Q653 Lord Faulks: […] Very briefly, I detect that one of the real problems for all your organisations is the uncertainty and quite what it will mean in commercial and cost terms if the Bill becomes law. Have you made some estimate in your own minds as to what the costs will be? Bearing in mind that you can of course recoup those sums from the Government, have you any general comments beyond those that you have already made in that respect?

Stephen Collins: It is very hard to estimate what the costs will be when we do not know what we would be expected precisely to do under the secondary legislation on the code of practice. That is very difficult. We know how much it costs to retain data. We could calculate on that basis. What would not be in the cost-reimbursable piece are all sorts of other things that have not been considered by the Home Office. Those would include things such as additional hardware databases for segmentation of the data from UK users—even if we could identity them, which I am not sure we could—into separate databases. A part of the draft Bill talks about the level of security required. It is almost an absolute that the data must be securely stored—not “reasonably securely” but “securely”: 100%. That creates an awful lot more cost as well. We will need redundant systems, so everything would have to be duplicated and put into two locations. We have ongoing personnel costs to manage all these new sites and databases and to respond to requests. There is a whole host of other costs that are not considered at this stage by the Home Office. It appears that it has just looked at the cost of data storage. That is just the tip of the iceberg in cost terms.

Q654 Lord Faulks: So you do not think that its estimates are realistic?

Stephen Collins: I think they are really unrealistic—and the costs will increase. Even if we gave you a figure now, I would be willing to bet money that in 10 years’ time that cost will have multiplied grotesquely.

Simon Milner: I very much support what Mr Collins said. In the same way as we do not understand how the Government have worked out their numbers, I cannot give you a number because we simply find it very difficult to understand what is actually being required of us. We expect that this would be a very significant engineering project. […]