
Introduction
In recent years, the world has witnessed a rapid expansion of digital identity projects, driven by promises to improve access to public and financial services and enhance the efficiency of government administration. During the COVID-19 pandemic, the practical importance of these systems became evident as they accelerated the delivery of remote healthcare and financial assistance.
In this context, the Egyptian state is working to develop a national digital identity system as part of its broader Digital Transformation 2030 strategy. The declared objectives of the project include streamlining government procedures, improving the delivery of subsidies and services to citizens, and promoting financial inclusion by enabling online account opening without requiring physical presence.
Despite these potential benefits, establishing a digital identity system raises fundamental challenges from a human rights perspective, as it may affect individuals’ dignity and fundamental rights as much as it may provide advantages. This paper adopts a critical perspective to evaluate the planned digital identity project in Egypt, focusing on the opportunities it may create for enhancing the enjoyment of rights, against the risks it may pose to privacy and freedoms.
The paper examines the conceptual framework of digital identity and its connection to rights and freedoms, the current Egyptian legal and regulatory context, and the main potential human rights challenges and risks. It also draws on international recommendations and standards to propose an integrated vision of the principles and safeguards that should be incorporated into any digital identity system that respects rights.
Fundamental Human Rights Concepts
Digital identity intersects with a wide spectrum of fundamental rights and freedoms, making it essential to approach it from a human rights perspective from the earliest stages of planning and design. Beyond being a technical tool for facilitating transactions or improving administrative efficiency, digital identity constitutes an infrastructure that may reshape the relationship between the individual and the state.
Furthermore, it affects vital domains such as privacy, equality, freedom of expression and movement, and economic and social rights. This section of the paper outlines the most significant rights associated with digital identity. It clarifies how such a system can serve as either a tool for empowerment or a tool for restriction, depending on the institutional and legal safeguards that govern it.
Digital Identity and the Right to Legal Identity
A digital identity is a digital file that defines an individual and contains essential identifying data, such as a digital identification number and personal and biometric information stored in electronic systems. Identity, in its comprehensive sense, is a fundamental human right enshrined in Article 6 of the Universal Declaration of Human Rights, which affirms the recognition of every individual’s legal personality.
According to data from the World Bank’s Identification for Development (ID4D) initiative, around 850 million people worldwide lack any state-recognized official identity document. Broader UN estimates indicate that the number could reach as high as 1.1 billion people.
The absence of legal identity results in direct exclusion from many fundamental rights, including access to education, healthcare, financial services, lawful employment, and political participation (such as voting), and restricts freedom of movement. Ensuring that all individuals possess a legal identity, whether traditional or digital, is an explicit United Nations Sustainable Development Goal, as it is essential to safeguarding human dignity and enabling full participation in economic, social, and political life.
Digital Identity and the Right to Privacy
The right to privacy and the protection of personal data are among the cornerstones of any human rights assessment of a digital identity system. These systems collect vast amounts of sensitive data, including biometric data (such as fingerprints and facial images). The integration of such data into a unified digital identifier poses a real threat to privacy if misused, as the system could become a tool for mass surveillance in the absence of strict safeguards.
International experience, particularly following the events of September 11, 2001, has demonstrated that national security justifications can drive countries to adopt expansive identity systems that enable comprehensive individual tracking. This underscores the critical importance of imposing strong legal and technical safeguards to ensure that privacy protection is a core, foundational principle in the system’s design and operation.
Digital Identity and the Principle of Non-Discrimination and Equality
Digital identity systems must be designed to ensure inclusivity and fairness for all populations, without discrimination based on gender, race, social status, or other factors. Failure to account for the needs of marginalized groups in the design of identity systems may exacerbate digital exclusion. Moreover, people with low incomes and residents of remote areas may face difficulties in registration due to a lack of documentation or weak infrastructure. At the same time, digital illiteracy or language barriers may prevent some individuals from fully benefiting from digital identity.
Even biometric features may be affected by technical biases; for example, recognition systems may fail to read the fingerprints of some individuals—particularly those engaged in manual labor—due to the erosion of their prints. Commitment to the principle of non-discrimination requires adopting inclusive design that addresses these challenges from the earliest stages.
