

Hold the Singapore Government Accountable over TraceTogether and SafeEntry Data use


Hold the Singapore Government Accountable over TraceTogether and SafeEntry Data use
The Issue
In 2020, in light of the Covid-19 pandemic, the Singapore government introduced the TraceTogether and SafeEntry systems to facilitate contact tracing efforts. SafeEntry requires people to "check in" or log their entry into locations, as well as to "check out" or log their exit from locations. TraceTogether was a proximity tracking system, designed to trace the close contacts of infected persons so that they could be isolated and quarantined before they become infectious.
In June 2020, the Singapore government announced that it would be rolling out TraceTogether hardware devices, for people without smartphones (such as the elderly). A petition, "Singapore says 'No' to wearable devices for Covid-19 contact tracing", was created, garnering 55,409 signatures. The petition expressed opposition to these devices, citing concerns that these devices were tracking devices and could be used for mass surveillance.
To assuage the public, the Singapore government invited prominent hackers such as Andrew "bunnie" Huang, Sean Cross "xobs" and two others to a teardown session. Based on the physical characteristics of the devices, the hackers concluded that: “If our inference [about its chip] is correct, we can safely say the Token cannot do anything other than Bluetooth-related activities. It cannot do GPS, Wi-Fi or cellular. It can’t sense your orientation or record your conversations.”
After this, in December 2020, the Singapore government then annouced that a new SafeEntry Gateway device (which combines both the SafeEntry and TraceTogether systems) had been on trial since October 2020. On 17th May 2021, TraceTogether-only SafeEntry check-ins (via the SafeEntry Gateways) was made mandatory at most public venues: "Other modes of SafeEntry check-in, such as the scanning of QR codes with a mobile phone camera or the SingPass app, will be discontinued from this date [...] Check-ins from May 17 must be performed using a TraceTogether app or token at venues that experience "higher throughput" of visitors, such as malls, workplaces and places of worship, and where people are likely to be in close proximity for prolonged periods." As such, having the TraceTogether app and/or token (working in conjunction with the SafeEntry Gateway device) was a compulsory prerequisite to accessing venues.
Combined, this means that TraceTogether and SafeEntry provide an enormous amount of data about a person's physical interactions and whereabouts. It is not known exactly if, or how both datasets are combined, what further data can be generated from this combination, and for what uses.
In early 2021, it was then revealed that the police had accessed TraceTogether data for a murder investigation. This caused the people's trust in TraceTogether and SafeEntry to be diminished. To add salt to injury, the Singapore government then passed a bill allowing TraceTogether and SafeEntry to be used in criminal investigations for "serious offenses". This caused an uproar, culminating in Minister of Foreign Affairs Vivian Balakrishnan taking ""full responsibility" for the Government's error in not stating that contact tracing data from TraceTogether is not exempt from the Criminal Procedure Code for criminal investigations" during a Parliament session on 2nd February 2021; Parliament was debating "on a Bill to limit the use of TraceTogether data for investigations into seven types of serious crimes".
On 5th February 2024, Smart Nation published a press release "Discontinuation of TraceTogether and SafeEntry". It states two key points: Firstly, that "TraceTogether and SafeEntry systems [are] no longer in use". Secondly, that "All COVID-19 related personal contact tracing data derived from TraceTogether and SafeEntry [have been] deleted as of 1 February 2024, with the exception of the TraceTogether data pertaining to a murder case in May 2020", "which will be retained by the Singapore Police Force (SPF) indefinitely".
The timeline of this contradicts or undermines a much earlier press release by the Ministry of Health (MOH), published on 9th February 2023 (i.e. the year before), which states: "Over the past few months, as the pandemic situation stabilised, the Government has progressively stepped down TT and SE. We no longer require infected persons to submit TT data, SE data is no longer being collected, and MOH has deleted all identifiable TT and SE data from its servers and databases."
