A Guide to Litigating Identity Systems c) The dissent in the Aadhaar judgment highlights the ability of the state to create comprehensive individual profiles based on data linked across databases used by the identity system.120 Individual profiles increase the state’s ability to track an individual’s movements and can fix permanent stigma to an individual’s identity in the system.121 d) The Kenyan High Court explicitly references profiling and surveillance as forms of potential misuse or unauthorised access, giving rise to the data protection requirements imposed by the court on the Kenyan national identity system.122 Moreover, the court prohibits the collection of GPS coordinates as part of the national identity system, referencing the ability to use such data to “track and monitor people without their knowledge.”123 The court also finds that centralised databases storing GPS information could be used to “create ‘watchlists’ or ‘blacklists’,” thereby “leading to a reversal of the presumption of innocence.”124 e) 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.125 Justice Sykes quotes scholar Nancy Liu and states when “unique identification just from biometric data is combined with a unique identification number is seeded into multiple databases and the use of the unique number is tracked the ‘biometric data not only allow individuals to be tracked, but create the potential for the collection of an individual’s information and its incorporation into a comprehensive profile by linking various databases together.’”126 120 Aadhaar Judgment, ¶ 247 of dissent. 121 Aadhaar Judgment, ¶ 247 of dissent. 122 Huduma Namba Judgment, ¶ 880. 123 Huduma Namba Judgment, ¶ 768. 124 Huduma Namba Judgment, ¶ 918. 125 Opinion of Justice Sykes, ¶ 246. 126 Opinion of Justice Sykes, ¶ 246. 31