Hostile Odds

According to The Guardian, the government, in its attempt to create a “hostile environment” for illegal immigrants, has recruited the banks into doing immigration checks on 70m current accounts.  That is just slightly more than the population of the UK, and not everyone in the UK actually has a Current Account.  I can only assume this means the government is asking the banks to check the immigration status of literally every current account holder in the UK!

In the process, according to the Guardian story, the “Home Office expects to identify 6,000 visa overstayers, failed asylum seekers, and foreign national offenders.”  The guardian story also informs us that “The accounts of those identified will be closed down or frozen.”

The Guardian story continues “Banks have been told to adopt a default position of telling customers to take up the matter with the Home Office if a mistake has been made, even if they provide a passport or biometric residence permit showing they are lawfully present in Britain…

“The new legislation requires the banks to check the identity of every current account holder against a Home Office supplied database held by an anti-fraud organisation, Cifas.”  So it looks like this is going to be an exercise in matching names of current account holders to a list of potential immigration rule violators.  So if someone who is here illegally has opened the bank account with a slightly different spelling of their name, they will be missed and there will be a false negative.  If someone with a perfectly legal right to be here just happens to have the same name as someone who is on this list, there will be a false positive.  That person will find their account frozen and will have to deal with the Home Office in order to unfreeze it – an experience which by all accounts compares favourably with banging one’s head against a wall.

Let’s run the numbers and assume that the Home Office are correct in their estimate that there are 6,000 people here illegally who also have current accounts. Given their recent performance overestimating the number of foreign students who overstay their visa by over 2,000%, that is stretching credulity.  But let’s go with that for the sake of making some estimates and crunching some numbers. 

Let’s consider some scenarios around the success rate.  Some estimates have suggested the Home Office’s error rate could be as high as 10% (see below).   

So we’ll use that as a worst case scenario.  We’ll run the numbers assuming the Home Office accuracy rate is:

• 90%;
• 99%;
• 99.9%; and
• 99.99%.

Then we can calculate the number of false positives we would expect given this level of accuracy, given that there are 69,994,000 current accounts held by people with every right to be in the UK.  The numbers are in the table below:

Accuracy	90%	99%	99.90%	99.99%
Error Rate	10.00%	1.00%	0.10%	0.01%
No. Of False Positives	6,999,400	699,940	69,994	6,999

In order to cut the number of false positives to be of the same order of magnitude as the number of people they are hoping to catch, the Home Office would need to be 99.99% accurate.  Even then, there are about 1,000 more false positives than the number of overstayers the Home Office expects to catch.  So it would be more likely that someone whose bank account was frozen as a result of this review had a right to be in the UK than not.  Remember this is the same Home Office that was once declared “unfit for purpose” by the minister in charge of it (who was quoting a senior civil servant).  The same Home Office that violated a court order in deporting someone to Afghanistan and may well have been in contempt of court.   The same Home Office that “accidentally” sent letters to over a hundred European citizens exercising their treaty rights living in the UK legally telling them they should pack their bags or face arrest.  To suggest that this Home Office can hit that target level of accuracy is patently absurd.

The next step is to make some assumptions about how quickly civil servants can clear up the confusion that results from false positives and set them right.  We will assume a somewhat optimistic 5 person hours per false positive to clear it all up.  Given some of the stories linked to above, this may be absurdly optimistic.  Remember that is just the time of the civil servants at the Home Office, it is not taking into account the time and effort of the people caught up in this dragnet, neither is it taking into account the time of bank staff.  We will further assume 500 civil servants are dedicated to this task and the cost of civil servant time to the tax payer is £24 per hour as this is the figure used to turn down Freedom of Information requests on the grounds they would cost too much.  On the assumption that these people work 8 hour days and 260 days per year, we can work out how many days and years it would take to clear all the false positives as well.  Those calculations are in the next table:

Accuracy	90%	99%	99.90%	99.99%
Person Hours to clear false positives	34,997,000	3,499,700	349,970	34,997
Hours to clear	69,994	6,999	700	70
Days to clear	8,749	875	87	9
Years to clear	34	3	0	0
Cost	£839,928,000	£83,992,800	£8,399,280	£839,928

Even on the optimistic assumption that the Home Office cuts the proportion of false positives to 10% of what it has been in the past, it would still take around 3 years to process all of the false positives coming out of this exercise.  That is a very long time for some people to be spending in limbo, with no access to their bank accounts, unable to pay the rent, mortgage, unable to pay the gas bill, unable to pay for groceries.  All to try and catch a measly 6,000 or so visa over stayers.

The Home Office might be able to catch a few more illegal immigrants if they expand their search parameters and look for common mis-spellings of the names that are on their list or other variations.  This would reduce the number of false negatives, but it would increase the number of false positives, leaving more innocent people with no means of paying the rent or mortgage or gas bill.

Yes, I’ve had to make a lot of assumptions in making these calculations.  However, at every point, the assumptions I've made are fairly reasonable.  The Home Office could cut the time it takes to clear the number of false positives by dedicating more civil servants to the task.  However this would not cut the total number of hours taken and would not cut the cost of dealing with the backlog, which could run as high as £840m.  Neither would it do much to cut the costs, panic and trauma imposed on thousands, maybe millions of perfectly innocent people.

The numbers work out this way, with so many more false positives than actual illegal immigrants caught because the number of illegal immigrants is just so small (even by the Home Office’s wildly inflated estimates) relative to the size of the UK population as a whole.  Yet the political hysteria surrounding this issue has reached fevered proportions.  The words of Sir Humphrey have never been so apt: “If you’re going to do this damned silly thing, don’t do it in this damned silly way.”

Indeed, these numbers and costs are so dire, that it is amazing to think that anyone could have thought this is a good idea.  Yet this is happening as a result of an Act of Parliament that was passed with full parliamentary scrutiny in both Houses.  Just imagine what these ministers and civil servants would get up to if a law were passed giving them the authority to make their own laws with the full force of an Act of Parliament with no Parliamentary scrutiny whatsoever!