Mandating digital identity as a prerequisite for online interaction or service access may restrict individuals’ ability to engage in anonymous expression, a fundamental safeguard for freedom of opinion and expression in the digital environment. Article 19 organization has warned that restricting anonymous spaces on the internet undermines the ability of activists and journalists to work freely.
In the Egyptian context, linking digital identity to surveillance systems or making its use a condition for traveling between cities could restrict freedom of movement and create a permanent climate of surveillance. For this reason, human rights organizations such as Access Now recommend halting any digital identity program that does not comply with standards of transparency, accountability, and respect for human rights.
Digital Identity and Economic and Social Rights
If designed and managed in line with human rights standards, digital identity can support the fulfillment of economic and social rights. It may facilitate access for marginalized groups to health, education, and social protection services, and foster financial inclusion by enabling them to open bank accounts and access formal financial services. However, the relationship between digital identity and rights is a two-way one: it can serve as a tool for the empowerment and guarantee of rights, or a tool for their restriction and undermining, depending on the legal and institutional framework governing it.
The Legal and Regulatory Framework in Egypt
As of the preparation of this paper, there is no specific law in Egypt regulating a comprehensive national digital identity system. The current national ID card is issued under the Civil Status Law; however, it does not constitute a “digital identity” with its expanded electronic and biometric components. With the state moving toward digitizing identity, a clear legislative gap emerges.
Steps toward launching digital identity are still being taken through secondary regulatory decisions, such as those issued by the Financial Regulatory Authority regarding digital verification in the non-banking financial sector, without a comprehensive legal framework that defines digital identity, its characteristics, uses, and safeguards. The absence of such legislation raises concerns about the scope of authority granted to government bodies that will manage the system, as well as about citizens’ rights and the means of protecting them in the context of digital identity.
Personal Data Protection Law
In 2020, Egypt issued Law No. 151 on Personal Data Protection, an important step toward establishing rules for digital privacy. The law is based on many principles of the European General Data Protection Regulation (GDPR) and mandates obtaining individuals’ explicit consent before collecting or processing their personal data. It also grants individuals fundamental rights, such as the right to know what data is collected about them, access it, correct it, and delete it.
While the Data Protection Law does not explicitly address the concept of “digital identity,” it provides a general framework that could—theoretically—be applied to any digital identity system for protecting citizens’ data privacy. For example, the operator of a digital identity system would be required to adhere to principles such as collecting only the minimum necessary data and using it only for authorized purposes, and to secure it against breaches or unauthorized processing.
However, the Data Protection Law has certain shortcomings when viewed as the sole safeguard for digital identity. The law contains broad exemptions in favor of national security agencies, the Central Bank, and others, which may allow privacy guarantees to be bypassed under the pretext of security considerations.
Furthermore, public awareness of the law and of individuals’ digital rights remains limited, and its practical applications are still rare. This raises questions about the readiness of the current institutional and legal framework to protect citizens’ rights within a large-scale digital identity project.
Electronic Signature Law No. 15 of 2004
The Electronic Signature Law, enacted in 2004, is one of the pieces of legislation directly related to digital identity, despite predating the current wave of digital transformation. This law regulated the legal recognition of electronic signatures and transactions. It designated the Information Technology Industry Development Agency (ITIDA) as the competent authority to grant licenses to providers of electronic signature and digital certification services.
The electronic signature infrastructure established by law can be regarded as an initial nucleus of digital identity, as digital certificates are granted to users, enabling the verification of their identities online when signing documents or conducting transactions over the internet. This law has played a role in making government and commercial services available online, based on identity verified through digital certificates.
Despite its significance, the Electronic Signature Law has become relatively outdated in light of current technological developments. For instance, it did not address digital identity in its broader sense, which includes biometric features and the integration of multiple databases. Nor did it establish a framework for a unified identification number for all citizens in digital services that goes beyond the national ID number printed on identification cards. Therefore, with preparations underway to launch a national digital identity system, there will be a need either to amend this law or to enact new legislation to ensure integration between the electronic signature system and a multi-purpose national digital identifier.
