Sunday, 17 October 2021

Sources for conspirationist...

I found on Telegram these very interesting links, unfortunately I can't remember from whom...

The pandemic aka the(plandemic)

The events that have taken place over the past 19 months have all been in the pipeline for numerous years maybe even centuries.

Strategic planning over multiple event scenarios and outcomes that our philanthropist overlords roll out on the human population without your vote or say so. To fit their specific agenda and reduce the carbon emitters or useless eaters in the words of klaus schwab and his friend bill gates👹

So this list of their plans will help educate you on the agendas bestowed upon all of us. Brought to your family’s door by the world economic forum, Rockefeller’s,  John Hopkins institution, Bill and Melinda gates foundation, WHO, CDC, FDA all with the help of your corrupt local government agencies and politicians!

Agenda 21

Agenda 30

Agenda 50

cyberpolygon 2021

Covid 19 - The great reset klaus Schwab.

Event 201

Operation Dark Winter

Operation crimson contagion.

Operation lockstep Rockefeller’s.

operation Cygnus uk gov

Uk influenza preparedness plan

National pandemic influenza plan

Spars pandemic (2025-2028)
The next event.

Pandemic influenza vaccine storage (March 2020)

Coronavirus act 2020(slavery act)

All this brought to you by the pharmaceutical global drugs cartel, they care so much about your health they plan how to cull you years in advance. Stay ahead of the game be informed people know the plans so you can counter the agenda and narrative.

Stay strong stay healthy stay ahead of the globalist plan!  

Friday, 15 October 2021

Wednesday, 13 October 2021

EU/USA /UK– 45,250 Covid-19 injection related deaths

EU/USA /UK– 45,250 Covid-19 injection related deaths, plus over 7.4 million injuries now reported by almost 2.2 million people by end Sept/ early Oct 2021.

Link to US ADR Data :

EUdraVigilance covers EEA countries and also some non EEA countries. Link to the database:

Link to the UK ADR’s by the MHRA:

Monday, 11 October 2021

The Use of Chip Implants for Workers


This paper briefly explains the technology of RFID chip implants; explores current applications; and considers legal, ethical, health, and security issues relating to their potential use in the workplace. 

Compulsory use would be likely to encounter legal and ethical challenges. Even voluntary use might be subject to challenges, for example, on data protection grounds. It seems that the risks of adverse health effects in humans might be considerably less than some have suggested, although they cannot be entirely discounted without better evidence. Contrarily, although there are indications of improvements in recent years, the benefits in terms of enhanced security might not be deliverable with the vulnerability of current RFID chip technology. 

This document was prepared by Milieu/IOM Ltd at the request of the Committee on Employment and Social Affairs of the European Parliament.

Un'altra cospirazione...

This document was requested by the European Parliament's Committee on Employment and 

Social Affairs (EMPL).


Richard GRAVELING, IOM Consulting Ltd, Edinburgh, UK. 

Thomas WINSKI, IOM Consulting Ltd, Edinburgh, UK. 

Ken DIXON, IOM Consulting Ltd 

Contributions by: 

David CABRELLI, School of Law, University of Edinburgh, Edinburgh (legal) 

Marc DESMULLIEZ, School of Engineering and Physical Sciences, Heriot Watt University, 

Edinburgh (technical) 

Murdo MACDONALD, Society, Religion and Technology Project, Church of Scotland, Edinburgh 


Peer review: 

Hilary Cowie, IOM Consulting Ltd, Edinburgh, UK. 

Joanne Crawford, IOM Consulting Ltd, Edinburgh, UK. 

Claire Dupont, Milieu Ltd, Brussels 


Stefan SCHULZ 


Laurent HAMERS 


Original: EN 


Policy departments provide in-house and external expertise to support EP committees and 

other parliamentary bodies in shaping legislation and exercising democratic scrutiny over EU 

internal policies. 

To contact Policy Department A or to subscribe to its newsletter please write to: 

Policy Department A: Economic and Scientific Policy 

European Parliament 

B-1047 Brussels 


Manuscript completed in January 2018 

© European Union, 2018 

This document is available on the Internet at: 


The opinions expressed in this document are the sole responsibility of the author and do not 

necessarily represent the official position of the European Parliament. 

Reproduction and translation for non-commercial purposes are authorised, provided the 

source is acknowledged and the publisher is given prior notice and sent a copy. 

The Use of Chip Implants for Workers 

PE 614.209 3 








3.1. Introduction 15 

3.2. Manufacture 15 

3.3. Providers, Users and Wearers 16 

3.4. Workplace Applications 17 


4.1. Introduction: Current Legislation of Relevance 19 

4.2. Data Protection Regulation 20 

4.3. Human Rights 21 

4.4. Legal Duties of Workers 23 

4.5. Law of Constructive Dismissal 23 

4.6. Religious Discrimination Laws 24 

4.7. Ownership of Data 24 


5.1. Introduction 26 

5.2. Safety 27 

5.3. Efficacy 27 

5.4. Privacy / Dignity 27 

5.5. Religious Beliefs 28 

5.6. Equity 28 

5.7. Informed Consent 28 


6.1. Introduction 30 

6.2. Possible Carcinogenic Effects 31 

6.3. Other Possible Dermal Effects 32 

6.4. Possible Effects on MRI Use 32 

6.5. Migration 33 

6.6. Effect on Pharmaceuticals 34 


7.1. The issues 35 

7.2. Solutions 36 



8.1. Overall implications 37 

Policy Department A: Economic and Scientific Policy 


 4 PE 614.209 

8.2. Health issues 38 

8.3. Security concerns 38 

8.4. Ethical barriers 39 

8.5. Legal issues 39 

8.6. Overall outcome 40 

8.7. Future considerations 40 




The Use of Chip Implants for Workers 

PE 614.209 5 








Chief executive officer 

Computed Tomography 

the European Convention on Human Rights 

European Union 

Food and Drug Administration 

GDPR General Data Protection Regulation 






Information and Communication Technologies 


International Organization for Standardization 


Magnetic resonance imaging 

PIN Personal Identification Number 

RFID Radio-Frequency IDentification 



Treaty on the Functioning of the European Union 

United Kingdom 


Policy Department A: Economic and Scientific Policy 


 6 PE 614.209 



Figure 1: An RFID chip on a hand (for scale) 12 

Figure 2: Components of an RFID system and mode of operation 13 



The Use of Chip Implants for Workers 

PE 614.209 7 



This paper presents various issues relating to the possible use of RFID chip implants in the 

workplace. Commissioned against a background of awareness of a growing number of 

voluntary uses of implants, it briefly explains RFID chip technology; explores current 

applications; and examines the legal, ethical, health and safety, and security issues relating 

to their potential use in the workplace. 

The Technology 

Implantable RFID chips consist of three parts: an integrated circuit that stores 

information, a means of acquiring power for that circuit, and an antenna for receiving and 

transmitting signals between that circuit and an (external) reader. These parts are 

encapsulated within a biocompatible material (usually a form of glass) for insertion under the 

skin. Some versions of the chips, such as those implanted in animals usually incorporate a 

coating that apparently promotes cell growth around the chip.   

The chip is used in conjunction with a reader that broadcasts an electromagnetic signal that 

any RFID chip within its range and signal frequency will respond to. Drawing its power from 

this signal, the RFID chip responds with an encrypted signal that is decoded by the reader. 

The information contained in this signal depends on the application. Thus, in the case of a 

simple implanted RFID chip used for identification, the signal might be some form of 

identification code which is processed and analysed to permit (or refuse) access. More 

complex approaches can involve including a secondary form of identification on the chip, such 

as a photograph of the wearer for biometric analysis, or a retinal scan for similar purposes. 

In some applications, such as medical uses, the chip can also carry information about the 

wearer such as medical notes. 

Use in the Workplace and Elsewhere  

Estimates of the extent of the use of RFID chip implants across all applications in humans 

vary from 2 000 to 10 000 worldwide, although there is no systematic record. It could be 

suggested that those providing such numbers have a degree of vested interest in maximising 

their profile. 

