NIA TO MEET PARLIAMENT’S COMMITTEE OF THE WHOLE

20TH JUNE, 2018
NIA RESPONDS TO CLAIMS MADE BY FORMER EXECUTIVE SECRETARY OF NIA MR. KWAME GRIFFITHS.





Mr. Kwame Griffiths has reacted to a post on NIA’s website and Facebook page and has been heard on a number of media platforms making false and inaccurate claims about NIA’s PPP project with IMS which we react to as follows:

CLAIM 1

“1. If the above claim by the NIA is anything to go by, then there was absolutely no need for a PPP with a private entity. This is because the $124m indicated as NIA’s contribution alone is enough to execute the project. Indeed, prior to him leaving office, some of the offers we had from solution providers (the credible ones among the lot) were as follows:

  1. Multimedia Glory of Malaysia was willing to do it for less than $50m
  2. Madras Security Printing of India was willing to do it for less than $100m
  3. CIDC of China was willing to do it for $ 115m
  4. EDAPS of Ukraine was willing to do it for € 123m for registration through to card issuance (including field operations)

Others who expressed interest came from countries like France (Safra [sic] Morpho), India (4G ID Solutions) and Serbia (Vlatacom).

2. The average cost of issuing ID Cards - from registration to card issuance (technical solution plus field operations) - is $5 per registrant. In April 2016, India crossed the one billion mark and has spent less than $2 per registrant, translating into less than $2 Billion in total so far. How can Ghana with a population of at most 30 million spend $1.2 Billion for this exercise over a 15 year period? In any case, once the system is set up and cards are issued to even a reasonable size of the population, revenue starts trickling in. The question that begs for answer is why the fifteen-year arrangement? By industry standards, the life span of ID Cards is usually ten years. Is the fifteen years contract intended to ensure a vender lock-in even beyond ten years?”

Response

Mr. Griffiths demonstrates a lack of appreciation of the fact that investments and costs normally precede revenues. He also fails to acknowledge the perennial underfunding of NIA and the fiscal constraints faced by Government. Surely, he is very much aware that NIA never received the much-needed resources for its statutory mandate even under his watch as CEO of NIA.

As we have already stated in previous releases on this matter, the $124 million NIA contributions include the payment of salary for staff and field operations, establishment of regional and district offices, provision of logistics and other equipment and machinery such as vehicles for NIA. The technical systems to be paid for by NIA makes up less than $29 Million (including the 2D barcode cards) of this amount.

Mr. Griffiths cites cost quotations from 3 different vendors: Multimedia of Malaysia at $100 million; CIDC of China at $115 million; and EDAPS of Ukraine at €123 million, which is equivalent to $145 million, to justify his claim on cost adequacy.

It is worth noting that the EDAPS contract was to be procured at 7.69 euros per card (Annex 6 of Draft EDAPS Contract) which contradicts his support and claim that the average cost per card should not be more than $5.00. The NIA/IMS higher specification card on the other hand is priced at $5.40 per card. Mr. Griffiths failed to take into account the expanded scope of the PPP project, which has been impacted by amendments to NIA’s statutes. Pursuant to the National Identity Register (Amendment) Act, 2017 (Act 750), all Ghanaians from birth would be registered and issued with Ghana Cards. Thus, unlike these solutions providers whose competing costs cover only the 16+ year population segment, the current expanded scope of PPP project includes the additional population of 10 million not previously registered or issued with cards and the over 1 million Ghanaians living abroad. Additional scope includes capabilities such as iris capture and storage and an online registration and payment portal.

Whereas the smart cards in the two unsigned contracts he refers to (EDAPS& CIDC) are 32k to 80k capacity chips and were to be centrally printed with 2 additional central printers, the new smart Ghanacard is 148k with an ECOWAS passport and 13 additional applications.

This additional scope items will ensure the completeness of the database which is crucial for revenue generation.

In addition, the new national identity card canbe printed centrally at NIA instantly with the purchase of two ultra-modern central printers by NIA as well as instantly by the 1100 secure instant issuance printers supplied under the PPP with IMS. These cards could be printed instantly in Ghana and in the 88 Ghanaian missions worldwide with more than double the amount of registration kits with iris capture equipment envisaged under the EDAPS/CIDC contract with deferred central printers issuance for 2 printers.