Human Rights Challenges and Risks
Privacy and Data Protection
Privacy violations are among the most significant risks associated with the digital identity project in Egypt, particularly in the absence of transparency regarding data collection and storage policies. So far, no clear standards have been announced to define how biometric data (such as fingerprints or facial images) are collected, where it is stored, or which entities are authorized to access it. By their very nature, biometric data are highly sensitive and unique, and any leakage or misuse could be catastrophic and irreversible.
Legitimate concerns are also raised about the potential sharing of digital identity data with third parties without individuals’ knowledge or consent. The system may enable government entities, such as ministries or security agencies, or private entities, such as banks and telecommunications companies, to gain direct access to the digital identity database for verification, service provision, or even marketing. In the absence of a strict legal framework, this could lead to large-scale data sharing or even the sale of data for commercial gain, which constitutes a form of commodification of personal information without the free and informed consent of its owners.
In this context, Privacy International organization has warned that adopting a unified identification number across multiple databases enables the integration of governmental and private data, granting entities a comprehensive 360° profiling of individuals’ lives. It also leads to the phenomenon of unintended expansion of use (Function Creep), where data is exploited for purposes other than those for which it was originally collected.
From a human rights perspective, the situation is aggravated by the absence of tools that enable individuals to exercise their digital rights. In systems with a strong rights-protection framework, citizens have the right to access their personal data, know who has accessed it, and demand its correction or deletion. In Egypt, however, there are no indications of plans to provide a portal that would allow citizens to manage access permissions to their data or to give prior consent for its sharing—meaning individuals would lose control over their digital identity to the system operator. The principle of self-control over data requires tools that allow users to grant or withdraw consent for the use of their data at any time, and any system lacking this feature remains inadequate for protecting privacy.
Digital Exclusion and Inequality
Despite the promises digital identity holds for facilitating access to services for all, in practice, it may exclude segments of the population if not carefully planned and implemented. In Egypt, the digital divide remains evident between urban and rural areas, as some villages and remote regions lack adequate or even any digital infrastructure, limiting internet access or rendering it of poor quality.
If the digital system assumes reliable internet connectivity or that everyone owns a smartphone, residents in these areas will face difficulties registering for and using digital identity. The same applies to older people and the digitally illiterate, who may be hindered by complex user interfaces or the absence of awareness and digital literacy programs.
Registering marginalized groups presents a particular challenge, as individuals who lack birth certificates or national ID cards—due to social or historical reasons—may be entirely excluded from the digital system. These groups at risk of statelessness or lacking civil registration include some residents of border areas or children of Egyptian mothers who are not legally recognized by their fathers. Unless exceptional measures are taken to reach these groups and provide them with a digital identity, the gap in access to rights may widen rather than narrow.
In this context, the UN Special Rapporteur on extreme poverty pointed out that digitalization may become a means of depriving the poor of services if alternatives suited to their circumstances are not provided. International experience has shown that the digital transformation of social welfare systems has led to the exclusion of those unable to use electronic platforms or who lack stable internet access.
Another risk emerges from the potential requirement for a digital ID as the sole means of accessing rights and services. If the government—once the project is completed—decides to restrict certain essential services, such as food subsidies or healthcare, to those with an activated digital ID, this would effectively make possession of a digital ID a prerequisite for enjoying fundamental rights, which contradicts the principle that rights must be inclusive and accessible to all.
The danger of this approach is evident in experiences such as the Aadhaar system in India, where some poor citizens were denied their food rations either because they did not possess a digital ID or because the system failed to read their fingerprints. This created an unfair trade-off between privacy and access to necessities.
Likewise, technical or administrative errors can lead to unintentional exclusion. An error in data matching or a technical failure during the registration process may prevent an individual from receiving service until the issue is resolved. With full reliance on digital identity, such interruptions become a major obstacle. Therefore, establishing effective mechanisms for exceptional handling is vital to quickly rectify these situations and ensure that eligible individuals do not lose access to services.
Surveillance and the Undermining of Civil Rights
Linking all individual transactions and services to a unified digital identity opens the door wide for unprecedented state surveillance of citizens’ lives. In the Egyptian context, there are serious concerns that digital identity could become an additional tool for tracking and violating civil rights. When every electronic transaction—from receiving food subsidy benefits to booking train tickets—requires presenting a digital identity, this generates a continuous flow of data on individuals’ movements and activities. If access to this data is granted to any authority without independent oversight, it would result in comprehensive surveillance of daily life.
