By Edrine Wanyama |
The Collaboration on International ICT Policy for East and Southern Africa (CIPESA) has made a submission to the Parliament of Uganda’s Committee on Physical Infrastructure on the controversial digital number plate project. Officially known as the Intelligent Transport Monitoring System (ITMS), the project is justified on public interest grounds such as fighting crime, improving traffic safety and management.
However, the system’s proposed capabilities, including automated vehicle identification, potential real-time tracking of vehicles and their occupants, and integration with other government databases, raise substantial concerns about privacy, data protection, and constitutional rights and freedoms.
The submission calls on the Committee to assess the ITMS not merely as a motor vehicle identification exercise, but as a large-scale vehicle monitoring and personal data processing system with wide potential for surveillance.
The submission highlights the major legal, technical, and operational concerns that could undermine the project’s compliance with the Data Protection and Privacy Act, Cap. 97. These include the absence of a published Data Protection Impact Assessment, and inconsistent public information about the system’s technical specifications, such as the use of SIM chips, GPS trackers, and Bluetooth beacons.
The submission argues that the design and potential effects of the ITMS go to the root of fundamental rights and freedoms, as they could have a chilling effect on freedom of movement, assembly, and association. Because the project involves foreign contractors and cross-border data processing, it also poses cybersecurity and data sovereignty risks.
To address these concerns, CIPESA makes recommendations to the Committee aimed at establishing robust oversight and safeguarding fundamental digital rights. It also calls on Parliament to require full disclosure of the project’s technical architecture, data-flow maps, retention schedules, and contract terms to enable meaningful public and parliamentary scrutiny.
Furthermore, CIPESA calls on Parliament to require statutory purpose limitations, judicial oversight, enhancement of powers of the Personal Data Protection Office, and conduct of independent privacy and security audits prior to any further rollout of similar projects.
Meanwhile, the ITMS is under Parliamentary scrutiny over legality encompassing the procurement process, financial model and implementation. Several questions as to whether the deployed technology and infrastructure meet the government’s aims and objectives are a going concern.
Please find the full submission here.