I have not been paid by MTN, neither am I their advocate…

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I have not been paid by MTN, neither am I their advocate, but I am a keen observer in the Ghanaian technology space, and I am concerned with quite a few incidents that have been happening recently.

1. There are 42 million active telco subscribers in Ghana
2. To successfully handle SIM card biometric registrations within the period that the NCA is specifying, there have to be 233,333 registrations per day.
3. A huge majority of these subscribers are MTN subscribers
4. MTN cannot possibly handle the logistics of registering over 100,000 (assuming their 57% active subscriber market share)
5. It is not MTN’s responsibility to incur extra costs and logistics to ramp up registration centers just to fulfil this regulatory obligation out of a vacuum when it does not represent a budgeted or direct operational activity but a government directive which was executed without the necessary consultation.
6. The execution of any project involving interactions beyond 100,000 people in a country like Ghana requires extensive project management planning, process flow management and execution, with everything from infrastructure to people management to logistics being very critical to the success of the event.
7. To scale it up to a projected 100,000 a day and think a private entity whose core mandate is to handle telecommunications infrastructre to deploy this with very little notice is a recipe for disaster.
8. To make it even worse, this process flow calls for dependencies, where subscribers have to get National ID cards, whose production and distribution is not defined as an even process and is still evolving on its own logistics and timelines.
9. ANyone who has done basic project management knows that for the end result of any project to work out, the dependencies must be fully accounted for. In this case, the dependencies are uncertain, even making a daunting task even more challenging.
10. Assuming that there are even 300 MTN outlets for registration ( dont believe there are) it means that each of those outlets needs to handle 300 applications per day successfully to be able to fulfill the quota required.
11. This is where it even gets more complex: The applications and the software is also dependent on ANOTHER 3rd Party. This third party IS A PRIVATE ENTITY.

The complexity here is this: We are not privy to any Service level Agreement (SLA) where their software is benchmarked to be online with say 90% uptime. That aspect of the operation is opaque, meaning that even if MTN provides location and everything, the performance of the software can compromise the process.

Sadly, there are reportedly serious performance issues with the software and probably serious security implications as to whether the software service provider is even authorized to handle biometric data of Ghanaians. Even websites now have to have signoffs on privacy issues, yet nobody has raised eyebrows on why a completely private entity has unrestricted access to our biometric data as citizens without any avenue for consent.

Moreover, we have no idea whether they are compliant with ISO 27001, ISO 27002 or ISO 27032 with relation to cybersecurity certifications that are internationally recognized and standardized or those of the 2020 ISO/IEC 39794 standards which are critical requirements for such an operation.

The legality of the duplication of processes and the interoperability of this provider’s database with the NIA and SSNIT hasnt even been discussed.

For a system operating with such erratic downtime, the consequences of a sophisticated man in the middle attack and the consequent cyber fraud that can cripple literally every electronically initiated commercial or statutory activity in this country cannot be underrated and there seems to be nobody ready to underwrite that risk or take responsibility for that risk.

In the midst of all of this is complete silence from the side of those who have authored this mess, the Ministry of Communication, in providing further guidelines and assuaging the public.

But hey, this is Ghana. In the comments section, we will see whether we really care, or we are just doing party politics with serious issues.

I leave you to decide as the discussions in the comments commence.

Have a nice day.

PS: Mind you that the Electoral Commission of Ghana spent $150 million on voter registration for 18 million people using similar circumstances and over 20,000 polling centers.