Sign the Open Letter: Preventing the Creation of a De Facto National Digital ID for Children

To: Bridget Phillipson MP, Secretary of State for Education

Cc: The Parliamentary Under-Secretary of State for Children, Families & Wellbeing

Cc: Members of the House of Lords considering the Children’s Wellbeing and Schools Bill

Dear Secretary of State, Ministers, and Members of the House of Lords,

We are writing to express serious concern about the mandatory use of the NHS number as a universal identifier for children, which risks establishing a de facto national digital ID starting with children, via the Children’s Wellbeing and Schools Bill. While the Bill’s stated aim - to improve children’s wellbeing and safeguard those at risk - is one we fully support, the mechanism chosen poses profound risks to privacy, autonomy, and trust in public services.

Digital ID Risk

The proposal meets all the functional criteria of a national digital identity system:

• Unique, lifelong identifier: The NHS number is permanent and already used across health services. Under the Bill, it would become a “consistent identifier” across health, education, and social care, effectively linking multiple records for each child.
• Compulsory cross-sector linkage: There is no opt-out, making participation mandatory and expanding state access to personal data without consent.
• Precedent for lifelong tracking: The NHS number is retained for life. Attaching it to education and social care data creates a persistent, linkable record of a child’s interactions with the state, accessible into adulthood.
• Pilot enables incremental expansion: Ministers have explicitly stated the identifier’s use will be tested and potentially expanded if additional “benefits” are realised (Committee Stage, 23 January 2025). This sets the stage for broader adoption without new legislation.
• Alignment with UK digital ID strategy: The Cabinet Office’s Digital Identity and Attributes Framework promotes cross-sector reusable identifiers. The Bill effectively implements this for one cohort - children - laying the groundwork for future population-wide extension.

Taken together, these features mean that the Bill, if enacted as currently drafted, would create a centralised, government-controlled digital ID system for children under the guise of safeguarding, with the potential to expand further over time.

1. No right to opt out

The Bill would mandate the use of the NHS number as a unique identifier across services, without any mechanism for consent or objection. Parents, carers, and children themselves would be unable to opt out. This represents a major departure from current practice, where participation in data-sharing is typically limited and consent-based.

2. Centralisation and scope creep

For the first time, the Bill would link the NHS number to a centralised dataset containing educational, social, and welfare records. This allows “ever-expanding databases” open to repurposing and scope creep. Government statements suggesting that scope expansion is “desirable” only heighten these risks.

“We have purposely prioritised linking use of the consistent identifier with safeguarding and welfare functions… If additional benefits are realised, we can obviously explore the provisions further.”

— Catherine McKinnell MP, Committee Stage, 23 January 2025

3. Predictable but harmful unintended consequences

Families seeking to avoid scrutiny or who have had negative experiences with state agencies may become reluctant to access healthcare or support, undermining the very safeguarding aims the Bill pursues. Paradoxically, those most “at risk” may be least likely to be “caught” by such a system if they have limited interaction with the state or no NHS number.

4. Weak and evasive assurances

Government assurances on data security and prevention of scope creep have been inadequate or ambiguous. The Bill lacks:

• Clear statutory limits on how the identifier may be used or shared;
• An independent oversight mechanism;
• A requirement for a Children’s Rights or Data Protection Impact Assessment;
• Any route for parental or child consent, appeal, or redress.

Without these safeguards, the proposal risks normalising a national digital ID for children with long-term privacy and civil liberty consequences.

5. What we are asking

We therefore call on:

• The Government to withdraw or substantially amend the digital identifier provisions, including a right to opt-out at absolute minimum;
• Members of the House of Lords to table and support amendments ensuring:
  • That the NHS number cannot lawfully serve as a general national identifier;
  • That any cross-departmental data linking requires informed consent, independent oversight, and a published impact assessment;
  • That children’s rights to privacy and autonomy are explicitly protected in statute.

We further ask that the Government publish, before Report Stage, a Children’s Rights Impact Assessment addressing these concerns and clarifying the intended data-governance framework.

6. In defence of children’s rights and public trust

The House of Lords has long served as a constitutional safeguard against overreach in matters of civil liberty. We urge Peers to ensure that this Bill’s good intentions do not open the door to a permanent, state-controlled digital ID infrastructure, starting with children. Protecting children’s wellbeing must never come at the cost of their privacy, dignity, or trust in public institutions.