A Guide to Litigating Identity Systems c) The dissenting opinion in the Aadhaar judgment also raises concerns of tracking, stating: “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.”132 d) The Kenyan High Court prohibits the collection of GPS coordinates in the Kenyan national identity system partly because the coordinates could be used to “track and monitor people without their knowledge.”133 The court also prohibits the collection of DNA information for use in the system, referencing the ability to use DNA and other biometric identifiers for “negative profiling of individuals for ulterior motives.”134 e) The majority in the Aadhaar judgment is satisfied that exact information regarding the purpose of an authentication request is not stored in the Aadhaar system, but the majority also points out that some data regarding location is recorded.135 The majority opinion in the Aadhaar judgment rejects profiling concerns, but relies on anonymisation, data minimisation, and the use of data silos to reach this conclusion.136 If these facets of the system did not exist, the majority may not have reasoned as it did. 132 Aadhaar Judgment, ¶ 239 of dissent. 133 Huduma Namba Judgment, ¶ 768. 134 Huduma Namba Judgment, ¶ 767. 135 Aadhaar Judgment, ¶ 197 at 276. 136 Aadhaar Judgment, ¶ 208 at 285. 33