Chips almost all seem to have been implanted solely on a voluntary basis, not always for 

work-related applications. One exception might be within the Mexican Attorney General’s 

Office where press reports suggest that a large number of staff were chipped as part of an 

access-control system for part of the department (some reports also suggest that they were 

also intended as an anti-kidnap measure). Reports do not indicate whether or not this was 


Legal Issues 

Although other legislation is relevant, the main legal challenges to the compulsory use of 

RFID chips in the workplace would seem to derive from data protection and human rights 

legislation. Even where RFID chip use was truly voluntary this legislation would still be 

relevant, especially in respect of data protection. In the case of voluntary applications, it 

would be necessary to ensure that the use was genuinely voluntary and that no disadvantage 

was seen to accrue to those individuals who declined to have a chip implanted or that any 

pressures (direct or indirect) were exerted on those invited to participate. 

Ethical Concerns 

In an overlap with legal arguments, ethical concerns stem in part from Articles 1 and 3 of 

the Charter of Fundamental Rights of the EU relating to the inviolability of human dignity and 

the human body. Further ethical issues relate to health and safety concerns; the efficacy of 

Policy Department A: Economic and Scientific Policy 


 8 PE 614.209 

the technology as a secure system; equity and choice; and (again in a parallel with legal 

issues) religious concerns. 

Health and Safety Worries  

Concerns have been expressed over the health and safety of RFID chip implants in four main 

areas: carcinogenicity; migration; interactions with MRI signals and the impact on 

pharmaceutical effectiveness. There have been no systematic studies of health impacts in 

human wearers. 

There are a number of reports of carcinogenic effects, mainly in specific strains of mice. 

However, it appears that this probably reflects the unique sensitivity of these species and is 

not a trans-species phenomenon. Potential mechanisms suggest any similar effects in 

humans to be unlikely (although currently impossible to discount completely with the present 

state of knowledge).  

Studies of the potential interactions between MRI scanning and chip implants appear to have 

excluded any significant effects, although local details on a scan can be physically masked 

by the chip overlying the area of interest. This problem can easily be overcome by inserting 

the chips into areas of the body where scans are not likely to be required.  

It is suggested that inter-species differences in the characteristics of sub-dermal layers 

makes significant migration unlikely, although this cannot be categorically excluded. Early 

reports of implanted chips suggested the upper arm as an injection site, although more recent 

applications seem to favour the web of skin between the thumb and first finger (usually of 

the left hand in right-hand dominant individuals). This has the benefit of being relatively 

unobtrusive as well as perhaps less likely to encounter significant migration due to anatomical 

constraints compared to the upper arm. 

Concerns regarding the impact of RFID technology on the efficacy of pharmaceuticals appear 

to stem from the proposed use of RFID tags as a security measure to label containers of 

pharmaceuticals. This would therefore involve scanning of the bulk compound. Any risk of an 

effect in vivo in scanning the compound circulating within the blood stream when briefly 

scanning for an RFID chip would be extremely limited as only a small proportion of the 

substance would be exposed during scanning. 

Possible Security Problems 

It would seem that, at present, the RFID chip technology (which is essentially similar to that 

used in credit cards and similar smart card systems) is not entirely secure. Security concerns 

include eavesdropping; cloning; disabling; and unauthorised tag modification. Although since 

their initial development there have been a number of schemes promoted to increase their 

security, usually with some form of encryption, it seems from the literature that each idea is 

swiftly followed by other researchers reporting some way of breaching the security measure 


Overall Themes 

One integrated theme regarding the use of RFID chips in the workplace would seem to be 

that of human rights; covering the inviolability of the human body and an individual’s right 

to privacy. These issues would seem to reflect both ethical concerns and the legal provisions 

currently in place safeguarding those rights. It would seem that legal measures to reduce 

those rights, in order to allow compulsory RFID chip implants in the workplace, would need 

to reflect over-riding demands, perhaps on the grounds of national security, sufficient to 

justify overturning those provisions. As part of this it would almost certainly be necessary to 

demonstrate that there was no effective alternative to their use. The evidence that the RFID 

technology is insecure can be seen as undermining the case for such a development, at least 

at present. 

The Use of Chip Implants for Workers 

PE 614.209 9 

However, even were such technological challenges to be overcome, it must be recognised 

that the use of such implants evokes strong objections (including religious concerns) and any 

compulsion would need to provide for appropriate exemptions in such circumstances. 

Given such challenges, unless there is seen to be an overwhelming need or demand for 

implantable RFID chips in the workplace, then adopting a waiting game would seem to be 

the preferred option.   

Where implant use is voluntary (as is the case at present) then legal considerations in respect 

of data protection still apply with regard to any information which might be collected by data 

logging systems as part of such use regarding access, patterns of use, etc. It has also been 

suggested that a degree of regulation of their implantation is desirable, whether implantation 

is voluntary or compulsory. 

Policy Department A: Economic and Scientific Policy 


 10 PE 614.209 


This paper presents various issues relating to the possible use of RFID chip implants in the 


Specifically, the paper addresses: 

• Current state of play regarding the use of radio-frequency identification (RFID) chip 

implants for workers, by exploring the technology involved (Summary of Technology 

Involved, Chapter 2); and ongoing and planned cases of workplace use (Workplace 

Uses, Chapter 3). 

• Issues associated with the use of chip implants for workers: 

o Legal issues (Chapter 4). 

o Ethical considerations (Chapter 5). 

o Health and safety hazards/risks (Chapter 6). 

o Security issues (Chapter 7). 

A concluding chapter then draws these various strands together in an integrated narrative 

(Chapter 8).  

Although a number of extensive reviews on RFIDs and implants have been identified, these 

are frequently not specific to RFID implants, nor do they usually relate to their use in a 

workplace context. For example, Sade (2007) writes of RFIDs in a medical context in 

addressing the ethical issues (where medical benefits add a further layer of complexity to be 

considered) while Hildebrandt and Anrig (2012) write of the ethical issues relating to 

Information and Communication Technologies (ICT) implants in general, not just RFIDs. The 

present paper extracts issues from these commentaries relevant to implanting RFIDs in a 

workplace context. 

Implantable RFID chips can be passive – designed to be ‘read only’ – or active, where data 

can be stored on the chip and the device has a ‘read-write’ capability. Although chips are also 

available that transmit a signal (allowing them to be used for tracking applications) the power 

requirements for such devices mean that they need to be a larger size (to contain a battery 

capable of storing and providing the necessary power) or need to be connected to a separate 

power source. Both of these factors mitigate against their ready use as implanted devices. 

Only the passive devices are considered in this paper, although many of the considerations 

concerning their use will also apply to active devices. 


The Use of Chip Implants for Workers 

PE 614.209 11 



• RFID chips come in passive and active forms with the passive form primarily 

addressed in this paper. 

• Passive chips are ‘read only’, allowing information stored on them to be accessed by 

an appropriate reader. Active chips are ‘read & write’ allowing additional information 

to be written to the chip in situ. 

• The first implantable RFID chips for humans were patented in around 1997. 

• The biocompatibility of RFID chips is covered by parts of ISO 10993. 

• The RFID chip contains an antenna, a power storage device and an integrated circuit. 

• RFID chip systems require the chip, a reader and a network and/or a computer. 


This Chapter briefly explores (and explains) the basic form and function of implantable RFID 


The particular type of chip in question is known as a passive RFID (read only) as opposed to 

more sophisticated ‘active’ devices which can have additional data added to them in-situ or 

can transmit a tracking signal (Sade, 2007). As noted earlier, this paper refers primarily to 

the passive versions as these are the type used in existing workplace applications. However, 

the use of active RFID chips is briefly considered where appropriate.  

The engineering principles underlying current RFID technology were first reported in 1948 

(Stockman, 1948). However, the first patent for using human-implanted RFID chips was not 

granted until July 1997 as ”an apparatus for tracking and recovering humans”1. A “syringe-

implantable” device for animal use had been patented a few years earlier in 19932. 

The patented device was intended to be used as a safeguard against kidnapping and to 

facilitate prompt medical emergency procedure in the case of acute illness, for example a 

heart attack. In 2004, a human-implantable microchip, called VeriChip®, received FDA 

approval as a medical device.  

As well as their use for animal human tagging, RFID chips are used in a wide variety of 

applications ranging from passport control to toxic and medical waste management (Roberts, 


The chip consists of three parts: an integrated circuit, a means of acquiring power from the 

reader, and an antenna for receiving signals from and transmitting signals to a reader.  

