Highlighting Risks for Vulnerable Groups Including AIMD Users and Electromagnetic hypersensitivity EHS Individuals.
The EM Radiation Research Trust is responding to alarming news reports regarding the Government’s proposed mandatory digital ID system, commonly referred to as “BritCard.” We have serious concerns about the potential impacts on public health, civil liberties, and data protection particularly for vulnerable populations such as users of Active Implantable Medical Devices (AIMDs), individuals with electromagnetic hypersensitivity (EHS), and immune-compromised individuals.
Below is the full text of our letter, sent to the Home Affairs Select Committee.
Sent via email on 25th September 2025
From:
Eileen O’Connor
Director, EM Radiation Research Trust
To:
The Right Honourable Dame Karen Bradley MP
Chair of the Home Affairs Select Committee
House of Commons
Cc:
Bill Esterson MP
Brian Stein CBE, Chairman, EM Radiation Research Trust
Dear Dame Bradley MP,
I write on behalf of the EM Radiation Research Trust (RRT), a UK-based public charity dedicated to researching and raising awareness of the health risks associated with electromagnetic fields (EMFs), particularly for vulnerable populations such as users of Active Implantable Medical Devices (AIMDs), individuals with electromagnetic hypersensitivity (EHS), and immune-compromised individuals.
We are deeply concerned about the Government’s proposed mandatory digital ID system (“BritCard”), reportedly intended to tackle illegal immigration. It is important to emphasise that the issue this proposal claims to address is illegal immigration and individuals without identification, and therefore does not and should not affect the general public. Most British citizens already possess valid forms of ID throughout their lifetime, such as birth certificates, passports, or driving licences. Using the general population as a “solution” to a problem affecting only those without ID is unnecessary, disproportionate, and an infringement upon the rights of law-abiding UK citizens.
Public Health Concerns
- ♦ Active Implantable Medical Devices (AIMDs): EMF exposure can interfere with pacemakers, cochlear implants, and other devices. ICNIRP guidelines (2020) explicitly exclude AIMD users from protection, leaving them unprotected.
- ♦ Electromagnetic Hypersensitivity (EHS): Exposure to EMFs can cause ill health for sensitive individuals, a condition increasingly recognised by UK courts.
- ♦ Carcinogenic Potential: The WHO/IARC 2025 systematic review confirms evidence of carcinogenic effects of radiofrequency (RF) radiation in laboratory animals. RF radiation remains classified as a Group 2B possible human carcinogen. However, following recent research, some independent doctors and scientists are calling for this classification to be upgraded to Group 1, a known human carcinogen.
- ♦ Other Risks: Non-thermal effects, such as microwave hearing, are not adequately assessed under current compliance standards.
Legal, Civil Liberties, and Data Protection Considerations
- ♦ Equality Act 2010, Section 149: Requires public authorities to consider health vulnerabilities and prevent discrimination.
- ♦ Court precedents (Steven Thomas v Cheltenham Borough Council [2025] EWCA Civ 259; Yasmin Skelt v First Secretary of State, 2003) confirm that credible health concerns related to EMFs cannot be dismissed solely on the basis of ICNIRP compliance.
- ♦ Data protection: Mandatory digital ID raises serious concerns under UK GDPR and the Data Protection Act 2018, centralising sensitive personal data and potentially creating targets for cyberattacks.
Conclusion
The EM Radiation Research Trust strongly opposes the introduction of a mandatory digital ID system based on public health, equality, civil liberties, and data protection grounds. Policymakers should prioritise safety, privacy, public health, and transparency, before considering any system that increases EMF exposure or centralises sensitive personal data.
For reference, our full submission to the Government consultation is available here:
https://radiationresearch.org/today-we-submitted-evidence-to-parliaments-digital-id-inquiry-heres-how-you-can-too/
Yours sincerely,
Eileen O’Connor
Director
EM Radiation Research Trust
Address: Chairman: Mr. Brian Stein CBE, Chetwode House, Leicester Road,
Melton Mowbray, Leicestershire, LE13 1GA