Crucially, Mr. Griffiths demonstrates a lack of understanding of the value of efficient risk allocation in the areas of cost overruns, quality assurance and timeliness in PPP contracts. By passing this risk to IMS, NIA has saved itself the risk of any cost increases. The weakness in this assertion however, is that revenue generation will only occur when NIA’s database is complete to provide value to other stakeholders.

The 15-year duration is driven by financial and technical considerations and not some vendor lock-in scheme. The longer duration ensures lower charges of verification services as the project will have longer time to recoup investment. Moreover, the technical system will be upgraded on a 5-yearly basis which makes it technically prudent to hand the project over to NIA after a 5th year anniversary after the system has been upgraded.

The options for transfer are as following:

  • Option 1 (5 years): A handover at the first 5th year will be unaffordable to users of the system.
  • Option 2 (10 years): The second 5th year (10 years) will coincide with the renewal of the smartcards and NIA would have to bear the cost of new cards.
  • Option 3 (15 years): The system would have been updgraded and cards still valid. This is the least cost and most technical optimum transfer period.

In short, NIA’s contribution only covers the cost of operation and not the issuance of registration equipment, smart cards and verification systems that require the additional $169 million contribution from IMS.

INDIA

As we have mentioned in previous releases, itt is important to note that under India’s biometric ID system known as “Aadhaar”, ten fingerprints and two irises of each individual are captured in order to issue a 12-digit unique identification number. “The unique ID number is then used for a variety of public and private services, often in conjunction with the person’s address, biometric information or password”. No ID card is issued, neither to Indians living in India or abroad. Ghana has clear legislative prescription for its identification system and it is different from India in all material respect.

Duration of PPP Contract

Under section 31 of the National Identity Register Act, 2008 (Act 750) as amended, the validity of the Ghana Card is 10 years from the date of issue. The validity of the card is different from the PPP contractual period. In short, while “by industry standards, the life span of ID Cards is usually ten years”; there are no industry standards for when contracting parties to any contract must limit themselves. Throwing in “vendor lock in” without elaborating further is a desperate venture to discredit the PPP contract, which has been reviewed many times, firstly by the wellknown law firm of AB & David, the Legal department of the Ministry of Finance, and finally as by law required, the Attorney-General, is nothing but giving the dog a bad name so it would be hanged.

CLAIM 2: Cost of $1.2 Billion

This claim is erroneous. The project costs the government $124 million while IMS will raise $169 million from debt and equity. It is projected that the project will generate a minimum of about $1 billion out of which a projected cost of about $900 million will be spent over 14 years. By strenuously confusing this PPP contract with the traditional engineering, procurement and construction (EPC) contracts, which is the proposal that all the solution providers Mr. Griffiths has named, prefer, where these companies simply design, procure, construct, commission and hand-over the project to NIA as the end-user or owner. As the previous Sagem contract demonstrated, this approach has proven to be expensive because government is unable to keep up with the cost of running, maintaining and upgrading the system. Under the current arrangement, the private partner is committing resources as part of its contractual obligations and has the contractual duty of ensuring that the NIS is upgraded every 5 years to ensure that the system stays updated and modern.

CLAIM 3: PPP is an inappropriate vehicle for the NID project

His assertion that the PPP is not a suitable vehicle is a matter of opinion. There is nothing in the existing PPP Policy Framework issued in 2011 forbidding PPP projects such as the instant neither is there any section of NIA laws that speaks against PPP. On the contrary, section 1(3) of National Identification Authority Act, 2006 (Act 707) permits NIA to “…enter into any contract or any other transaction” for the performance of its statutory functions.

His concern for national security has already been addressed through the assignment and ownership of all data-bearing assets to the state represented by NIA. IMS will only provide smartcards and technical support to the project. Indeed, long before the Niamey declaration of 2014, section 2(2) (b) requires NIA to “ensure the accuracy, integrity, confidentiality and security of data collected” by NIA. Per section 2(2) (d) of Act 707, NIA is to “make data in its custody available to persons or institutions authorised by law to access the data.” The NIA has abided by these statutory provisions and the Data Protection Act, 2012 (Act 843) in the discharge of its mandate. It would be useful to find out from Mr. Griffiths how this PPP arrangement is a national security threat and how that is addressed by the involvement of all the completely foreign owned entities he prefers to a Ghanaian Company