For human (and animal) use, these must be encapsulated within a biocompatible material 

(usually a form of glass). Non-implantable devices used for commercial applications or animal 

applications may be encapsulated in polymers that are unsuitable for human implantation.  

The chip material in contact with human tissue must not harm, inflame or change the 

composition of that tissue. Undesirable local or system effects in the human body must be 

avoided. Moreover, the chemical stability of the encapsulating packaging is essential, with 

good resistance to attacks from the harsh internal environment. Inside the human body, 

hydrolytic, oxidative and enzymatic mechanisms take place that can modify the chemical 

structure of polymers leading to biodegradation (Donaldson, 1976). Glasses and ceramics 

can withstand long periods of resistance to gas or fluid ingress (defined as permeability) 

ranging from months, or tens of years, depending on the material thickness. 


1 Personal tracking and recovery system US 5629678 A 

2 Syringe-implantable identification transponder. US 5211129 A 

Policy Department A: Economic and Scientific Policy 


 12 PE 614.209 

Assessment of the biocompatibility of implanted medical devices is covered by ISO 10993 

with extensive in vitro and in vivo tests required. Tests include cytotoxicity, sensitization, 

irritation, introcutaneous reactivity, acute systemic toxicity or pyrogenicity, subchronic 

toxicity, genotoxicity, implantation, chronic toxicity and carcinogenicity, depending on the 

class of medical devices considered. Implantable RFID chips would be covered by relevant 

parts of this Standard. 

As noted above, some versions of implantable RFID chips incorporate a coating over part of 

the glass sheath. Various accounts present this as a non-slip layer, to reduce/prevent chip 

migration, or as a coating to encourage ‘assimilation’ into body connective tissue by 

supporting cell growth. Alternatively, versions without such a coating can be regarded as 

reducing the extent of assimilation into body tissues and therefore of easing the subsequent 

removal of the chip should that become necessary. However, it follows that these will be 

more liable to migrate, to the extent that this is possible (see Chapter 6).  Figure 1 shows an 

example of an implantable glass RFID chip. 

Figure 1: An RFID chip on a hand (for scale) 


Source: Chip photos courtesy of Three Square Market, River Falls, Wisconsin 

The RFID chips are used as part of a system that has four component parts: 

• The RFID chip (also known as a tag) stores information about the chipped person 

and sends this information back to the reader when a signal of the correct frequency 

is sent to the chip by the RFID reader for interrogation. As it is a TRANSmitter and a 

resPONDER, RFID chips are classified as ‘transponders’. As noted above, there are 

two main categories of chip. The passive chip gets its electrical power from the 

electromagnetic waves emitted by the RFID reader. The active chip has its own battery 

that tends to limit its useful life and add additional components to be contained within 

the device. Both types of chip have their own antenna (or coil).  

• The RFID reader is a device that broadcasts an electromagnetic signal that any RFID 

chip within range and operating on the same frequency will respond to. Drawing its 

power from this signal, the RFID chip will respond with an encrypted signal. The RFID 

reader will decode this and pass the resulting information to a network. 

• The network gets the decrypted information from the reader and transmits it to a 

computer for processing. Sometimes, a simple interface between the computer and 

the reader is used instead of a network. 

• The computer (also called the host or controller) controls the RFID reader with 

software controls. It processes the information received from the network to enable 

an operator to make a decision.  

The type of information transmitted depends on the application. Thus, in the case of a simple 

implanted RFID chip used for identification, it might be some form of identification code which 

is processed and analysed to permit (or refuse) access to an area or installation. More 

complex devices can include a secondary form of identification on the chip. For example, it 

is understood that a photograph of the wearer, or a retinal scan can be included which would 

permit the use of facial or biometric identification to enhance security. 

The Use of Chip Implants for Workers 

PE 614.209 13 

Note that the RFID reader, network and computer can physically be a single device and that 

the ‘operator’ can be an automated function. Figure 2 illustrates such a system in schematic 


Indications of the basic operation of a chip system are provided by Hassan et al (2015), who 

summarised the basic operations of a RFID system (referring to tags rather than chips): 

• The tag enters the RF field of the reader. 

• RF signal powers the tag. 

• The tag transmits its data. 

• The reader captures data. 

• The reader sends data to the computer. 

• The computer sends data to the reader. 

• (The reader transmits data to the tag) – Not in a passive device. 

Not all systems necessarily include all these steps. For example, there is no necessity for 

data to be returned to the chip in a purely passive device (although some otherwise passive 

systems include such a mechanism as part of security encryption procedures). The ID and 

other characteristics (time, location, etc.) might then be stored on a computer for future 

reference and analysis. 

Figure 2: Components of an RFID system and mode of operation 


Source: Marc Desmulliez & Richard Graveling 

The chips have the potential to have additional information stored on them, which can then 

be read directly without the need for recourse to other devices. This provides the basis for a 

number of medical applications where medical information relating to the ‘wearer’ is included 

on the chip to avoid any need to interrogate a computer system.  

Although not necessary for understanding this basic functionality, the RFID chips and readers 

used for implantation utilise what is known as near-field coupling (also called magnetic 

induction coupling) in which the reader generates a magnetic field. Any device passing 

through the proximity of this magnetic field, such as an RFID chip, will create a voltage that 

can charge a capacitor in the chip. This stores enough energy to power the integral 

semiconductor within the chip. Once this is powered, the identification data that it holds is 

Policy Department A: Economic and Scientific Policy 


 14 PE 614.209 

then transmitted by the coil of the chip which creates its own magnetic field. This produces 

a disturbance in the magnetic field of the reader that the reader will detect and decode. The 

information represented by the decoded signal has thus wirelessly been transmitted from the 

chip to the reader. 

Although generally presented in the context of ID systems, requiring the chip to be held close 

to the reader, the technology exists to install more powerful reader/transmitters. According 

to Singh et al (2017) the read range for passive chips is up to about 40 feet (~12 metres), 

although it is likely that the smaller size of chip used for implant purposes will significantly 

limit this range as increasing the read range of the chip requires the use of a larger antenna 

within it. 


The Use of Chip Implants for Workers 

PE 614.209 15 



• Estimates of the number of chips implanted worldwide range from 3 000 – 10 000. 

• To date, although some companies have adopted the technology, this seems to be 

limited to a very small (but well-publicised) number, almost all of which provide them 

on a purely voluntary basis. 

• Most of the wearers appear to be private individuals who do so ‘for convenience’ (e.g. 

to unlock doors) or to embrace the technology. 

• In terms of utility, the most significant adoption would seem to be that of the Swedish 

Rail company SJ who enable wearers to utilise their chip to verify ticket details.  

• In a workplace context the most significant reported application would appear to be 

that involving the Mexican Attorney General where press reports indicate the use of 

RFID chips as part of enhanced security access. It is not known whether or not this 

use was voluntary. 

3.1. Introduction 

This chapter explores: 

• Current and previous workplace applications. 

• Current extent of workplace use. 

• Current and previous workplace users. 

A number of applications of RFID chip implants were identified through press and other 

reports on the internet. From these, contacts were identified and approached for details 

relating to dates adopted, type of chips used, number of workers implanted, what the chips 

were being used for, observations regarding their use, controversies and lessons learned. 

Opinions were also gathered in respect of perceptions and awareness of issues such as health 

and security. 

Searches sought to identify Manufacturers of the RFID chips, Providers of the chips for 

others to apply, organisations who could be regarded as Users of RFID chip technology and 

Wearers (those individuals with chips inserted). As a further channel, information was 

sought from animal users (vets) regarding the source of their chips, in an alternative 

approach to identifying chip manufacturers. 

3.2. Manufacture 

Many of the early reports regarding the human use of RFID chips referred to a common 

manufacturing source, VeriChip®. Believed to be the first organisation to gain Food and 

Drugs Administration (FDA) approval for the use of their chip in humans, VeriChip® was made 

by VeriMed (part of PositiveID) but, in 2010, PositiveID ceased marketing the VeriChip® 

apparently due to ‘poor acceptance’3. A minority partner (Digital Angel) continued to market 

RFID chips. However, after merging with Veriteq they also ceased marketing the devices for 

human implantation. 