Human rights organizations point out that many governments in the Middle East adopt surveillance technologies without independent oversight, leading to widespread violations of privacy and human rights. This description applies to Egypt, which has witnessed a notable expansion in the use of surveillance technologies, including facial recognition cameras, and a requirement that telecommunications companies store data for 180 days under the Anti-Cyber and Information Technology Crimes Law.
Adding the digital ID to this system may enable the integration of multiple security and service databases, allowing authorities to build a comprehensive picture of citizens’ lifestyles, from their travel destinations to their consumer transactions and services. The absence of clear legal safeguards increases the risk of misuse of this data in political or security contexts. If the authorities decide to suspend or revoke the digital ID of an opponent or activist, this could effectively prevent them from accessing essential services, which is equivalent to withdrawing a passport or restricting legal capacity.
International experiences, such as the linkage in China between digital identity and the “Social Credit” system to punish dissenters, demonstrate how dangerous such uses can be. And although Egypt does not apply a similar system, the vague laws, such as the Emergency Law and Anti-Terrorism laws, could allow the use of digital identity data in exceptional measures against individuals.
Tracking citizens’ movements through the digital identity could lead to actual restrictions on freedom of movement within the country, such as recording passage at checkpoints between governorates or preventing certain individuals from booking transportation digitally. This form of digital surveillance poses a greater danger than traditional checkpoints, as it is invisible and operates continuously, enabling it to penetrate the details of daily life without individuals even noticing.
The possibility that digital identity in Egypt could become a tool for political and social control will persist as long as no clear safeguards are built into its design and operation. Such safeguards must include a precise definition of the purposes of data collection, a prohibition on its use for surveillance or tracking without judicial authorization, and the application of the principle of data minimization, so that only what is strictly necessary is collected and retained for the required duration. The absence of these guarantees would turn digital identity into a means of undermining rights rather than enhancing them.
Additional Structural and Systemic Risks
Alongside the immediate risks that can be observed from the very first moment of operating the digital identity system, there is a set of risks that may not surface right away but are embedded in the system’s underlying infrastructure and in how it is run and managed over the long term. These risks are cumulative and may gradually creep into the system without clear indicators at the outset.
One of the most prominent risks is the loss of individual control over personal identities and data. If a person’s identity becomes entirely dependent on a state-managed centralized digital system, the citizen may effectively lose any authority over how they are defined before others. In this model, the state determines the attributes and content of the digital identity. It may link it to additional information from other databases, such as criminal, health, or financial records, thereby reducing a person to a comprehensive identification number. This excessive concentration of power over individuals’ identities undermines the concept of self-identity, which allows a person to choose what information to disclose or conceal depending on the context.
The risk becomes even more complex if the digital identity is eventually integrated with opaque artificial intelligence systems. Algorithms could be used to analyze citizens’ patterns of service usage, classify their behavior, predict their needs, or even determine the level of “risk” associated with them. These algorithms are often “black boxes” that do not reveal the logic behind their operation. They may also contain programmed or unintended biases, which could result in discriminatory or erroneous decisions against individuals, without them having any means to know the reason for the decision or to challenge it.
The UN Special Rapporteur on Extreme Poverty noted that the application of automation and artificial intelligence in social welfare systems in several countries has often deepened discrimination against people experiencing poverty rather than alleviating it. For example, an algorithm may determine that a particular individual is ineligible for social assistance based on spending data tracked via a digital identity, resulting in the automatic cancellation of their entitlements.
The risks also include the absence of effective complaint and appeal mechanisms. If a citizen encounters a technical issue, such as their digital account being suspended, or a legal issue, such as objecting to the collection of certain personal data, there must be clear and swift channels for lodging complaints and obtaining remedies. If the only recourse is litigation in court, the prolonged duration and complexity of legal procedures may prevent affected individuals from securing their rights, particularly in urgent cases such as receiving benefits or accessing healthcare entitlements.