Establishment of IMS Ltd

Unlike EDAPS, CIDC, Madras Security Printing and all the companies Mr. Griffiths prefers, IMS Ltd, licensed to implement the FIMS Project, is incorporated under Ghanaian laws with registration No. CS 707342015. IMS II, in partnership with NIA to implement the registration and issuance of Ghana Cards to Ghanaians in Ghana and abroad, is registered with registration No. CS272572017 and is wholly owned by IMS Ltd. 60% of the stake in IMS is owned by the Margins Group while the remaining 40% is held by IDFG of Denmark. In terms of management, all the executive management positions are held by Ghanaian citizens. Determining whether a company is foreign or local is a matter of law. It is not based on conjecture, empty suspicion, emotions or personal preferences.

It is noteworthy that as far back as 2014, NIA had, upon request, submitted the shareholding structure of IMS to the National Security Council Secretariat.

CLAIM 4: FIMS Project not a Pilot

We are unsure of the basis of this claim. It is on record that two different Boards of NIA have directed that the FIMS project be expanded to cover Ghanaians. Indeed, that is the title of the Feasibility Reports that were approved by PPPAC. The FIMS contract also makes reference to the project as a Pilot. In any event, pursuant to the Board meeting of December 2013 invoked the clause of the FIMS Project Agreement to engage IMS on the expanded scope of the PPP Project. Thus began a series of engagements with the appropriate regulatory and approval bodies such as the PPPAC.

The CIDC loan was an additional low cost funding opportunity to reduce funding burden on government and to explore how gaps in funding NIA’s component could be met. Contrary to Mr Griffith’s claim, it was not to replace the PPP but to help government fund its part of it Indeed, the CIDC loan never materialised and as at the time Mr. Griffiths exited NIA he knew that the framework agreement forming the basis of discussion with the China EXIM Bank, which was signed by the governments of Ghana and China had expired in November 2015 and had not been renewed. Using an expired proposal as the basis for casting aspersions on the PPP contract is mind boggling.

CLAIM 5: Alleged conflict of interest and overpriced contract

Mr. Griffiths authoritatively declared that “value for money audit for the FIMS project was conducted by a company owned by a director of FIMS now IMS. This constitutes a serious case of conflict of interest”.

This is a blatant falsehood! Although he did not mention names, there is no doubt that he meant Mr. Frank Oye, a director of IMS. For the records, Mr. Oye’s consultancy firm, Artemis, prepared the feasibility studies for the FIMS project that was submitted to NIA as an unsolicited proposal. Following the approval of the proposal and signing of contract, the Principal Founder of Artemis Consulting was head hunted to join the Margins Group. Furthermore, Artemis Consulting had no leverage in the approval of the FIMS project. We are confounded as to how this constitutes a conflict of interest

Mr. Griffiths also stated that he has “no doubt in [his] mind as an expert in the field that FIMS contract was hugely overpriced”. He did not provide any better and further particulars in support of this serious allegation. If he has any facts to the contrary, same should be made available. He who asserts must prove.


CLAIM 6: The FIMS project has under-delivered.

The production of smart cards under the FIMS Project has not yet commenced because the NIA was considering a smartcard solution for registering nationals and it would not have been prudent to proceed with the FIMS smartcard without due regard to the future aims of NIA. The continued use of the 2-D barcode card in the FIMS was to ensure interoperability between the specifications for a future citizen’s card and that of the current foreigner card. This required a smartcard specification process (standards, size etc) to ensure that the two systems would be interoperable and also meet NIA requirements.

Interoperable cards would require a single ABIS and Identity Ecosystem; and ultimately deliver the benefits of a lower cost of ABIS ownership and easier integration costs to the NIA. IMS is able and ready to issue the smartcards for foreigners following the NIA’s acceptance of the new ID infrastructure that has smartcard capability.


CLAIM 7:
Audit Report by PriceWatherhouse, NIA Internal Audit Report, report from Audit Service, report by Inter-ministerial Committee, made up of the Ministers of Finance, Communication and Justice & Attorney General, etc

In February 2017, His Excellency Dr. Mahamudu Bawumia, the Vice-President of the Republic of Ghana set up a Legal Committee as part of three strategic committees to develop a roadmap for the creation of a single central database of biometric and demographic information of all Ghanaians living in Ghana and abroad, and all foreigners legally resident in Ghana.

