2020 Statelessness & Citizenship Review 2(2) Centralising the administration of all identity services exposes a person to the tracking of their life events and transactions with government. For example, a person’s addition of dependants under their health insurance account is not only recorded in the database of the national insurance company, but also noted by the digital ID system as new identity documents are printed. Data about the person, such as their residential address, is also noted as the identity document is delivered to them. The person may also have to present themselves to the local authorities to collect the identity document. Some foreseeable complications in lumping social services with security functions include exposure of personal data regarding health or family relations, among others. 45 Persons at risk of statelessness are often marginalised and in need of social services. Such services are best provided in a safe environment and without unnecessary engagement with law enforcement. The pursuit of social services should not put at risk an individual’s legal and ethical right to privacy. Instead, their dignity should be protected and promoted. 46 This would best be achieved by a digital ID system that protects their data from unwarranted access. CONCLUSION Legal identity is a fundamental right and a moral obligation owed by a country to the people within its borders. Prolonged statelessness is a failure of a state to address this right and obligation. The case of NIIMS clearly shows that basing a primary form of ID on the existence of other forms of primary ID will not solve the issue of statelessness, but will instead entrench it and all of its consequential issues. Persons at risk of statelessness are often minorities who are different from the majority of the population in terms of ethnicity, place of origin or religion. They require higher protection to safeguard their human rights. For digital ID systems to achieve sustainable development goals in a holistic manner, they must include and prioritise those who have historically not been counted. 45 ‘Everyone Said No’ Biometrics, HIV and Human Rights: A Kenya Case Study (Case Study, Kelin 2018) <https://www.kelinkenya.org/wpcontent/uploads/2018/07/%E2%80%9CEveryone-said-no%E2%80%9D.pdf>. 46 Magdalena Sepúlveda Carmona, Is Biometric Technology in Social Protection Programmes Illegal or Arbitrary? An Analysis of Privacy and Data Protection (ESS — Working Paper No 59, International Labour Organisation 2018) <https://www.ilo.org/wcmsp5/groups/public/--ed_protect/---soc_sec/documents/publication/wcms_631504.pdf>. 354