In addition, there is a risk of commodifying and economically exploiting data. Considering data as the “oil of the digital age,” government entities may collaborate with private companies to provide additional services through digital identity platforms. Such collaboration could grant these companies access to personal data, such as geographic location and consumption patterns, or the data could be sold in aggregate to market research and advertising firms under the pretext of anonymization. In either case, the result is the same: the economic exploitation of personal information without the explicit consent of its owners, which violates the principle of free and informed consent.
Moreover, reliance on biometric verification technologies, such as facial recognition or fingerprint scanning, carries additional risks. These technologies are not 100% accurate and may produce matching errors that unjustifiably deny individuals access to services. The problem is further compounded by the lack of alternatives to manual verification, potentially leaving individuals stranded outside the digital system.
Finally, there is the risk of discriminatory use of the digital identity against specific groups, such as political opponents, human rights defenders, or religious and ethnic minorities. Invisible classifications could be added to an individual’s digital profile, used to impose special restrictions, such as subjecting them to security checks for every transaction, delaying the processing of their requests, or even deactivating their digital account during sensitive periods.
These structural risks require attention from the very early stages of planning a digital identity project. The launch of any such system should be accompanied by robust governance, including a clear legal framework, independent oversight bodies, and transparent mechanisms for civil society participation in supervision, so that the digital identity remains a tool for empowering citizens rather than a means of controlling or excluding them.
Relevant International Standards and Recommendations
The UN Special Rapporteur on the Right to Privacy has emphasized in reports that any system for collecting and processing data, including digital identity projects, must comply with human rights principles from the design stage. This can be achieved by establishing strict safeguards that ensure only the minimum necessary data is collected for legitimate, clearly defined purposes, and that no data is processed without individuals’ free and informed consent.
The Special Rapporteur also emphasized the importance of full transparency in privacy and data protection policies, so that citizens are clearly informed in advance about what data is being collected about them, how it will be used, and which entities may have access to it. She further highlighted the principle of accountability, which requires a designated body that can be held accountable in the event of any data breach or violation.
In a 2019 report, the Special Rapporteur on extreme poverty warned against the transformation of states into “digital welfare states”, a model often associated with violations of the rights of the poor. The report explained that governments justify the use of complex and costly biometric digital identity systems by citing fraud prevention and improved efficiency in social welfare services. However, the underlying motivation may actually be to reduce social spending, narrow the pool of beneficiaries, and establish bureaucratic surveillance systems over citizens under the guise of technology.
The Special Rapporteur recommended conducting a comprehensive review of the human rights impact of any digital transformation in social service systems, ensuring it does not come at the expense of the acquired rights of people with low incomes. Among other recommendations, he advised maintaining a non-digital option for accessing essential services to remain available to those unable to access them digitally, and not making smartphone ownership or internet connectivity a prerequisite for enjoying fundamental rights.
In 2017, a group of United Nations agencies, the World Bank, and international partners adopted the “Identification for Sustainable Development Principles” document, which provides a framework for guidance to help countries build digital identity systems based on inclusivity, trust, and accountability. These principles emphasize ensuring that all individuals—citizens, residents, or refugees—have access to a legal identity without discrimination and removing barriers to registration and use, whether financial, geographic, or cultural.
The principles also emphasize designing identity systems that are reliable and secure, maintaining uniqueness while providing strong protection of personal data through technical and regulatory measures that prevent breaches and misuse. In terms of governance, the principles stipulate the need for a comprehensive legal framework that clearly defines responsibilities and safeguards rights, alongside independent oversight and effective grievance mechanisms.
In addition, Privacy International warned that digital identity systems, despite their administrative and technical appearance, constitute a fundamental human rights issue. Through case studies in countries such as India and Kenya, the organization documented how the introduction of a unified digital identifier led to the exclusion of certain population groups, due to registration difficulties or verification failures, and made the data vulnerable to exploitation and surveillance.
The organization called for strict legal safeguards to prevent arbitrary surveillance, such as prohibiting the mandatory use of the digital ID for public presence or purchasing SIM cards, and ensuring that different databases are not linked without a clear legal basis.
Opportunities to Enhance Rights through Digital Identity
Despite the challenges and concerns outlined above, digital identity, if properly designed and managed within a human-rights-respecting framework, remains a powerful tool to enhance access to rights and services in Egypt. Framing the project in a way that places rights at its core can transform digital identity into a means of empowerment rather than a source of restrictions.