The Legal Committee’s principal tasks were to

  • Review all Acts that empower stakeholder agencies to capture and manage biometric and demographic information.
  • Review all existing contracts related to biometric system across the nation to determine if there are any legal show stoppers to the proposed identity system
  • .Review and strengthen the Data Protection Act in order to establish what is required to earn the confidence of the population
  • Review and leverage all enabling policies to mandate the use of a National Identity card in all sectors of the economy.

The Committee comprised of representatives from the National Identification Authority (NIA), the Attorney General’s Department, and the Office of the Vice President. The Committee held several meetings to deliberate on its mandate. It also granted audience to a former CEO of the NIA, Mr. Osei Kwame Griffiths and a team from AB & David, a law firm associated with the Public Private Partnership (PPP) arrangement between NIA and IMS Ltd as well as received a written a response from IMS Ltd.

They established that in 2014, “NIA received a letter from the Presidency directing it to suspend activities on the expansion of the scope of the PPP and to engage all stakeholders about the concerns about the expanded scope. NIA complied with the directive and subsequently sent a report on its broad stakeholder engagement to the Presidency. It further requested for permission to continue with activities on the expanded scope.

Pending receipt of a reply, the Presidency moved NIA from the Presidency to the Ministry of Communications (MoC). Following the movement to MoC, a request for legal opinion on the FIMS Project as well as the expanded scope was sent by the CEO, Dr Cobbah, to the Attorney-General through the sector Minister of Communications.

The MoC sent a policy directive to the NIA informing it of the Government’s intention to engage Messrs EDAPS to roll-out an integrated population registration system”.

Attorney-General’s Legal Opinion

The Legal Committee established that “The Attorney-General gave an opinion dated 25th August, 2015. The opinion concluded that the FIMS Contract is valid and binding. It also affirmed the NIA’s authority to execute a contract such as the expanded scope deriving authority from its enabling Act, (Act 707).

The Attorney-General concluded that the parties had not yet executed a binding contract to expand the scope of the FIMS contract. However, as was also stated in the said opinion, considering the work undertaken by IMS on the expanded scope in preparation for the roll-out, which expansion was at the instance or express request of NIA, an implied contract could be inferred or alternatively, the court could make orders in favour of IMS to avoid any unjust enrichment of NIA, which had evidently benefitted and was permanently positioned to continue to benefit from its collaboration with IMS.


Inter-Ministerial Committee (IMC) on the Contractual Relationship between the NlA and IMS

Notwithstanding the foregoing, the Government set up an IMC on the relationship between NIA and IMS. On the face of the record, the Committee, which comprised Mr. Seth Terkper, Minister for Finance as the Chairman, and Dr. Edward Omane Boamah, Minister for Communications, and Marietta Brew Appiah-Opong, Attorney-General and Minister for Justice, as members, signed its final report on 30th June 2016. However, the said report was only submitted to the Secretary to Cabinet on 19th December 2016, almost six (6) months after the Committee purportedly completed its assignment. There is no evidence that Cabinet considered and decided on the said report.

The Committee’s report appears to contradict the earlier opinion given under the hand of the Attorney-General who incidentally was also a member of the IMC. It is instructive to note that the report has received a strongly-worded rejoinder from IMS rejecting the Committee’s work and conclusions as “inherently biased, misleading and lacking any evidentiary and legal basis.” In its response, IMS threatened to sue should the IMC’s report lead to a breach of any of the “existing contracts” between it and NIA.

