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The National Communications Authority (NCA), and the Ministry of Communications and Digitalization, have both denied having information on the government’s SIM card registration application, GH SELF SIM REG APP.
The NCA and the ministries made this clear in separate responses to right to information requests made by The Fourth Estate seeking information on the contract, cost and procedures used in procuring the services of the appl developers.
On September 13, 2022, The Fourth Estate requested information from the National Communications Authority on the SIM card registration application.
The NCA directed The Fourth Estate to the Ministry of Finance and the Ministry of Communications and Digitalization. The NCA said it referred the request because it was only an “implementing” agency and that the aforementioned ministries were “better placed to provide the requested information”.
However, when the same information was sought from the Ministry of Communications and Digitalization, the Ministry asked The Fourth Estate to redirect the request to the NCA, indicating that “the requested information is in the custody of (the) National Communications Authority.”
The Ministry of Finance, on the other hand, told The Fourth Estate that it has no information about the SIM card application in its records.
“We wish to indicate that from our internal investigation, the requested information does not exist in the Ministry of Finance.”
When asked about information on the application, the Chief Executive Officer of the Ghana Chamber of Telecommunications, Dr. Ken Ashigbey, wondered how the NCA would not have the “information when they signed the contract”.
He indicated that the NCA engaged the telecom companies only on the technical aspects of the App.
“That is an app that they have developed. We were only involved in the technical side of things. But in terms of the contractual obligations, this is their service provider, so our members are not involved.”
Asked whether it would have been better for NCA to have consulted the telcos in the procurement process, he said his outfit is more “interested” in the functionality of the App, and that the Authority had the discretion to choose who they wanted to work with.
App is not user friendly
A Technology Consultant, Maximus Ametorgoh, in an interview with The Fourth Estate said the App’s “design is not user-friendly. There are a lot of vulnerabilities within the app.”
As a result of these bottlenecks, there have been several complaints by subscribers. Out of about 3.05k reviews on the app, only 49 were positive.
They complain about having to pay the mandated 5 cedis multiple times because of problems with the app.
“When you are doing your registration, you pay the 5 cedis before you enter your biodata. And a lot of the time, people are terminated at that point. And there is no design functionality in place where you can log into that account and continue the process. You have to log in all over again and pay the 5 cedis. And then some people have been charged multiple times,” Maximus told The Fourth Estate.
Maximus further disclosed that even before the Ministry of Communications and Digitalization launched the self-registration app, it was “charging” the telecom companies 5 cedis per registration.
He also corroborated the company our research had indicated produced the app; a Nigerian company called XCEL INC LTD.
According to the tech analyst, the NCA told stakeholders the app would be hosted in Ghana. But after a reverse engineering done by his colleague, they found out the app was being hosted on servers owned by Google and Amazon.
The reverse engineering carried out by Maximus’ colleague, a developer who prefers to be anonymous shows that the app is being hosted in the U.S.A and Belgium.
In September 2022, Stranek-Africa also revealed that the data captured by XCEL INC LMT was “uploaded to an Amazon Web service server which is not controlled or owned by the government.”
This, experts say, contravenes sections 17 and 18 of the Data Protection Act, 2012 (Act 843) and Article 18 (2) of the 1992 Constitution.
Maximus added that “there is no evidence to prove” that XCEL INC LTD is a “registered data controller” in Ghana. He wondered how the company should have the authority to collect and process the data of Ghanaians.
“When you go on play store the app is owned by XCEL not NCA or Ministry of Communications. Why should a third-party person own our data and be collecting the data on our behalf? Whether they’re transmitting it to NCA’s servers {or not} what are the security layers in place to ensure their system is secured and protected so nobody’s data leaks and why should they use a Nigerian company to do that?” he quizzed.
Implications
Maximus then pointed out that the data on the 42 million SIM cards in use in the country are at risk of being piped onto a database that stakeholders don’t know if it’s secure, safe or protected.
“So, who is going to make sure that nobody can hack into their system, nobody will steal our data, nobody will use our data for verification elsewhere? Nobody has given us any guarantee in that respect.”
The Minister of Communications and Digitalization, Ursula Owusu-Ekuful, on 21 October 2022, announced that all unregistered SIM Cards would be deactivated by the end of October. Although the deadline has ended, the government has not made public whether it has indeed blocked all unregistered SIM Cards except data-only SIM cards, which have up until the end of November 2022 to register or be blocked.
She indicated that out of the 42,749,662 million SIM cards in the country, 18,930,664 had been fully registered.
With more than 60 percent of the current SIM Cards to be blocked, Maximus pointed out that the government’s revenue would be affected.
“So, if MTN says last year we paid GHS2 billion in taxes and this year they say they are paying only GHS1 billion, it means that we’ve lost GHS1 billion in government revenue. But someone has collected 5 cedis per subscriber somewhere that they haven’t accounted for. Those are the implications.”
The bottom line is that the telcos are going to be affected because, according to him, the investments they have made to register their subscribers have increased their operating costs but will not be reaped if the millions left to register are blocked.
“What is going to happen is that we are going to eat into the telcos’ bottom line because they’re going to invest money in registering their subscribers; they’re going to invest in using field officers to register their subscribers. There are so many line items that they’re going to put in their budget and the government is not going to get the expected revenue they want from the telcos.”
Background of SIM card registration exercise by the Communications Ministry
The SIM card re-registration exercise, which started on October 1, 2021, with the aim of creating a secure and accurate SIM database was scheduled to end on March 31, 2022, but has faced several challenges.
The only identification document accepted for the SIM re-registration exercise is the Ghana card. However, businesses and foreign nationals are allowed to use their business registration documents and passports respectively.
Meanwhile, for many Ghanaians, acquiring the Ghana Card to do the needful has been a tussle. Some individuals who applied for their Ghana cards as far back as 2019 are yet to receive them.
According to the National Identification Authority, 17,277,348 people have registered for the card out of a population of 30,800,000 and 15,962,885 cards have been issued. The inability of the NIA to issue Ghana Cards to the rest of the population has hindered some persons from re-registering their SIM cards. Thus, there has been a continuous extension of the deadline following calls from the public and other stakeholders.
The initial deadline, which was extended from March to July 31, and later to September 30, 2022, was to allow subscribers who had completed only stage one of the process to finish stage two. Stage one is completed when subscribers successfully link their Ghana cards to their SIM cards. And stage two is when the biometric details of subscribers are captured and verified. The extension was also to give subscribers who had not registered or received their Ghana Card time to acquire it.
On August 25, 2022, the GH SIM SELF REG App was launched as an alternative for telecom subscribers to complete the SIM card re-registration exercise with their Ghana Cards at a fee of GH₵5. It was to make it convenient for subscribers to register and expedite the process.
On September 5, 2022, the NCA directed telecommunications companies to block outgoing calls and data services for SIM cards that had not been fully registered on a rotational basis for two days in a week. The punitive measures were to ensure compliance because, according to the Minister of Communications and Digitalisation, some individuals were simply being adamant about registering their SIM cards.
She claimed there was a “90% drop in SIM reregistration as soon as the first deadline was extended on 21st March. Until a week ago, there were no queues, people started going to register when they realized that the deadline was imminent after going to sleep.”
The directive was met with criticisms, especially from the opposition National Democratic Congress (NDC). The party described the directive as “unlawful”.
A pressure group and some individuals also sued the NCA on the same grounds.
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The writers of this report, Thelma Amedeku & Edmund Agyemang Boateng are Fellows of the Next Generation Investigative Journalism Fellowship at the Media Foundation for West Africa.