- Enabling Marginalized Groups to Access Basic Services: In contexts where segments of the population live in remote or rural areas and face difficulties in obtaining official documents or traveling to urban centers, a unified national digital identity can bridge this gap. It enables remote electronic identity verification, allowing a citizen in a remote village to access healthcare, education, or social services without the hardship of travel.
- Supporting Financial Inclusion and Economic Development: A significant portion of Egyptians face financial exclusion, either lacking bank accounts or having difficulty accessing formal financial services. A digital financial identity linked to the national digital ID, as planned by the Central Bank of Egypt, would allow financial institutions to verify clients remotely and open accounts electronically. This removes barriers such as document requirements or the need for in-person visits, thereby integrating a broad segment of citizens into the formal financial system and enabling them to save, access credit, and obtain insurance.
- Enabling Remote Digital Documentation and Signing: The digital identity provides the necessary infrastructure to generalize electronic signing and remote documentation, allowing citizens to conclude contracts, submit tax declarations, and obtain official documents, such as birth and marriage certificates, online. This step supports the right to access justice and public services efficiently while reducing reliance on paper-based transactions, which are often characterized by bureaucracy and susceptibility to corruption.
- Alleviating Bureaucracy and Improving the Efficiency of Public Services: A unified digital identity minimizes the need for citizens to submit the same documents to multiple agencies, enabling secure linking of electronic systems and facilitating information exchange. This accelerates access to services, eases administrative burdens, and respects the citizen’s time and dignity.
- Enhancing Electoral Integrity and Developmental Planning: When used under strict safeguards, digital identity can help ensure electoral integrity by electronically verifying voters’ identities and preventing fraud. Additionally, aggregated, de-identified data can provide a more reliable basis for public policy-making and for allocating resources to the regions and groups most in need, thereby promoting developmental rights.
Thus, a digital identity can either serve as a tool for empowerment, enhancing citizens’ quality of life and safeguarding their rights, or become a technical burden that exacerbates existing inequalities. A rights-conscious approach, adherence to international standards, and lessons drawn from global experience can ensure that digital identity serves as an instrument for advancing rights and freedoms while effectively serving the public.
Recommendations
Based on the discussions above and international experiences, there is a comprehensive set of principles and standards that should be integrated from the outset into the design and operation of Egypt’s digital identity system to ensure respect for human rights. The key principles are as follows:
- Free and Informed Consent
The collection of personal data or its use for new purposes must be conditional upon the citizen’s explicit, free, and informed consent, provided after the citizen has been fully informed about the purpose of data collection, the types of data collected, and the entities that will process it.
The digital identity application form should include a clear, simple explanation in plain language, with options that allow the user to consent to or refuse the sharing of specific data in defined contexts. Participation in the system should remain as voluntary as possible, and any mandatory registration must be narrowly scoped, legally justified, and subject to judicial oversight.
- Minimization of Data Collection (Data Minimization Principle)
The digital identity system must be designed to collect only the information strictly necessary to provide a service or verify identity, and to prohibit any expansion to request data not directly relevant to the intended purpose. For example, income or health information should not be demanded to be included in the digital identity file unless it is directly linked to a specific service and supported by a legal basis. Additionally, full tracking of user activity across different services must be prohibited, and techniques such as transaction anonymization (tokenization) or attribute-based verification should be adopted to minimize the amount of data exchanged.
- Transparency and Accountability
Policies governing the operation of the digital ID system and the user rights framework should be widely published, with an easily accessible channel for the public to obtain this information. Periodic reports must be issued detailing the number of registrants, instances of breaches or malfunctions, and how they were addressed, with this data made available to the public and media. The responsibilities of government and private entities participating in the system must be clearly defined by law, and an audit log should be implemented to track all access to the data, with penalties imposed for any misuse.
- User Self-Control over Identity and Data
Individuals should be empowered to access their stored data, know which entities have viewed it, and correct any errors as soon as they are discovered. Options for granular consent should be provided, allowing only the minimum necessary information to be shared to complete a transaction without revealing the full identity. Additionally, individuals should have the right to deactivate or cancel their digital identity if they wish, with traditional alternatives available to access services.