A number of the findings in the Committee’s report are, with the greatest respect, factually false and misleading. The following instances would suffice:

  • contrary to the IMC finding, the NIA Board approved the expanded scope at its meeting of December 20, 2013.
  • To say decisions on the expanded scope of the PPP were taken unilaterally is misleading and untrue. The then Head of Technology and Biometrics at NIA, Mr. Osei Kwame Griffiths, was actively involved in the design of the specifications for the expanded scope as already indicated above. Mr. Griffiths and former staff of his Department, Medford Kanyi, spent a month in Hamburg, Germany, porting data from the old Safran Morpho system into the Dermalog system and sending regular updates on the progress of the work through e-mails to the Chairman, and CEO of NIA, Mr. Larry Adjetey and Dr. Cobbah, Mr. Moses Baiden, Mr. Frank Oye and Mr. Emmanuel Selby of IMS
  • NIA’s appearances before the PPPAC included such management members as the then Head of Finance, Philemon Mennia, Head of Internal Control, Suleiman Sualihu, Head of Policy, Research and Monitoring, Chris Bogart, Head of Technology and Biometrics, Osei Kwame Griffiths, Head of Administration, Legal and Compliance, Josef Iroko and Principal Accountant, Kenneth Boateng.
  • Contrary to the IMC finding, the PPPAC also “gave approval in principle to NIA on the above project subject to the submission of all contracts documents related to the Project for review and final approval.”
  • Concerning the alleged danger of allowing a private company to register Ghanaians, it has always been the case that under the law (Act 750) custodian of the national ID register shall always be the Executive Secretary of the NIA for the public interest. Under the expanded scope, the NIA was going to oversee the registration process, in line with its statutory mandate. In practice, even under the FIMS project, IMS refers identity verification requests to NIA for processing. Clauses 21 and 22 of the FIMS Project Agreement on “Ownership and Custody of Data” and “Data Protection” respectively, also confirm the foregoing.
  • The concerns against the involvement of a private company in national ID management as stated by the IMC is weakened by its own recommendation that another company, EDAPS, also a private-cum- foreign company, be given the same job! EDPAS Overseas is Dubai, U.A.E based. Notwithstanding the change of its name to National Security Ventures for purposes best known to EDAPS.

In its 42-page report, the Legal Committee concluded as follows:

“Conclusions

There is a binding contract between NIA and IMS to produce biometric ID cards for foreigners resident in Ghana under the FIMS contract.

The collaboration between NIA and IMS has resulted in the registration and instant issuance in real time of biometric national ID cards to foreigners resident in Ghana.

The equipment and software procured and installed in Ghana under the FIMS contract, have been upgraded and expanded to ensure the effective registration and instant issuance of biometric national ID cards to all Ghanaians in real time.

On the bases of the several valid contracts and approvals, IMS has undertaken significant expansion of the scope of its original contract with NIA dated 4th May 2012 and procured the requisite technology/equipment/software to extend its registration and instant card issuance in real time to cover all citizens. The said contracts and approvals are:

  1. FIMS Project Agreement dated 4th May 2012, particularly, clause 16 thereof;
  2. The MoU signed in Hamburg, Germany, on 14th October 2012;
  3. PPA approval dated 18th October 2012 for NIA to sole – source Dermalog to procure 455 MRWs to finish the biometric registration in northern Ghana;
  4. Supply Contract dated 23rd August 2013, between NIA, Dermalog and IDFG Denmark for the supply of Mobile Verification Systems and Mobile Registration Workstations (MRWs);
  5. Board Approval of 20th December 2013;
  6. Addendum to the above Supply Contract of August 2013 to enable, inter alia, the following:
    1. expansion of NIA AFIS currently deployed for FIMS to issue the non-citizen cards;
    2. provision of AFIS software and licenses including the development, integration and customization of the AFIS software up to 40 million records;
    3. provision of printers to enable instant printing of national ID cards to Ghanaians;
    4. porting;
    5. project management;
    6. installation;
    7. testing and commissioning; and
    8. design, specification and installation of expanded call centre and social media platform.
  7. Addendum to FIMS Project Agreement dated 31st December 2013 by which IMS transferred FIMS AFIX early to NIA;
  8. Supplemental Joint Escrow Instructions adjusting procedures for setoff claims under contract in (vi) above;
  9. Second Supplemental Joint Escrow Instructions by the PPP parties for CAL Bank Ltd. to apply FIMS revenue collected in the Project Escrow Account to pay for the loan facility IMS secured to purchase additional equipment and software to complete the construction of a Central Site for the instant issuance of ID cards to all citizens;
  10. Second Addendum to Project Agreement between the PPP parties for financial support transaction for the supply of additional equipment for Central Site/instant issuance system to enable the instant issuance of Ghana cards to Ghanaians;
  11. PPA letter dated 7th May 2015 regarding the revision in the scope of works and confirming the lawfulness of the ratification of the expanded scope by NIA without seeking prior approval from PPA, as the cost of the expansion fell within the PPA approved threshold communicated earlier to NIA”.