In other words, there is a discrepancy between (1) Smart Nation's February 2024 press release's stipulation that TraceTogether and SafeEntry data has been deleted as of 1st February 2024, and (2) MOH's February 2023 press release's stipulation that "all identifiable TT and SE data" has been deleted as of 2023. What accounts for this discrepancy? It could mean a distinction between "identifiable" data and other kinds of data – in which case, what does each category refer to? Alternatively or additionally, it could mean that specific data has only been deleted from the servers and/or databases of specific ministries, agencies, statutory board and/or departments – in which case, where has the data been retained, and what data has been retained?
We, the undersigned, urge the government to uphold transparency and be accountable to Singaporeans by answering the following questions:
- The MOH announced that data had already been deleted in 2023. Does the recent Smart Nation press release mean that all copies of TraceTogether and SafeEntry data have been deleted, and thus is not in the possession of any government agency? Does the Smart Nation press release mean that additional data has already been deleted? What data was deleted?
- What is the definition of "identifiable data"? What data does that include, and what data is not identifiable? How exactly will data that is non-identifiable be used, if at all?
- What data does "COVID-19 related personal contact tracing data derived from TraceTogether and SafeEntry" include? What data collected by TraceTogether and SafeEntry does not fall under this category? How is that data being used?
- Has Tracetogether and SafeEntry data been used for any police investigation besides the Punggol Field murder case? If so, what data was used and how?
- SafeEntry Gateways are linked to specific locations (such as mall entrances). Given that this effectively combines the SafeEntry and TraceTogether systems together, wouldn't this then create location datapoints that could be used to track a person’s movements, which may invalidate bunnie et al’s assessments?
- The public was promised that TraceTogether data would be used only for contact tracing – it was revealed that the Criminal Procedure Code allows police officers to use TraceTogether data for criminal investigations and overrides TraceTogether’s privacy policies. While the government has provided its reasoning on the basis of compromise in the name of public safety and security in stopping specific types of crimes, this does not guarantee reliable calibration of the safeguarding of actual public interest. Who has the mandate and discretion to reliably determine the calibration – especially given that institutional trust has already been broken via the government’s previous opacity in its breach of confidentiality?

The Issue
In 2020, in light of the Covid-19 pandemic, the Singapore government introduced the TraceTogether and SafeEntry systems to facilitate contact tracing efforts. SafeEntry requires people to "check in" or log their entry into locations, as well as to "check out" or log their exit from locations. TraceTogether was a proximity tracking system, designed to trace the close contacts of infected persons so that they could be isolated and quarantined before they become infectious.
In June 2020, the Singapore government announced that it would be rolling out TraceTogether hardware devices, for people without smartphones (such as the elderly). A petition, "Singapore says 'No' to wearable devices for Covid-19 contact tracing", was created, garnering 55,409 signatures. The petition expressed opposition to these devices, citing concerns that these devices were tracking devices and could be used for mass surveillance.
To assuage the public, the Singapore government invited prominent hackers such as Andrew "bunnie" Huang, Sean Cross "xobs" and two others to a teardown session. Based on the physical characteristics of the devices, the hackers concluded that: “If our inference [about its chip] is correct, we can safely say the Token cannot do anything other than Bluetooth-related activities. It cannot do GPS, Wi-Fi or cellular. It can’t sense your orientation or record your conversations.”
After this, in December 2020, the Singapore government then annouced that a new SafeEntry Gateway device (which combines both the SafeEntry and TraceTogether systems) had been on trial since October 2020. On 17th May 2021, TraceTogether-only SafeEntry check-ins (via the SafeEntry Gateways) was made mandatory at most public venues: "Other modes of SafeEntry check-in, such as the scanning of QR codes with a mobile phone camera or the SingPass app, will be discontinued from this date [...] Check-ins from May 17 must be performed using a TraceTogether app or token at venues that experience "higher throughput" of visitors, such as malls, workplaces and places of worship, and where people are likely to be in close proximity for prolonged periods." As such, having the TraceTogether app and/or token (working in conjunction with the SafeEntry Gateway device) was a compulsory prerequisite to accessing venues.
