The Communications and Creative Industries Branch of the Commerce and Economic Development Bureau (CEDB) issued the consultation paper to seek the views on a proposed real-name registration programme for subscriber identity module (SIM) cards.
The real-name registration programme for SIM card (“SIM card registration”) undermines the right
to privacy. It involves mass monitoring, interception, collection, storage, or other use of communications material, that is not targeted at an individual, a particular group or location, and will make it harder to communicate anonymously – a crucial enabler of the right to privacy. Thus, Amnesty International Hong Kong (AIHK) believes that this proposal is not a proportionate and necessary interference and may violate the right to privacy.
The SIM card registration hampers the right to freedom of expression. With the enactment of the National Security Law (NSL), it allows law enforcement agencies (LEA) additional investigative powers, while bypassing oversight by Hong Kong’s legislative and judicial system. AIHK fears that such authorities may multiple the risk induced by the registration SIM-card registration, as the access to the personal data can be given to the authorities without adequate oversight mechanism, which may interfere the right to freedom of peaceful assembly, association and expression in the foreseeable future.