BIBA response to DVLA Trial of Smart Card Provisional Driving Licences – Public Consultation

9th January 2008

The British Insurance Brokers’ Association (BIBA) is the UK’s leading general insurance intermediary organisation. We represent the interests of insurance brokers, intermediaries and their customers.

BIBA represents 2,300 insurance intermediaries including 98 of the UK’s top 100 insurance intermediaries. Our members handle about half the value of all UK home, contents, motor, travel, commercial and industrial insurance policies. Independent insurance intermediaries distribute nearly two-thirds of all UK non-marine general insurance, of which BIBA members account for more than 80%. They also introduce £20 billion of premium income into London’s insurance market each year.

BIBA is pleased to have the opportunity to respond to the DVLA Consultation into thetrial of smart card provisional driving licences on behalf of its’ collective membership.

Our responses to the 13 questions set out are as follows:

  1. Do you understand and agree with the trial approach?

  2. Do you agree with the reasons for restricting the trial to Welsh Provisional Driving Licences? Yes

  3. Do you agree that only the information printed on the face of the card should be written to the microchip?
    Yes, as the purpose of this change is to prevent fraud in respect of driving test candidates being fraudulently represented and to be used by police on the roadside (3.9). No other information is necessary.

  4. Do you agree that the ‘microchip’ should be rendered read-only?
    Yes, we believe it is very important that the chip is read only to prevent fraudulent changes.

  5. Do you think the Departmental route for funding is most appropriate?

  6. Do you consider that the risks identified above have been correctly assessed?

  7. Do you think there are risks that we have not included above?
    Failure of the microchip (what is its guarantee period?) and fraud are the two main concerns.

  8. Do you think remote authentication will be of benefit to drivers and / or to the commercial companies with whom they interact? What uses would be most beneficial?
    The paper talks about this operating in exactly the same way as credit/debit cards – however the UK is experiencing record levels of fraud in this area. Therefore we would urge extreme caution regarding remote authentification.
    We would also like to take the opportunity to comment that it is still important for insurance brokers to view the paper counterpart driving licence to check convictions. The fees DVLA want to charge for the fee enquiry service (£4.00 for the on-line service and £6.00 for the telephone/paper service) are too high for brokers to be able to afford to systematically check every drivers licence details automatically. This paper talks about a fee paying service for these remote enquiries. Insurance brokers play a valuable role in reducing driving licence fraud and we would like to highlight the fact the other direct gov and ask MID websites do not charge for similar enquiries. We would urge DVLA to consider waiving charges to authorised remote users in the interest of reducing fraud.

  9. Do you think electronic transfer of microchip data under the control of individual drivers would be beneficial?
    If this data were only available to DVLA, Police and Courts to populate their systems then that would save resources. However concerns still exist as to the potential for fraud if other unauthorised parties are able to access the data.

  10. Would you like to see a facility to record optional (non-driver related) data held on the microchip if the cardholder had a choice on what data they wanted included and the data was held in a separate, secure, re-writeable area on the microchip?

  11. What data do you think would be useful?
    We believe data should be kept to the bare minimum. There have been highly publicised issues of data loss from government in recent times and we believe that information should be restricted to the core licence information, relating back to the original reasons for these proposed for the changes – to prevent/reduce fraud, not for a commercial opportunity or any other purpose.

  12. Do you think the address should be on the card and the microchip, the microchip only or stored only by DVLA on the main database?
    The address is an integral part of the driving licence; Insurance brokers use this to help prevent licence fraud. We would like to see it on the cards and the microchip and stored by DVLA on the main database

    Also from a financial crime perspective a lot of financial firms use the driving licence as a means of fulfilling their KYC (Know your customer) obligations which are designed to mitigate money laundering and terrorist financing. The prospect of removing the address from the licence might as a result prove an unpopular move with those firms.

  13. Would you see this optional (but chargeable) retention of address on the Driving Licence as an attractive or viable option to pursue?
    No, the address is a vital basic part of the driving licence and should be compulsory and NOT chargeable for any changes.

    BIBA would request that they be included on any further DVLA consultation papers or communications in respect of this subject going forwards.

Thank you for taking the time to consider our response. If you have any further queries please contact Graeme Trudgill BIBA’s Technical and Corporate Affairs Executive for further information on 02073970218 or [email protected].

Yours sincerely

Graeme Trudgill

Technical and Corporate Affairs Executive
Direct Tel: 020 7397 0218
Direct Fax: 020 7626 9676
[email protected]