In the UK, RFID chips for animal use are provided by PETtrac, who also provide an 

accompanying animal ID service for tracing purposes. PETtrac is part of AVID ID Systems 

Inc who manufacture and provide these devices in North America, Spain and the UK. 

Enquiries through their UK base indicated that, following instructions from their US parent 



Policy Department A: Economic and Scientific Policy 


 16 PE 614.209 

company, they do not approve their products for human use. No other animal chip 

manufacturer has been identified. 

Enquiries of Three Square Market, a USA-based company who promote the use of RFID 

technology (including RFID implants) indicated that the RFID chips they provide are 

manufactured by a company called Cybernise. It has not been possible to trace this US-

based company, which appears not to have any internet profile, for further information. 

One source4 suggests that Biohax (see below) buy-in the actual chip as a commercially 

available device, add an antenna and encapsulate these within the glass cylinder. However 

we have been unable to confirm this as the company is currently subject to confidentiality 

agreements with its supplier. 

No further information regarding RFID chip manufacture for human use has been identified.  

3.3. Providers, Users and Wearers 

Three Square Market can be regarded as Providers and Users. They also include wearers 

amongst their workforce. In telephone discussions, the President indicated that they were 

relative newcomers to the field, having only adopted the technology this year. They see their 

main interest as the uses to which RFID chips or tags can be put – which extend beyond their 

use in human implants – and they primarily develop RFID applications to include implanted 

and non-implanted applications. 

The President estimates that they have implanted around 1 000 people on a voluntary basis 

(although they also offer the chip in a wearable wristband option) and considered a figure of 

around 5 000 globally to be a reasonable estimate. He was unaware of any reports of adverse 

reactions to these implants, indicating that he had one personally. He regarded the implanted 

chip as ‘noticeable’, although it generally went unremarked unless attention was specifically 

drawn to it. 

The President of Three Square Market conceded that there were issues relating to the security 

of the technology at present, meaning that current applications could be vulnerable, but 

indicated that he felt solutions to this vulnerability to be relatively close. He indicated that he 

understood that requiring workers to receive an implanted device was illegal in current US 


In a recent, non-work development of interest, the Swedish rail company SJ is understood 

to be trialling a system where travellers can use a chip to ‘store’ their train ticket. Details of 

their ticket are stored on the SJ ticket system and their chip code provides a link to those 

details5. However, SJ are not offering to carry out implants themselves but making the ticket 

facility available to those who already have an RFID chip implanted. According to press 

reports, it is suggested that about 2 000 people in Sweden already have a chip implant. 

This figure of 2 000 was reiterated by the CEO of a second company Biohax (based in 

Sweden), who also Provide and Use RFID chips. The CEO, himself a wearer, indicated that 

he was an early adopter of the technology having personally had a chip implant in 1996. 

They provide (implant) individuals with the chip for personal use, although they do encourage 

adopters to generate further interest through their employer. To date, the Biohax CEO  has 

no indications of any employer persuading or coercing a worker to have an implant. He was 

strongly against this due to it being a violation of personal integrity. He also indicated that it 

would be illegal in Sweden to do so. As well as being personally responsible for implantations 

he has removed four chips, two of which were in himself (he experimented with alternative 

body sites at one time).  





The Use of Chip Implants for Workers 

PE 614.209 17 

He indicated that the other two were removed for personal reasons and that there were no 

indications of adverse effects of the implantations. However, he was very aware that the 

implantation process itself carried potential health risks and was strongly in favour of 

regulation/certification of this process to ensure that it was carried out in suitably aseptic 

conditions. He was aware of some of the reported health concerns (in mice) although he was 

not concerned as he felt that these were not applicable to humans and might be a reflection 

of the type of (coated) chip used. 

On the issue of migration he was aware that the chips could remain mobile for some time (in 

that they could become realigned with other body structures) but was unaware of any more 

severe migration. 

On security, the Biohax CEO also acknowledged the vulnerability of the technology to hacking 

or other interference. He indicated that he always adopted a secondary form of security such 

as a Personal Identification Number (PIN) where this was a concern, although for non-critical 

uses (such as gym access) this did not apply. 

A further provider is the organisation Dangerous Things, who supply an RFID kit for self-

administration (including an insertion syringe) over the internet6. Through this, any would-

be wearer can access the technology and self-inject. 

3.4. Workplace Applications 

Searching the literature for examples of workplace applications regularly leads to hearsay or 

descriptions of workplace cases without any names or details. Below are examples of cases 

identified in the literature, with some available details: 

• Mexican legal department – Foster and Jaeger (2007) cite a claim that “the attorney 

general of Mexico and 18 of his staff had chips implanted to allow them to gain access 

to certain high-security areas”. This seems to be a reduction from earlier reports that 

160 staff had received such implants with more perhaps to follow. Neither report 

documents whether or not this was a voluntary programme, although indications that 

the chips were a requirement for staff to be able to enter a new anti-crime information 

centre suggests a degree of compulsion7. Roberts (2006) also reports this application, 

stating that it was intended as a kidnap control measure as well as being used for 

access purposes. 

• – Two workers were implanted with an RFID chip for the purpose of 

increasing the layer of security within their organisation. Ease of integration into their 

current system was described as an attractive quality. However, a vulnerability to 

hackers was later identified and shared with CityWatchers who reported to not have 

been aware of the vulnerability8. 

• EpicCenter – Approximately 150 workers were implanted at the beginning of January 

2015. The purpose of this was to allow access through secure doors and the main 

benefit was reported to be convenience. No controversies were described9.  

• A Belgian marketing company NewFusion has been reported as ‘offering’ their workers 

the chips. “The chips contain personal information and provide access to the 

company's IT systems and headquarters, replacing existing ID cards”.  The report 

does not indicate how many have accepted the offer10.  









Policy Department A: Economic and Scientific Policy 


 18 PE 614.209 

Estimates of the number of implants in use vary widely and are not available from any 

accredited source. The sources suggest from 2 000 to 10 000. As well as those figures 

indicated by providers during telephone interviews they include: 

• “So far around 3,000 people in Sweden have a microchip.” (2017)11. 

• “Despite the limited uses, human chip implant manufacturer Dangerous Things told 

AFP that there are now around 10,000 “cyborgs” — or humans with digital chips in 

them — across the globe.” (2015)12. 

• “around 2,000 people have already been injected with RFID implants for humans” 









The Use of Chip Implants for Workers 

PE 614.209 19 



• Although other legislation is relevant, the main legal challenges to the compulsory use 

of RFID chips in the workplace would seem to derive from data protection and human 

rights legislation.  

• Data protection would encompass ongoing and subsequent use of data acquired 

through chip use. 

• Human rights considerations stem, in particular, from Article 8 of the European 

Convention on Human Rights (“ECHR”), which safeguards a worker’s right to respect 

for his private and family life. 

• The technology appears to provoke significant opposition on religious grounds 

amongst some parties and this might lead to issues regarding religious discrimination 


4.1. Introduction: Current Legislation of Relevance 

At EU level, there is no specific, tailored and/or comprehensive legislation, case law or 

regulatory regime banning, restricting or controlling the use of microchip implants by 

employers. The only foray in the EU regulatory field to date in this regard is the Active 

Implantable Medical Devices Directive of 199014 (and subsequent amendments)15. However, 

this does not prescribe how employers ought to use microchips in the workplace, but simply 

harmonises the use, inspection procedures and safety aspects of implantable microchips in 

the medical context and sector throughout the EU. For obvious reasons, this is largely 

irrelevant to the issue of workplace practices, although some of the issues addressed might 

be of relevance in a workplace context. 

As such, whether employers have the power to coerce their workers to accept such implants 

is a matter that is governed by the general principles and rules of EU labour law and human 

rights law, as well as the National laws of each of the member states of the EU (“Member 


There are six principal areas of Labour Law that will be engaged where an employer requires 

a worker to have a microchip implanted for the purposes of monitoring the activities or 

location of its workers. It is likely that, even if just used on a voluntary basis for ‘simple’ 

applications such as gaining access to a building, the potential exists for the fact that the 

person is within the building to be recorded and stored for future use.  

The six areas are: 

• Data protection regulation. 

