The Myanmar government in 2014 announced a public consultation on mandatory SIM Card registration. This is a global trend: 161 countries require it as of 2021, of which 14 require biometrics.33 In 2014 MCRB submitted comments calling for the human rights impacts to be considered.34 This included the risk of excluding groups who do not have ID cards from access to essential services provided by phone, and the risk of providing an enhanced ability to track and monitor users, undermining their right to privacy and freedom of expression. This is a particular risk in countries such as Myanmar where legal safeguards for privacy and data protection are inadequate (see above). Since 1 February 2021, the human rights risks for users have heightened, since public security appear to be tracking user location based on SIM card use, leading to searches and arrests of opposition activists and journalists. 35 Following the 2014 consultation, the government proceeded with the SIM Card registration requirement, based on individuals uploading a scan of their ID/passport or registering in a shop.36 When the impact on users without ID became evident, some flexibility was provided in terms of documents which users could upload where they did not have a CSC or passport (e.g. attestation of identity from a local official). The Post and Telecommunications Department announced that from 1 April 2019, each CSC card holder could only have a maximum of 2 SIMs per mobile operator (as there are 4 operators, this means a maximum of 8 SIM cards per person). However, a review of the registration databases held by companies in 2020 showed that in some cases several hundred SIM cards were registered to a single ID, probably by a reseller.37 This risks an individual having their ID incorrectly associated with another user’s activity. There were also suspicions that many SIMs were registered to fake IDs. Over 34 million unregistered and multiple-registered SIM cards were deactivated after 30 June 2020, during the COVID pandemic.38 In a resumed attempt to resolve the issue of multiple registrations and document fraud, the Post and Telecommunications Department (PTD) in 2019 developed plans to tender for a biometric database, capable of holding up to 70 million biometric records. It emerged that the costs of this database would be funded by the Universal Service Fund (USF), which was set up to increase access to mobile data for underserved areas and populations, but has not been spent on its intended purpose.39 Tender documents prepared by PTD in 2020 stated that the data to be collected would be ‘name, left and right thumbprints, identity type, identity number and scan of identity card on both front and back sides’, and possibly the person’s father's name, date of birth and address. Copying the same data that are found on a CSC card for a database based on biometrics is not necessary, or consistent with a data minimisation 33 https://privacyinternational.org/long-read/3018/timeline-sim-card-registration-laws MCRB calls for Further Consideration of the Impacts of Requiring SIM Card Registration in Myanmar, 21 May 2014 35 In May 2022, the SAC spokesman confirmed that they intended to require importers to register the International Mobile Equipment Identifier (IMEI) of devices. An IMEI is linked to the physical devices and remains the same throughout its life. It was claimed that this was to prevent import tax fraud. The significant lost tax revenues associated with mobile phone smuggling were documented by EuroCham Myanmar in 2019 amounting to $1.6 billion of an estimated $2.4 billion lost. It is unclear whether this registration will be connected in any way to the subsequent purchaser .Since phones may be shared, resold or passed down in families, it is not an accurate indication of the individual user. 36 Mobile Users Must Now Register SIM Cards With Government, Myanmar Insider, 19 October 2016 37 Announcement on systematic re-registration of SIM Cards, Myanmar Digital News, 23 February 2020 38 Telecoms ministry says it has deactivated more than 34 million SIM cards Myanmar Now, 27 October 2020 39 Myanmar diverts special telecoms fund to biometric database, Myanmar Times, 11 June 2020 34 10