Recommendations The Bangladesh government has historically approached the documentation of Rohingya in an instrumental manner, not as an exercise which must be carried out comprehensively and with proper safeguards in place, but rather, as something to be offered, withheld and conditioned on the basis of other criteria and priorities. This is why for example, Rohingya were not registered between 1993 and 2017, and why the current registration and digital ID drive has raised deep concerns of coerced repatriation and data-sharing with the Myanmar government. The role played by UNHCR and other UN agencies has also added to the concerns of the community. In this context, we make the following recommendations: Rohingya should be registered and protected as refugees in Bangladesh. They must be meaningfully consulted on repatriation arrangements between Bangladesh, Myanmar and UN agencies. In particular, Rohingyas experiences and opinions on Myanmar’s national verification process and the forced issuance of NVCs must be taken into account in repatriation arrangements. Without these consultations taking place, the voluntariness of return is undermined. Refugees must have better control over the use of their data. The uses of digital registration and “smart cards” for Rohingya refugees must be specified within clearly set out parameters that are communicated effectively to refugees. These uses should be limited to providing access to humanitarian assistance in Bangladesh to ensure they are not used to implement future repatriations or for other purposes. Rohingya refugees must be meaningfully consulted by state authorities and UN agencies, in order to ensure their informed and non-coerced consent to their data being taken and stored in digital ID and registration processes. These processes should take past traumas into account as well as gender-sensitivities. Awareness raising drives, to educate Rohingya of the benefits as well as implications of digital IDs, must be implemented in ways that address the concerns of the whole refugee community. There must be better transparency and clarity related to data privacy, and in particular, the sharing of data with third parties. Under no circumstances should refugees’ biographic or biometric data be shared with the Myanmar government without individual consent. Rohingya should benefit from the full protection of comprehensive privacy laws that adhere to international standards. Such laws should apply to all persons on Bangladesh territory, and not just to citizens. 20