Further, a smart phone application used in the lead up to the 2020 general election, to provide voters with information about candidates, was widely criticised internationally for using ethnic identifiers that listed Rohingya candidates as "Bengali". The app was developed by Swedish organisation, International IDEA, which provides support to electoral processes and was funded by the EU, Asia Foundation and STEP Democracy. Human Rights group, Justice for Myanmar, described these organisations as “complicit in the erasure of Rohingya identity”. 133 Perhaps the clearest warning, is administrative violence and genocide risks associated with Myanmar’s National Verification Cards, which at different stages of their evolution, have been endorsed by various international actors, including the EU and the UN Special Envoy on Myanmar.134 Data collection and the issuance of NVCs, have been closely associated with mass expulsions and the deliberate infliction of statelessness on Rohingya since 2016. Firstly, NVCs are understood by many Rohingya to lock in and entrench a foreign and stateless status for Rohingya in Myanmar, thus further producing and legitimising exclusions. Secondly, NVCs have been enforced by inflicting conditions of life on Rohingya that make survival in Myanmar without them almost impossible – whereby they cannot access livelihoods, nutrition, or healthcare without them. With paper NVCs, the Myanmar government was able to control most of the necessary livelihood activities, a digital version would allow the government to further extend these capabilities. Thirdly, the enforcement of NVCs and national verification has been directly associated with the devastating genocidal violence of 20162017.135 All these factors should raise alarm bells for the international agencies and corporations planning to invest or provide financial or technical support to digital identification systems in Myanmar. Digitised Identification Systems in Myanmar: Another Tool of Persecution and Exclusion? Within the context of the divisive national verification process, the collection of biometric data was piloted in Rohingya areas of Rakhine in 2015. In many cases NVCs are issued but they do not lead to applications for citizenship verification. The cards are instead used by holders since they are required to move within the area and access work, markets, healthcare and family life. Biometric data was collected as part of the broader national verification project, but was not linked to ID cards or utilised in other ways.136 Reports from Maungdaw district are that currently biometric data is not collected for the purpose of issuing NVC cards, which are still paper-based. However, those who attempt to apply for citizenship including submitting supporting documents, are reportedly asked to provide fingerprints and iris scans for use in future citizenship cards, but not NVCs.137 Rohingya have expressed concerns that country-wide implementation of biometric IDs under the existing laws may further enable Myanmar’s discriminatory and persecutory policies that target them. It may lock in an imposed foreign or stateless identity, make access to lands and livelihoods even harder, and further lock in the structures of segregation and apartheid.138 A centralised and permanent database that registers citizenship and retains biographic and biometric information could erase Rohingyas’ ethnic identity, mark them as foreigners, or undermine their claims to belong the Rakhine region of Myanmar, which is understood to be a key element of the ongoing situation of genocide in Myanmar.139 The Independent, ‘Ethnic identifiers in Myanmar election app criticized’, (October 2020) available at: https://www.independent.co.uk/news/ethnic-identifiersmyanmar-election-app-criticized-myanmar-rohingya-democracy-bengali-controversy-b740573.html [accessed 11/11/2020] 134 Burma Campaign UK, ‘UN Special Envoy should drop ‘appalling’ support for NVC Process’ (2019) available at: https://burmacampaign.org.uk/rohingya-crisisun-special-envoy-should-drop-appalling-support-for-nvc-process/ [accessed 11/11/2020]; Burma Human Rights Network, ‘National Verification Cards: A Barrier to Repatriations,’ (2019) available at: http://www.bhrn.org.uk/en/report/1090-national-verification-cards-a-barrier-to-rohingya-repatriation-full-report.html [accessed 13/11/2020] 135 For more information on how NVCs were associated with genocidal violence in 2016-7, see N. Brinham, ‘"Genocide cards": Rohingya refugees on why they risked their lives to refuse ID cards’ Open Democracy (October 2018) available at: https://www.opendemocracy.net/natalie-brinham/genocide-cards-why-rohingya-refugees-areresisting-id-cards [accessed 13/11/2020]; See also Fortify Rights, ‘"Tools of Genocide": National Verification Cards and the Denial of Citizenship of Rohingya Muslims in Myanmar’ (2019) available at: https:// www.fortifyrights.org/downloads/Tools%20of%20Genocide%20-%20Fortify%20Rights%20-%20September-03-2019-EN.pdf [accessed 13/11/2020] 136 A forthcoming briefing from Privacy International sets out what is known to date about the new digital ID proposal in Myanmar and raises some specific concerns based on Myanmar's current citizenship regime and ID system. 137 Information provided by Rohingya researchers in North Rakhine State (names withheld) 138 Amnesty International, ‘Caged without a Roof: Apartheid in Myanmar's Rakhine State’ (2017) available at: https://www.amnesty.org/en/documents/ asa16/7484/2017/en/ [accessed 13/11/2020] 139 UN News, ‘Genocide threat for Myanmar’s Rohingya greater than ever, investigators warn Human Rights Council’ (September 2019) available at: https://news.un.org/ en/story/2019/09/1046442 [accessed 13/11/2020] 133 25