Promoters of the CovidCard Bluetooth contact tracing technology have increased their efforts to obtain a government commitment to their $100 million novel and unproven proposed solution.

They make a good case and have convinced some high-profile commentators and observers to add their voices in support.

But their business case raises many more questions than it answers.

Any contact tracing technology will involve significant privacy implications. If the technology is going to be effective, and assist manual contact tracers, and allow economic activity to continue at a higher rate than would otherwise be the case, then it is worth assessing and determining how to obtain those benefits, while minimising any risks to privacy and civil liberties.

The CovidCard proposal has hurdles to jump before it even gets to that “is it going to be effective” start line and some real challenges to overcome were it to get a green light for implementation. A universally distributed device to aggregate data from friends, associates and strangers 24 hours a day, seven days a week, by every person in the country raises issues of practicality and proportionality.

Here are my principal reservations.

Locked in technology

Knowledge about the pandemic, its features and what interventions would succeed or fail is growing as fast as the disease is spreading. Thousands of academic papers and government studies are appearing every month.

The thinking behind the CovidCard has not changed significantly since I was first briefed on the concept in March. That thinking predated the unprecedented joint Apple/Google exposure notification system that is being trialled by some countries. Software solutions to assist with contact tracing can iterate and improve as we understand their strengths and weaknesses.

While many other countries are experimenting with a wide variety of quickly adapting software solutions, only New Zealand is actively pursuing a universal piece of hardware for distribution to the entire population as a principal means of defence against the virus. (Singapore has recently begun to distribute a device to those who do not have or wish to use a mobile phone).

The CovidCard would be designed based on what we know today and we would be stuck with that for a year with no ability to adapt or change or learn from the experience of other countries, or of how the card operates in New Zealand.

Government or business mandate

The CovidCard paper glosses over the legal framework that would be required to support a universal card-carrying policy, but clearly the promoters believe carrying the card should be compulsory. A “government mandate” means no less. This would be a significant legal and cultural change for New Zealand society. The only current obligation to carry any kind of government-mandated card in public is the obligation to carry a driver’s licence while driving.

How is this to be enforced? Are people to be stopped by Police and asked to show their card? Must they be able to prove it is theirs? What will be the penalty for being in public without the card?

The “business mandate” is barely less troublesome. The thinking is that business and industry would club together for the good of the economy to agree that their goods, services, and premises are only available to customers or patrons who can show their CovidCard - or any CovidCard.

What happens when you’ve left your card in your other jacket when you go to the supermarket or restaurant? Will cash-strapped small businesses really exclude paying customers when there is no evidence of community spread of the disease, just because they do not have their CovidCard? Should they? What happens when people lose their Card? Are they condemned to social and commercial exclusion until a replacement can be issued? Or will they borrow someone else’s? Will a black market in counterfeit CovidCards develop for those who don’t wish to or can’t use the real thing?

Registration and issuance logistics

Also barely discussed is the mechanics of issuing and distributing the CovidCard. We know the proposal is for a card to be issued to every person in New Zealand, and that each card should be registered to that person in a centralised register of the team of five million. That register must include contact details.

What will be the initiating dataset? We do not have a population register in New Zealand. Probably the closest and most accurate record of individuals is maintained by Inland Revenue, but even IRD struggles to maintain up-to-date address details.

Who do we send the CovidCards to? At what address? How do people who do not receive one access their card? Do people have to prove who they are to register their card? How do they do that? How do you prevent duplicates being issued? Does it matter?

Behavioural efficacy

The promoters of the CovidCard have tested their technology and it still faces challenges. The exchange of Bluetooth IDs will not work well unless the card is on a lanyard around the wearer’s neck. It might not be as effective in a pocket with a phone. It probably won’t work in a handbag.

No testing has been done to determine whether a widely diverse population will wear the card routinely in a compliant fashion. 

Conclusion

There is no doubt that technological aids will be able to improve the speed and effectiveness of contact tracing processes. The CovidCard solution might have a role to play but it will not be a silver bullet. Government Ministers will need to consider what if any role that might be, and the relative strengths and weaknesses of the alternatives. From a cost/benefit perspective, how much more effective could the existing manual contact tracing process become if the CovidCard’s $100 million price ticket was invested in enhancing and improving those resources?

My Office will continue to participate in the conversations about the trade-offs involved in different solutions. For CovidCard to be among them, there are many questions yet to be answered. It may be there are compelling answers to be given. When we see those, we too will lend our support to this innovative proposal.

Image credit: Contact tracing, explained - Vox

International, Covid-19