A Guide to Litigating Identity Systems of individuals.84 The dissent states: “biometric data not only allows individuals to be tracked, but it also creates the potential for the collection of an individual’s information and its incorporation into a comprehensive profile.”85 b) The majority opinion in the Aadhaar judgment ultimately rejects mass surveillance concerns because of oversight by the Technology and Architecture Review Board and Security Review Committee (government committees established by the Aadhaar legislation) and prohibitions on the recording of information about the nature of the transaction, encryption, and data silos.86 However, the court does not make this determination concerning identity schemes generally, but instead relies on data minimisation and anonymity within the Aadhaar system.87 Data minimisation means the collection and storage of only minimal data necessary for effective authentication, including prohibition on the collection of data unrelated to the purpose of the transaction.88 c) Justice Sykes of the Jamaican Supreme Court references the danger of power afforded to the state by the linking of data across state databases under the Jamaican identity system.89 Linking databases together allows individuals to be tracked and provides the state with the ability to build a comprehensive profile of an individual.90 d) Justice Batts of the Jamaican Supreme Court holds that the Jamaican identity system implicates a danger of abuse by the state and its 84 Aadhaar Judgment, ¶ 239 of dissent. 85 Aadhaar Judgment, ¶ 239 of dissent. 86 Aadhaar Judgment, ¶ 447 at 541–544. 87 See Aadhaar Judgment, ¶ 208 at 285. 88 See Aadhaar Judgment, ¶ 191–95 at 271–274. 89 Opinion of Justice Sykes, ¶ 246. 90 Opinion of Justice Sykes, ¶ 246. 25