Based on the foregoing, the Legal Committee recommended that:

“Recommendations

In view of Government’s stated commitment to issuing national Identity Cards to citizens by February 2018, it is recommended that the expanded scope, which has been designed to do just that and has taken several years of collaborative engagement between the PPP partners, be approved subject to any enhancements, upgrades, etc., for deployment.

It would amount to willfully causing financial loss to the state for all that has been done, including the procurement of the Central Site AFIS and other related hardware, stakeholder engagements, data porting from the old system into the Dermalog AFIS which has been expanded to be able to hold 40,000,000 million records, be allowed to go waste.

Indeed, the system is ready for use and is fit for purpose. NIA has used portions of its revenue from the FIMS Project to pay for the Central Site. Thus, the system belongs to the NIA and by extension, the Republic of Ghana. Any dispute can be resolved under the mechanisms provided for in the FIMS contract that is being expanded, or indeed in any subsequent contracts that may be signed regarding the project. In the light of the significant shortfalls in the report of the IMC and the false and misleading statements it contains some of which have been pointed out in this writeup and by the IMS rejoinder, it is recommended that the said report be treated with utmost caution and little weight ought to be placed on it. Indeed, the private partner and other key stakeholders whose inputs would have also enriched and enlightened the Committee’s work were not called for their side of the story to be heard and factored into the Committee’s report. In short, on the face of the records, the Committee, in my considered and respectful opinion violated the sacred audi alteram partem rule. No person or entity should be judged without a fair hearing in which each party is given the opportunity to respond to the evidence against them.

The legal opinion delivered by the Attorney-General dated 25th August 2015 generally represents the true legal position as far as the relationship between the parties herein is concerned. It must be preferred to the one dated 30th June 2016 which was purportedly presented to Cabinet on 19th December 2016 (almost 6 months after its completion).

The Legal opinion of 25th August 2015 admits of no ambiguity and should not have been disturbed. The IMC’s report of 30th June 2016 appeared to be an attempt to roll back the clear analysis of the situation between the parties as captured in the legal opinion of 25th August 2015.

The NIA/FIMS relationship is governed by a series of valid contracts and approvals, the unilateral abrogation of any of which may trigger needless litigation.

It is recommended that the sanity and validity of the NIA/FIMS agreements be upheld and the NIA be supported to pursue the implementation of the NIS and to issue Ghana cards to all qualified persons accordingly.

It is further recommended that, negotiations be initiated between NIA and FIMS to address any concerns about value for money, data security and ownership of the SPV to ensure the effective achievement of the objects of the NIA and to best serve the national interest”.

It is also worth stating here that NIA’s Head of Legal who also doubled as the recorder at Board meetings until he was replaced under the tenure of Mr. Griffiths, was involved in the process of gathering the relevant documentation for the first opinion rendered by the Attorney-General. However, he was not involved or asked to play any role in the proceedings of the Inter Ministerial Committee, which from the records available to NIA, had Mr. Griffiths and a former staff of NIA, Mr. Chris Bogart as representatives of NIA before the said Inter-Ministerial Committee. In fact, these reports were made available to the Head of Legal only after the assumption of office by the current CEO.

In light of the above, it should not be surprising that Mr. Griffiths’ article was heavy in placing reliance on the work of the Inter Ministerial Committee while completely silent on the first opinion of the Attorney-General dated 25th August 2015.

CLAIM 8: Value for Money Audit by PPA

Mr. Griffiths claims that “As an expert in the field of Biometric technology, let me state categorically that the PPA, lacks the required exposure, expertise and competence to conduct value for money audit for an AFIS System. During NIA’s dealings with the Chinese firm, CIDC, Crown Agents was contracted in 2013 to conduct Value for Money and it turned out that even the $115 million the Chinese had proposed as the total cost for the entire solution, was overpriced by about $30 million. It is my view that all documentation relating to the current $1.2 billion NIS contract be submitted to Crown Agents for a competent Value for Money review”.