• The human rights of workers under Article 8 of the European Convention on Human 

Rights (“ECHR”), which safeguards a worker’s right to respect for his private and 

family life. 

• The legal obligations of the worker to follow reasonable instructions and orders of the 

employer, i.e. to accede to requests to microchipping. 

• The law of constructive dismissal. 


14 Council Directive 90/385/EEC of 20 June 1990 on the approximation of the laws of the Member States relating 

to active implantable medical devices OJ No L 189 of 20 July 1990. 

15  Directive 2007/47/EC of the European Parliament and of the Council of 5 September 2007 amending Council 

Directive 90/385/EEC on the approximation of the laws of the Member States relating to active implantable 

medical devices, Council Directive 93/42/EEC concerning medical devices and Directive 98/8/EC concerning the 

placing of biocidal products on the market. 

Policy Department A: Economic and Scientific Policy 


 20 PE 614.209 

• Religious discrimination laws, e.g. where the implantation of a microchip under the 

skin of a worker or somewhere in or on the worker’s body does not conform to his/her 

religious beliefs or amounts to a fundamental breach of that religion.  

• Laws governing the ownership and continued use of the microchip and the data stored 

on the chip when the employment relationship is terminated. 

As noted above, a number of these issues apply whether the implants are voluntary or 


4.2. Data Protection Regulation 

Turning to the potential for employer liability in the case of data protection law, these laws 

primarily intend to ensure that workers have voluntarily consented to the collection, 

maintenance and processing of any personal data or sensitive personal data about them. 

Since microchipping involves the collection, maintenance and processing of such data, the 

data protection laws are engaged. Whether the actual implantation is voluntary or 

compulsory, consideration must be given to the purposes any information collected as a 

result of their implantation might be used for. 

Data Protection regulation is one area where the EU has the sole power to legislate by virtue 

of Article 16 of the Treaty on the Functioning of the European Union (TFEU). The EU’s General 

Data Protection Regulation (“GDPR”)16 which comes into force in May 2018 demands a very 

high standard of consent from workers, which must be given by clear affirmative action 

establishing a freely given, specific, informed and unambiguous indication of the 

worker’s agreement to their personal data being processed17. If the employer wants to use 

personal data for new or different purposes, it must update the privacy notice and obtain a 

new consent if relying on consent to justify personal data processing18.   

An employer relying on consent to process personal data from their workers must satisfy the 

following requirements under the GDPR19: 

• Consent must be specific and informed which includes information on the right to 

withdraw consent. 

• Consent must be freely given. 

• Consent must be unambiguous and take the form of an affirmative action or 


• For certain types of personal data processing, the consent must be explicit. 

• When consent is given in a document that also concerns other matters, the request 

for consent must be: 

o Presented in a manner that is clearly distinguishable from the other matters. 

o In an intelligible and easily accessible form. 

o In clear and plain language. 

Any failure to comply with such requirements would amount to a breach of the law, enabling 

a worker to claim compensation.  

As noted above, even where the implantation itself is voluntary, applications of that chip 

within the workplace raise the potential for data protection issues if the use of that chip is 


16 Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of 

natural persons with regard to the processing of personal data and on the free movement of such data, and 

repealing Directive 95/46/EC (General Data Protection Regulation) 

17 GDPR Art. 7.1 

18 See GDPR Art 13(3). 

19 See GDPR Arts 4(11), 7, 9, 49 and Recitals 32, 33 and 50. 

The Use of Chip Implants for Workers 

PE 614.209 21 

recorded in some way by an employer. Similar considerations will also apply in the case of 

non-workplace uses such as a club or gymnasium. 

The individual worker is still required to give their informed consent regarding the uses that 

any information will be put to by the employer, including any transfer to third parties; and 

the employer still needs to comply with each of the requirements under the GDPR. 

4.3. Human Rights 

The human rights of workers under Article 8 of the ECHR (which directs that “everyone has 

the right to respect for his private and family life, his home and his correspondence”) will be 

engaged by workplace microchipping. The relevant issue to be resolved in this context is 

whether (even where the original implant is voluntary) the microchipping of workers and 

consequent recording of data regarding the use of that chip would constitute the collection 

of personal data about the worker. It would have to be decided whether that amounted to 

an interference with his/her ‘private life’, since the concept of ‘private life’ is construed very 

broadly: see Niemietz v Germany20 and Bărbulescu v. Romania21. At issue is whether the 

restrictions on the employee’s private life in terms of microchipping are proportionate. The 

relevant stages to be adopted in terms of the ‘proportionality’ test were clarified by the ECtHR 

in Bărbulescu v. Romania22. This case related to the surveillance and monitoring of an 

employee’s electronic communications. As similar considerations might apply to the use of 

RFID chips, Box 1 details these stages. 

Box 1: Bărbulescu v Romania 

Bărbulescu v Romania [2017] IRLR 1032, 1047–1048 

Judgment of the Grand Chamber of the ECtHR: 

… proportionality and procedural guarantees against arbitrariness are essential. In this 

context, the domestic authorities should treat the following factors as relevant:  

(i) whether the employee has been notified of the possibility that the employer might take 

measures to monitor [the microchip and data], and of the implementation of such 

measures. While in practice employees may be notified in various ways depending on the 

particular factual circumstances of each case, the [ECtHR]t considers that for the measures 

to be deemed compatible with the requirements of Article 8 of the [ECHR], the notification 

should normally be clear about the nature of the monitoring and be given in advance;  

(ii) the extent of the monitoring by the employer and the degree of intrusion into the 

employee’s privacy. In this regard, a distinction should be made between monitoring of 

the flow of [data stored on the microchip] and of their content. Whether all [data] or only 

part of [it has] been monitored should also be taken into account, as should the question 

whether the monitoring was limited in time and the number of people who had access to 

the results (see Köpke v Germany… ). The same applies to the spatial limits to the 


(iii) whether the employer has provided legitimate reasons to justify monitoring the 

[microchip and data] and accessing their actual content... Since monitoring of the content 

of [the microchip and data] is by nature a distinctly more invasive method, it requires 

weightier justification;  

(iv) whether it would have been possible to establish a monitoring system based on less 

intrusive methods and measures than directly accessing the content of the [microchip and 


20 (1992) 16 EHRR 97. 

21 [2017] IRLR 1032. 

22 [2017] IRLR 1032. 

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 22 PE 614.209 

data]. In this connection, there should be an assessment in the light of the particular 

circumstances of each case of whether the aim pursued by the employer could have been 

achieved without directly accessing the full contents of the [microchip and data];  

(v) the consequences of the monitoring for the employee subjected to it… and the use 

made by the employer of the results of the monitoring operation, in particular whether the 

results were used to achieve the declared aim of the measure (see Köpke v Germany…); 

(vi) whether the employee had been provided with adequate safeguards, especially when 

the employer’s monitoring operations were of an intrusive nature. Such safeguards should 

in particular ensure that the employer cannot access the actual content of the 

communications concerned unless the employee has been notified in advance of that 

eventuality. In this context, it is worth reiterating that in order to be fruitful, labour 

relations must be based on mutual trust (see Palomo Sánchez v Spain…). Lastly, the 

domestic authorities should ensure that an employee whose communications have been 

monitored has access to a remedy before a judicial body with jurisdiction to determine, at 

least in substance, how the criteria outlined above were observed and whether the 

impugned measures were lawful (see Obst… and Köpke v Germany…). 


Whether an employer or a Member State of the EU is liable for a breach of human rights law 

will be context-dependent and vary from case to case. As such, there is no definitive answer 

to the question whether microchipping is unlawful under labour law, since it will depend on 

the nature and extent of the harm done to the worker (see Chapter 6), which is weighed 

against the employer’s need to engage in microchipping to fulfil a legitimate commercial 

objective. As such, each case will turn on its own facts and circumstances.  

At the core of this will be Article 8(2) of the ECHR. This states: 

“Article 8(2) 

There shall be no interference by a public authority with the exercise of this right23 

except such as is in accordance with the law and is necessary in a democratic society 

in the interests of national security, public safety or the economic well-being of the 

country, for the prevention of disorder or crime, for the protection of health or morals, 

or for the protection of the rights and freedoms of others.” 