Combined, this means that TraceTogether and SafeEntry provide an enormous amount of data about a person's physical interactions and whereabouts. It is not known exactly if, or how both datasets are combined, what further data can be generated from this combination, and for what uses.
In early 2021, it was then revealed that the police had accessed TraceTogether data for a murder investigation. This caused the people's trust in TraceTogether and SafeEntry to be diminished. To add salt to injury, the Singapore government then passed a bill allowing TraceTogether and SafeEntry to be used in criminal investigations for "serious offenses". This caused an uproar, culminating in Minister of Foreign Affairs Vivian Balakrishnan taking ""full responsibility" for the Government's error in not stating that contact tracing data from TraceTogether is not exempt from the Criminal Procedure Code for criminal investigations" during a Parliament session on 2nd February 2021; Parliament was debating "on a Bill to limit the use of TraceTogether data for investigations into seven types of serious crimes".
On 5th February 2024, Smart Nation published a press release "Discontinuation of TraceTogether and SafeEntry". It states two key points: Firstly, that "TraceTogether and SafeEntry systems [are] no longer in use". Secondly, that "All COVID-19 related personal contact tracing data derived from TraceTogether and SafeEntry [have been] deleted as of 1 February 2024, with the exception of the TraceTogether data pertaining to a murder case in May 2020", "which will be retained by the Singapore Police Force (SPF) indefinitely".
The timeline of this contradicts or undermines a much earlier press release by the Ministry of Health (MOH), published on 9th February 2023 (i.e. the year before), which states: "Over the past few months, as the pandemic situation stabilised, the Government has progressively stepped down TT and SE. We no longer require infected persons to submit TT data, SE data is no longer being collected, and MOH has deleted all identifiable TT and SE data from its servers and databases."
In other words, there is a discrepancy between (1) Smart Nation's February 2024 press release's stipulation that TraceTogether and SafeEntry data has been deleted as of 1st February 2024, and (2) MOH's February 2023 press release's stipulation that "all identifiable TT and SE data" has been deleted as of 2023. What accounts for this discrepancy? It could mean a distinction between "identifiable" data and other kinds of data – in which case, what does each category refer to? Alternatively or additionally, it could mean that specific data has only been deleted from the servers and/or databases of specific ministries, agencies, statutory board and/or departments – in which case, where has the data been retained, and what data has been retained?
We, the undersigned, urge the government to uphold transparency and be accountable to Singaporeans by answering the following questions:
- The MOH announced that data had already been deleted in 2023. Does the recent Smart Nation press release mean that all copies of TraceTogether and SafeEntry data have been deleted, and thus is not in the possession of any government agency? Does the Smart Nation press release mean that additional data has already been deleted? What data was deleted?
- What is the definition of "identifiable data"? What data does that include, and what data is not identifiable? How exactly will data that is non-identifiable be used, if at all?
- What data does "COVID-19 related personal contact tracing data derived from TraceTogether and SafeEntry" include? What data collected by TraceTogether and SafeEntry does not fall under this category? How is that data being used?
- Has Tracetogether and SafeEntry data been used for any police investigation besides the Punggol Field murder case? If so, what data was used and how?
- SafeEntry Gateways are linked to specific locations (such as mall entrances). Given that this effectively combines the SafeEntry and TraceTogether systems together, wouldn't this then create location datapoints that could be used to track a person’s movements, which may invalidate bunnie et al’s assessments?
- The public was promised that TraceTogether data would be used only for contact tracing – it was revealed that the Criminal Procedure Code allows police officers to use TraceTogether data for criminal investigations and overrides TraceTogether’s privacy policies. While the government has provided its reasoning on the basis of compromise in the name of public safety and security in stopping specific types of crimes, this does not guarantee reliable calibration of the safeguarding of actual public interest. Who has the mandate and discretion to reliably determine the calibration – especially given that institutional trust has already been broken via the government’s previous opacity in its breach of confidentiality?

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Petition created on 15 February 2024