- Establishing an Effective and Independent Complaints and Redress Mechanism
An independent authority or commission should be established to handle complaints related to the digital identity system, separate from the system operator, to ensure impartiality. Complaint procedures should be free of charge, simple, and swift, with the authority to issue corrective orders or compensation. This mechanism serves as a safeguard to restore rights in case of errors or misuse.
- Bridging the Legislative Gap with a Comprehensive Digital Identity Law
A dedicated law must be enacted to regulate all aspects of digital identity, define its components, specify the powers and responsibilities of relevant entities, and enshrine rights-based principles as binding legal provisions. The law should explicitly guarantee every individual’s right to obtain a digital identity without discrimination, and the right to object and seek redress in cases of privacy violations, with clear penalties for any unlawful data exploitation.
- Activating and Implementing the Personal Data Protection Law
The provisions of the Personal Data Protection Law and its Executive Regulations should be promptly activated to ensure that the digital identity project adheres to data protection principles.
- Providing Non-Digital Alternatives for Digitally Disadvantaged Groups
Essential services must remain accessible through parallel traditional channels during the transition period and even after the digital identity system is fully implemented, to ensure that no citizen is deprived of their rights due to a lack of digital skills or tools. This includes keeping government service offices open in villages and remote areas and providing trained staff to assist older people, people with disabilities, and those who are digitally illiterate in completing their transactions. Digital identity applications should also be designed in accordance with inclusive access standards, integrating assistive technologies such as screen readers, voice commands, Braille, and text magnification options to ensure ease of use for all users.
- Cybersecurity and Infrastructure Protection
The system must be designed according to the highest security standards, including end-to-end encryption, early breach detection mechanisms, and rapid response plans for cybersecurity incidents. Additionally, regular penetration tests should be conducted by independent entities, and strict access control protocols must be established to ensure that only authorized personnel can access sensitive data and systems.
- Data Retention Periods and the Right to Erasure
The legal and regulatory framework should clearly stipulate that personal data within the digital ID system must not be retained longer than necessary for the legitimate purposes for which it is processed, with maximum retention periods specified for each data category according to its type and sensitivity.
Data should be automatically deleted or destroyed once the purpose has been fulfilled, and individuals must have the full right to request the erasure or destruction of their data at any time when it is no longer needed, including data stored in backup copies. Erasure procedures should be clear and documented, and a mechanism should be provided to allow users to verify that deletion has been effectively carried out.
- Right to Data Portability
Individuals must be able to obtain a comprehensive, up-to-date copy of their data in a standardized, machine-readable format compatible with other systems and platforms, while ensuring secure transfer and protecting the data in transit. This right enables individuals to reuse their data with other service providers, promotes competition, and reduces the risk of informational monopolies by a single entity. The process should also be free or low-cost, and easy to execute without technical obstacles that could prevent its exercise.
By implementing these principles as an integrated package, it can be ensured that the digital identity will serve as a tool for empowering citizens rather than a means of control or exclusion, while fostering public trust and supporting fundamental rights over the long term.
Conclusion
Building a national digital identity system is a project that goes beyond technical and administrative aspects; it is a political and social endeavor with profound effects on the relationship between citizens and the state, as well as on the societal fabric as a whole. The significance of digital identity lies in its connection to human dignity, serving as a fundamental tool for establishing an individual’s existence and legal recognition. Accordingly, any violation or misuse of this identity constitutes a direct infringement on human dignity and a constraint on personal freedoms.
This paper has highlighted that digital identity intersects with a broad spectrum of rights, ranging from the right to privacy, through equality, freedom of expression and movement, to fundamental economic and social rights. Accordingly, the proper design of Egypt’s digital identity system should be grounded in the principle that respecting these rights does not undermine the project’s effectiveness; rather, it constitutes the essential guarantee for its success and sustainability.
Digital identity can become a genuine tool for empowerment, facilitating easier access to services, enhancing government transparency, and opening new economic opportunities—provided it is designed and managed within a comprehensive human-rights framework that places individuals at the center of the process. Achieving this requires clear legislation, building trust through transparency, involving citizens at all stages of the project, and establishing strict mechanisms to prevent misuse. Without these safeguards, the initiative risks becoming a threat to rights rather than a means of supporting them.