While the Bill’s stated aim – to improve children’s wellbeing and safeguard those at risk – is one everyone would likely support, the mechanism chosen poses profound risks to privacy, autonomy, and trust in public services.

Digital ID Risk

The proposal meets all the functional criteria of a national digital identity system:

• Unique, lifelong identifier: The NHS number is permanent and already used across health services. Under the Bill, it would become a “consistent identifier” across health, education, and social care, effectively linking multiple records for each child.
• Compulsory cross-sector linkage: There is no opt-out, making participation mandatory and expanding state access to personal data without consent.
• Precedent for lifelong tracking: The NHS number is retained for life. Attaching it to education and social care data creates a persistent, linkable record of a child’s interactions with the state, accessible into adulthood.
• Pilot enables incremental expansion: Ministers have explicitly stated the identifier’s use will be tested and potentially expanded if additional “benefits” are realised (Committee Stage, 23 January 2025). This sets the stage for broader adoption without new legislation.
• Alignment with UK digital ID strategy: The Cabinet Office’s Digital Identity and Attributes Framework promotes cross-sector reusable identifiers. The Bill effectively implements this for one cohort – children – laying the groundwork for future population-wide extension.

Taken together, these features mean that the Bill, if enacted as currently drafted, would create a centralised, government-controlled digital ID system for children under the guise of safeguarding, with the potential to expand further over time.