In the context of voluntary use, the fact that the worker has consented will be a factor that 

tempers or dilutes the “harm” or level of interference (caused by the microchipping) to the 

worker for the purposes of the proportionality exercise. The lower the level of harm or 

interference experienced by the worker, the more likely that the microchipping will be lawful, 

although the employer would still need to establish that it was urgent or pressing for it to 

achieve a legitimate commercial objective. Additionally, freeing workers from the hassle, cost 

and security risks of having to have or use PINs, passcodes and access cards, or from losing 

them, can possibly be seen as a legitimate pressing social need or aim in justifying the 


A key issue will be that of proportionality. The test will be whether the harm caused by the 

interference associated with the microchipping is proportionate to the legitimate aim or social 

need invoked by the employer. This will involve a balancing of the employer’s need to engage 

in microchipping to achieve the legitimate objective that it has identified, against the level of 

interference in the employee’s privacy and harm done to the employee as a result. In this 

regard, the greater the interference or harm suffered by the employee, the more pressing 

and urgent it must be for the employer to apply microchipping to achieve the legitimate 

objective. The reality of this balancing test is that, if there is a less restrictive means of the 


23 For his private and family life, his home and his correspondence. 

24 See the discussion in J. Reidy, “One Step Closer to Robots Taking Over” (2017) 34 Business NH Magazine 33. 

The Use of Chip Implants for Workers 

PE 614.209 23 

employer achieving the legitimate objective, then the employer – and the Member State – is 

likely to lose the case in any legal proceedings taken.  

Nonetheless, it is opined that it would be an unusual case where an employer is not in breach 

of human rights law if it uses microchips in the workplace. At the very least, in cases 

successfully defended by an employer, it is likely that the employer’s use of the device would 

need to be passive. It would be an exceptional case for a court to hold that there had been 

no breach of human rights law where the device has been used in an active capacity, or the 

worker has not given his/her voluntary consent at the very least, or the worker is unaware 

of the existence of the device. Furthermore, it would be incumbent on an employer to disclose 

the consequences (and also the possibility) of transference of the data to third parties, such 

as the police and prosecution authorities25.  

As a final point it is interesting to note that if it is alleged by an employee that his/her 

employer has engaged in microchipping for the purposes of conducting unlawful monitoring 

or surveillance of the employee’s activities (in non-compliance with Article 8(2)), then any 

legal action raised by the employee will need to be against a Member State, rather than the 

employer. This is because Article 8 of the ECHR only permits vertical legal action to be taken 

by a private citizen against the State, on the basis that the State has failed to ensure that its 

National laws prevent such unlawful managerial behaviour. 

4.4. Legal Duties of Workers 

A further area where workplace microchipping will be affected by the Labour Laws of the 

Member States of the EU is in relation to the legal obligations of the worker to follow the 

reasonable instructions and orders of the employer, i.e. whether there is a legal duty imposed 

on workers to accede to requests to microchipping.  

Unlike Data Protection laws, policy and legislative competence in the context of the regulation 

of the basic obligations of workers and employers is retained by the Member States. As such, 

the EU has no power to promulgate legislation in this particular context. Where an employer 

exercises their managerial prerogative to instruct an employee to follow one of its instructions 

or orders, most legal systems will support the employer’s command by insisting on 

performance from the employee. 

However, if the implantation of a microchip gives rise to health and safety issues (see Chapter 

7), there is a strong argument that such a managerial instruction would be unreasonable and 

unlawful and the worker is under no obligation to accede to the request. For example, both 

German and UK law provide for exceptions where certain commands issued by employers 

will not be clothed with legality. In this event, the worker is not bound to conform to the 

instruction and will not be in breach of the law for non-performance. 

Under such circumstances, it is likely that were the employer to compel the worker to be 

microchipped, the Labour Laws of the Member States would rule that there has been a breach 

of Labour Law. Such a breach will have different consequences depending on the Member 

State, e.g. in some Member States it will be possible for the worker to claim compensation 

or to treat him/herself as constructively dismissed. 

Where the worker volunteers to be microchipped, this particular area of the law will assume 

no relevance, since this branch of the law is concerned with the legal position where a worker 

refuses to comply with an employer’s order. 

4.5. Law of Constructive Dismissal 

The Member States currently maintain sole jurisdiction to promulgate laws governing the 

dismissal of employees and the termination of the contract of employment. However, 


25 Bărbulescu v. Romania [2017] IRLR 1032 and Vukota-Bojic v Switzerland [2017] IRLR 94. 

Policy Department A: Economic and Scientific Policy 


 24 PE 614.209 

technically, the EU does have power under Article 153(1)(d) of the TFEU to pass laws that 

regulate the powers of dismissal of employers. 

In a number of the Member States of the EU, a concept known as “constructive dismissal” is 

recognised. This is not an outright dismissal by the employer, but describes a situation where 

an employer’s behaviour is so serious that it amounts to a repudiatory breach of the 

employment contract, which enables a worker to treat him/herself as “constructively 

dismissed” and to terminate their contract. The fact that a command issued by the employer 

to the worker that the latter ought to be microchipped could have health and safety 

implications (or might run contrary to their religious beliefs) results in the engagement of the 

law of constructive dismissal.  

It is not essential to the establishment of constructive dismissal that the employer’s order is 

imposed without the worker’s consent. Where the worker agrees to comply, but the health 

and safety implications for workers are so serious that the employer’s behaviour qualifies as 

a repudiatory breach of contract, this will therefore empower the worker to make a 

constructive dismissal claim. 

4.6. Religious Discrimination Laws 

The EU has competence pursuant to Article 19 of the TFEU and has passed the Framework 

Directive governing the protection of employees and workers from discrimination on the basis 

of their religious belief. This would apply for example where the implantation of a microchip 

under the skin of a worker, or somewhere in or on the worker’s body, does not conform to 

his/her religious beliefs or amounts to a fundamental breach of that religion26. Assuming that 

every worker is treated the same; and that no workers adhering to a particular religious faith 

(or none), are being singled out for special adverse treatment, then any claim would need to 

be one of indirect rather than direct religious discrimination. 

For such a claim to be established, the microchipping must put workers possessing the same 

religious belief as the claimant worker at a particular disadvantage when compared with other 

workers (who do not adhere to that religious belief). The microchipping must not be 

objectively justifiable by the employer on the basis of a legitimate aim, or  be appropriate 

and necessary to achieve that aim. If a less restrictive means of achieving the employer’s 

real business need or legitimate aim is found to exist, or the microchipping cannot be shown 

to be appropriate and necessary, the defence will be rejected and the claim likely to succeed. 

4.7. Ownership of Data 

Labour and data protection laws governing the ownership and continued use of the microchip 

(and the data stored on the chip) will be a significant issue when the worker leaves the 

employment of the employer. First, the ownership of the chip itself and the data collected 

and stored would be governed by the express terms of the contract of employment. These 

terms will be produced by the employer and as such, would specify that the chip and the 

data are owned by the employer. In the absence of express terms, the implied default law 

would have to develop as the use of the technology became more pervasive in the workplace. 

The GDPR explicitly provides for an individual’s “right of erasure” and “right to be forgotten”. 

When the employer initially requires the employee to be microchipped, Article 13(2) of the 

GDPR prescribes that it must furnish the employee with several pieces of information, and 

part of that information concerns the employee’s “right of erasure”. The employer must 

therefore give the employee the right to access the data collected and stored on the microchip 

in terms of Article 15 of the GDPR. Article 17(1) of the GDPR directs that employees have a 

general right to the erasure of personal data concerning them without undue delay, while 


26 Directive 2006/54/EC of the European Parliament and of the Council of 5 July 2006 on the implementation of the 

principle of equal opportunities and equal treatment of men and women in matters of employment and 


The Use of Chip Implants for Workers 

PE 614.209 25 

Article 17(2) of the GDPR includes a “right to be forgotten”. However, these are to some 

extent balanced by Article 17(3) that states that both the right to erasure under Article 17(1) 

and the right to be forgotten under Article 17(2) do not apply to the extent that they would 

collide with certain public policy interests. 

This relates to the conservation of data collected as a result of the microchipping after the 

microchip is disabled or removed.  