In the first instance, Mr. Griffiths is not even aware that the PPA has established the Due Diligence /Value for Money Unit1 then he proceeded to insult the hard working staff of the public agency as lacking the “required exposure, expertise and competence to conduct value for money audit for an AFIS System.” He has not seen the value for money audit report of PPA yet he feels as confident as to rubbish the report. Just like he demonstrated with the foreign solutions providers he has so favourably spoken of, the only value for money report he would accept must be one done by a foreign entity. We might want to ask of Mr. Griffiths if Mr. Akwasi Osei Pianim, his predecessor Head of Technical at NIA and a member of the PPA team that conducted the value for money audit, lacked the “required exposure, expertise and competence to conduct value for money audit for an AFIS System.”


CLAIM 9:

“For the 2D Barcode cards, there are enough blank cards, printing technology and consumables to print them for the age bracket below 15 years. The six MX6000s printers, owned by NIA either require upgrades to current version or could be traded in for the newer one. The six printers are capable of a combined throughput of 9000 cards per hour. This is enough to print cards for the whole of the African continent.

In the case of the high specs smartcard for the population above 15 years of age, the specifications are not so different from those received from companies mentioned above except for the memory, which among the offers were mostly between 80-128K . One will therefore wonder what is so different that will lead to a cost that is so prohibitive.”

As indicated in previous releases on the PPP Project, all the 2 D bar codes would be used for 0-14 population. 2 new MX6100 printers have been acquired and installed at NIA premises that are capable of doing deferred and instant printing of cards. The projected cost of the PPP Project is quite clear in its outline and breakdown as it relates to the partners. It is not enough to say that the cost is prohibitive. Surely, the assertion that the cost is prohibitive must be measured against a counter proposal with detailed outline breakdown as the current PPP Project.


Conclusion
https://www.ghanaweb.com/GhanaHomePage/NewsArchive/PPA-creates-units-to-tackle-sole-sourcing-576611

The PPP Project contract has been signed. The contract and related components went through the required regulatory and approval processes, including Cabinet and Parliamentary approvals. This was after Project agreement has been reviewed by the relevant bodies such as the PID and Legal divisions of the Ministry of Finance, the PPPAC and the Attorney-General. If Mr. Griffiths feels strongly that something untoward had occurred, in spite of the instant narrative, he is entitled to use the appropriate channels available to him in a democratic Ghana to prove his claim(s). Prior to the above, by letter dated 22nd May 2017, Government directed the National Identification NIA to immediately engage with Identity Management Systems Ltd (IMS), a subsidiary of the Margins Group, to “agree on modalities to ensure the efficient roll-out of NIS project no later than 15th September 2017”.

The said directive followed Government’s acceptance of the key recommendations of a Technical Committee established by the Vice President to develop a roadmap for implementing the NIS Project. Based on the recommendations of the Technical Committee, Government had “determined that the existing agreement between NIA and IMS constitutes a viable and effective vehicle for the implementation of a modern, robust and reliable NIS for Ghana consistent with Government’s stated policy commitments”. Government was to build on an existing Public Private Partnership (PPP) arrangement between NIA and IMS, which it described as constituting a turnkey solution for the NIS Project.

It is instructive to note that, the Technical Committee comprised 16 individuals, most of whom were heads of ICT or operations at a number of statutory public service institutions involved in the issuance of identity cards or interested in data management. They included the Social Security and National Insurance Trust (SSNIT), National Health Insurance Authority (NHIA) Driver and Vehicle Licensing Authority (DVLA), Electoral Commission (EC), Ghana Immigration Service (GIS) and the NIA. Other members were from the National Information Technology Agency (NITA), Ghana Interbank Payment and Settlements System (GHIPPS), National Development Planning Commission (NDPC), Births and Deaths Registry, and the Office of the Vice-President.

The NIA supports accountability and welcomes public scrutiny of its statutory activities, including the PPP Project, which was done in a transparent manner as permitted by law. It was our belief in transparency that led to the involvement of reputable firms such as EY Ghana and AB & David in the PPP process as additional layers of oversight.

While we do not begrudge Mr. Griffiths for describing himself as “an expert in the field of Biometric Technology” it is interesting to note that he was the CEO of NIA from July 2015 to 27th January 2017 and yet he could not deploy his expertise to revive the fortunes of NIA during his tenure.

Issued: NATIONAL IDENTIFICATION AUTHORITY
20th June, 2018.