office who oversees the Freedom of Information Act and Data Protection Act has been made fully aware of this situation.

We will let the penultimate slide of Kevin Francis’s presentation to the RFID Industry last April 2012, sum up:   “West Cheshire College – a first in the Education sector”