required to access universal healthcare, get a passport, register as a voter, apply for a driving licence, register a mobile phone number, pay taxes, open a bank account and more. Communities warned that this system, popularly known as 'Huduma Namba', could have a devastating impact on those who had struggled to secure citizenship documentation. In January 2020, following a legal challenge by Kenyan civil society groups, the court ruled to stop the implementation of the scheme until a regulatory framework was in place to address data privacy and exclusions. ³⁰ As this paper evidences, the experiences of Rohingyas with the roll out of digital ID systems in India and Bangladesh provide further reasons for a cautious and rights-based approach, which must protect against discrimination and address underlying structural problems, before implementing digital identification systems. These warnings are especially pertinent for international and domestic actors involved in Myanmar’s move towards a digitisation. At all stages in designing and implementing the new system, Myanmar’s marginalised and disenfranchised communities must play a part. ²⁶ Institute on Statelessness and Inclusion, ‘Making SDG 16.9 work for the wider Sustainable Development Agenda: Lessons from the citizenship, statelessness and legal identity community’ (2019) available at: https://files.institutesi.org/legal_identity_policy_brief.pdf [accessed 13/11/2020]immigration enforcement”. ²⁷ Ibid. ²⁸ There are further examples of Roma in Serbia and populations in Assam, India provided in the ISI briefing paper referenced above. ²⁹ E. Hayes de Kalaf, ‘Making foreign: Legal identity, Social Policy and the Contours of Belonging in the Contemporary Dominican Republic’ (2018) available at: https://ethos.bl.uk/OrderDetails.do?uin=uk.bl.ethos.774013 [accessed 13/11/2020] ³⁰ Open Society Justice Initiative, ‘Kenyan Court Puts Hold on Digital Identity Scheme’ (2020) available at: https://www.justiceinitiative.org/newsroom/kenyancourt-puts-hold-on-digital-identity-scheme [accessed 13/11/2020]; See also, Privacy International, ‘A Guide to Litigating Identity Systems’ (2020) available at: https://privacyinternational.org/sites/default/files/2020-09/PI_A%20Guide%20to%20Litigating%20Identity%20Systems_Biometrics.pdf [accessed 13/11/2020] 9