Policy Department A: Economic and Scientific Policy 


 26 PE 614.209 



• In an overlap with legal arguments, ethical concerns stem in part from Articles 1 and 

3 of the Charter of Fundamental Rights of the EU that relate to the inviolability of 

human dignity and the human body. 

• Further ethical issues relate to health and safety concerns; the efficacy of the 

technology as a secure system; equity and choice; and (again in a parallel with legal 

issues) religious concerns. 

5.1. Introduction 

The ethical issues surrounding the use of RFID chips implants are complex and wide reaching, 

often overlapping with (or interacting with) other aspects of their use. In some instances, 

the issues depend upon the particular field of application. For example, Monahan and Fisher 

(2010) raise concerns about their use in health environments, including the possibility that, 

perhaps because it eases the process, those patients with a chip implanted might receive 

some priority in treatment. 

As an example of some of the ethical issues identified in a workplace context, in 2005, the 

European Group on Ethics in Science and New Technologies to the European Commission 

published an opinion on ethical aspects of ICT implants. Although its focus was much wider 

than RFID chip implants (which were referred to briefly in one subsection), some of the issues 

raised are relevant to such devices. The opinion cites Article 1 of the Charter of Fundamental 

Rights of the EU (2000) as stating that: “Human dignity is inviolable. It must be respected 

and protected”27. It further cites Article 3 of the same Charter, which establishes the principle 

of inviolability of the human body28. Although a legal document, the legal provisions address 

what can be seen as ethical issues and are therefore explored here.  

The opinion then sets out a series of what are termed “Fundamental ethical principles”29 

which include: 

• Human dignity. 

• Non-instrumentalisation. 

• Privacy. 

• Non-discrimination. 

• Informed consent. 

• Equity. 

• The Precautionary Principle. 

• Value conflicts. 

Although some of these may be of limited relevance to RFID chip implants, they should still 

be considered (even if to dismiss them). Clearly, as noted above, there are considerable 

potential overlaps with legal and other aspects, for example in respect of legal safeguards in 

place for personal data protection and privacy; or the precautionary principle when it comes 

to the lack of knowledge regarding the health effects of potential long-term implantation. 

How these might be addressed, other than by not permitting the technology, should also be 

considered (see Chapter 8). 


27 Cited in: European Group on Ethics in Science and New Technologies, (2005) p15 

28 Ibid, p16 

29 Source: European Group on Ethics in Science and New Technologies, (2005) pps22-23 

The Use of Chip Implants for Workers 

PE 614.209 27 

5.2. Safety 

One of the primary areas of ethical concern must be safety. Ensuring the health and safety 

of an employee is a major responsibility for all employers, and failure to address this issue 

adequately as the technology is deployed would be a significant failure on their part. As is 

apparent from Chapter 6 below, little is known about the safety and risks to health of these 

devices. Foster and Jaeger (2008) suggest that the knowledge of suggested carcinogenic 

effects in implanted rodents was not necessarily initially made known to human wearers, an 

issue that has clear ethical implications (whether concerns about similar effects in humans 

are justified or not).  

Asking (or in the future possibly requiring) individuals to have such a device inserted, when 

we cannot be sure that they are safe, has clear ethical implications. Recent years have seen 

the emergence of the ‘precautionary principle’ by which, if something is not known to be safe 

(as opposed to there being no evidence that it is unsafe) then this is regarded as a strong 

argument against its introduction. 

As well as any consideration of the health issue of chips when in place under the skin, there 

appears to have been little formal evaluation of their removal, for example on termination of 

employment. Although it appears that the chip can relatively easily be disabled or ‘wiped’ 

this still leaves the physical device in situ and needing to be surgically removed. Available 

anecdotal accounts relating to this (derived from a mixture of accounts posted on the internet 

and personal accounts from interviewees) range from the casual dismissal of it as an issue; 

to the view that it requires considerable surgical intervention as a consequence of it becoming 

embedded in connective tissue. Thus, in addition to any assurances given to potential wearers 

regarding the safe insertion and wearing of devices, it must also be made clear whose 

responsibility it will be to ensure safe removal, inactivation and disposal of the chip at the 

end of the employment period (or even if the individual changes their mind about having one 


As a further consideration, as well as any potential impact on physical health, consideration 

must be given to possible mental health issues – again with ethical implications. If a person 

receiving an implant feels that they are required to modify their behaviour as a consequence 

of doing so, this may have a significant effect on their mental health- especially if they already 

feel vulnerable or insecure, or have a pathological tendency towards mistrust or suspicion. 

Assurances must be given that any detrimental effects on the mental and emotional health 

of employees who are chipped will be monitored and mitigated. 

5.3. Efficacy 

Although in some situations they are promoted based on ‘convenience’ in work situations the 

concept of a chip implant is often ‘sold’ to potential wearers on the basis of enhanced security. 

Given that there appear to be doubts about this (see Chapter 7) the ethics of using this 

argument must be questioned (see for example, Perakslis and Michael, 2012). In this context, 

Glasser et al (2007) raise an interesting issue in questioning a society in which moral 

considerations are given a lower priority than business or security. Even if security concerns 

were effectively addressed this dilemma would remain. 

5.4. Privacy / Dignity 

According to Monahan and Fisher (2010), “loss of privacy is the main concern that ethicists 

and others have about RFID implants”, echoing the views of others such as Glasser et al 

(2007). Depending on how (and where) they are used, the chip presents the possibility of 

being able to monitor the wearer in some way (for example, logging the time a wearer spent 

in different areas accessed using chip readers) which could be seen as an invasion of privacy. 

As noted earlier, the technology exists to extend the ‘read’ range of readers, enabling 

monitoring over a greater area. Chapter 4.7 raised legal questions regarding the ownership 

Policy Department A: Economic and Scientific Policy 


 28 PE 614.209 

of data. Here we see a moral dimension as well, regarding different ways in which information 

made available through using an implanted chip might be used (or perhaps mis-used). 

Furthermore, the chips can be reprogrammed within the body, altering their use and purpose 

from that initially agreed and consented to. Clearly, if changes are made by the employer, it 

is essential that the worker is fully informed of any changes before they are effected, and an 

opportunity to raise concerns be given. However, as referred to in the context of security 

(Chapter 7), the chips are not necessarily secure and the possibility that they might be 

‘hacked’ by a third party with malicious intent cannot be discounted.  

Additionally, in a further possible overlap with the legal issues, the insertion of a chip can be 

regarded as breaching the integrity of the human body or violating human dignity. 

5.5. Religious Beliefs 

Some religious views may preclude the insertion of an implant (there is some evidence of 

some very strongly held views in this regard including the suggestion that they are the ‘Mark 

of the Beast’ e.g.30,31) and the requirement to do so (or perceived pressure to do so) may be 

seen as a form of religious discrimination (see also Chapter 4.6). For some religions, any 

intrusion into the human body, even on the strongest of medical grounds, is unacceptable 

and it is difficult to see how the insertion of an ID chip as a requirement for employment 

could be tolerated under such circumstances. 

5.6. Equity 

In most employment situations, employer and worker do not enjoy equivalent status. The 

employer usually has some capacity to influence the decision made by the worker, as there 

is usually an exchange of assets (salary or other benefits) in return for the worker providing 

their labour or skills. This has significant implications for the equity of any arrangement. 

However, a worker might find that, not only is access to certain areas of physical space 

denied to them on the basis of their failure to accept the use of a chip, but that progression 

or promotion within the company may also be restricted if they do not demonstrate loyalty 

in this way. As noted earlier, similar concerns regarding detrimental effects on non-wearers 

were identified by Monahan and Fisher (2010) in respect of the use of such implants in a 

patient care situation. 

While in many situations this may not be a significant concern, it is possible that undue 

coercion and control may be facilitated through this. This may be especially true where the 

inequality between employer and worker is pronounced; for example in those who feel unable 

to voice objection for fear of losing their only source of income or security. There is a need 

to protect the most vulnerable in our society from exploitation and it is feasible that pressure 

to retain employment might result in workers accepting situations that, given a free choice, 

they would otherwise choose not to do. 

5.7. Informed Consent 

Although the need for informed consent appears to be an obvious expectation (see Section 

4.7 relating to data protection and the GDPR), Glasser et al (2007) raise some interesting 

questions regarding how freely such consent might be given; and safeguards that might be 

required to protect vulnerable individuals. For example, if agreeing to having a chip implanted 

was a condition of employment with a certain organisation then the need of an individual for 

such employment might override any concerns they might have about accepting such a 

condition of service. It might therefore be considered necessary to introduce safeguards to 





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PE 614.209 29 

avoid against such an eventuality. However, the authors also raise a contrary view, namely 

that protecting people from their own decisions freely given might be seen as patronising 

and unacceptable. Clearly, issues such as the availability of alternative employment for the 

individual concerned will contribute to this aspect of any debate.  


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• Concerns have been expressed over the health and safety of RFID chip implants in 

four main areas: carcinogenicity; migration; interactions with MRI systems; impact 

on pharmaceutical effectiveness. There have been no systematic studies of health 

impacts in human wearers. 

• There are reports of carcinogenic effects of RFID chips in some animals (mainly 

specific strains of mice). However, it appears that this is likely to be a feature of the 

unique sensitivity of these species and not a trans-species phenomenon. Potential 

mechanisms (such as ‘foreign body carcinogenicity’ which has been documented) 

suggest any similar effects in humans to be unlikely (although impossible to discount 


• Detailed studies of the potential interactions between MRI scanning and RFID chip 

implants appear to have excluded any significant effects, other than the risk of local 

details being masked by the chip image. 

• Although anecdotally RFID chips can ‘move’ under the skin this appears to be a local 

reorientation. It is suggested that inter-species differences in sub-dermal layers 

makes significant migration unlikely although, in the absence of anything more than 

anecdotal evidence, this cannot be categorically excluded. 

• Concerns regarding the impact of RFID technology on the efficacy of pharmaceuticals 

appear to stem from proposed use of RFID tags to label containers of pharmaceuticals. 

The scanning of bulk material presents a very different situation to that of 

pharmaceuticals circulating in the blood, where any risk of an effect would be 

extremely limited.  

6.1. Introduction 

In exploring the scientific literature in respect of RFID chip implants, the overriding 

impression is one of a lack of good quality information on health/safety effects. Information 

on actual effects on humans, rather than possible effects, is virtually non-existent; and 

information on their use in other animals raises issues regarding cross-species applicability. 

For example, what reliable information on the risk in humans can be derived from a laboratory 

study of mice (possibly specifically bred for susceptibility to adverse health effects)?  Other 

papers regarding adverse effects in animals (often companion animals such as dogs and cats) 

are frequently case reports involving just one or two animals.  

Concerns have been expressed that, as well as any health issues that might arise from the 

implantation process itself (which clearly must be carried out in accordance with appropriate 

hygiene and infection controls), having an implanted chip might have adverse health impacts 


• Carcinogenic effects (e.g. Albrecht 2010, Blanchard et al, 1999). 

• Adversely affect (or be adversely affected by) the use of devices such as MRI scanners 

(e.g. Baker & MacDonald, 2010, Steffen et al, 2010). 

• Migration under the skin (e.g. Albrecht 2010) with potentially adverse consequences; 

• Impact on the efficacy of pharmaceuticals (e.g. Sade, 2007). 

Each of these concerns (and any others that emerge) will be explored in turn. 

A further issue to consider (and which will again be explored) relates to the implications 

surrounding the subsequent removal of an implanted RFID chip (for example on ceasing 


The Use of Chip Implants for Workers 

PE 614.209 31 

One caveat to be placed on the information below is that it is believed to be approximately 

20 years since the first documented implantation of RFID chips in humans (although there 

are some anecdotal reports of earlier uses). Since that time, the technology and materials 

used in such chips have changed. It is possible that some of the effects experienced were 

specific to the type of chip being used, rather than being applicable to any chip implants. 

Unfortunately, relevant details of chip construction that could be used to establish this are 

not always available. 

6.2. Possible Carcinogenic Effects 

Albrecht (2010) reported on a review of the literature relating to ‘the safety of implantable 

microchips’, identifying eleven papers spanning the period between 1990 and 2006. On the 

basis of this review the author concluded that there was ‘a clear causal link between microchip 

implants and cancer in mice and rats’ (p348); and that it ‘appeared’ that they could cause 

cancer in dogs. Given the potential impact of such an effect it is worthwhile exploring this in 

a little more detail.  

The first report identified by Albrecht was a brief conference abstract (Johnson, 1996 as cited 

by Albrecht, 2010) and so had little detail other than that they had found tumours in <1 % 

of mice and that these were described as ‘foreign-body sarcomas’. The author cited an earlier 

review on this topic (Brand et al, 1976 as cited by Albrecht, 2010) that reviewed the topic of 

‘foreign body tumorigenesis’ concluding that it was independent of the material of the foreign 


The next paper, Tillman et al (1997) described the incidental observation of cancerous 

growths in 36 of 4 279 mice (0.8 %). In their discussion, the authors cite six earlier papers, 

covering a variety of different animal species (in relatively small numbers), none of which 

identified cancerous growths. In response to the failure of another study (Rao & Edmonson, 

1990) to identify cancerous growths they suggest that variations in genetic susceptibility 

might account for this, although the smaller number of mice in the earlier paper (~140) 

might also have played a part. 

The next paper was another conference abstract. In this case the authors (Palmer et al 1998) 

examined 800 mice and found tumours in 16 (2 %) of these. The authors comment that the 

mice in question were a specific strain and that earlier studies they had conducted in other 

strains had not found any such growths, adding weight to the views of Tillman and colleagues 

of a strain-specific susceptibility.  

This theme is also echoed by the next paper (Blanchard et al, 1999). In their work, 18 out 

of 177 mice developed cancerous growths at the implant site (~10 %). The purpose of the 

paper and the research it reported was to explore the use of this transgenic strain. The strain 

had been bred specifically to have a deficiency in a tumour-suppressing gene; and the study 

was planned to demonstrate their resultant susceptibility to cancer. The authors refer in their 

introduction to their prior experience (nearly ten years) of using the implants without adverse 


Elcock et al (2001) reported on studies using rats rather than mice. Two separate but related 

studies found an 0.96 % and 0.58 % incidence of tumours in a total of over 1 000 rats, again 

of a specific strain. Again, in their discussion, the authors refer to earlier work in a variety of 

animal species that had failed to find any such effect.  

The final study examined tumours collected from mice in a number of different experiments. 

In all, 52 tumours were collected from experiments involving a total of 1 260 mice (~4 %), 

again of a specific strain bred for carcinogenicity testing (Le Calvez et al, 2006). 

Although these studies serve to indicate a potential for carcinogenesis associated with the 

use of RFID implants, there are clearly questions regarding the potentially intentionally 

susceptible strains of animals (mainly mice) used in many of the studies that have found 

effects; and the inter-species relevance of the findings.  It is of particular interest that all of 

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the authors refer to previous experience with no tumours. It is not known whether the RFID 

chips used were coated (which would encourage tissue growth round the device) or uncoated. 

One mechanism referred to in a number of these papers is that of carcinoma associated with 

foreign bodies. In their paper reporting three cases, Jennings et al (1988) describe foreign 

body tumorigenesis as ‘not proven definitively in man’, although they then demonstrate, 

through their reported cases in humans, that it is possible. In an earlier paper, Brand & Brand 

(1980) draw parallels to the (low) incidence of cancers associated with ‘implanted’ foreign 

bodies (including material ‘accidentally acquired’ – for example as a war injury).  However, 

in contrast, a more recent paper on investigations of such acquired foreign bodies (Gaitens 

et al, 2016) found no signs of neoplasms in tissue surrounding the foreign body. 

In a recent review on the carcinogenicity of implantable materials, Williams (2014) presented 

a broad assessment targeted at implantable devices in general, not specifically RFID chips. 

Commenting on the general use of animals to assess biocompatibility, the author states that 

“such tests are rarely predictive of performance in humans” (p579). Specifically on 

carcinogenicity the author expresses an even stronger view, stating that: 

“…species specificity considerations mean that extrapolation from observations of 

tumors around biomaterials in rats and mice to clinical use in humans is scientifically 

invalid.” (p579) 

Although addressing implants from a much wider perspective, this latter comment would 

appear to be relevant to any debate on the carcinogenicity of RFID implants suggesting that 

even the tests for human biocompatibility might be flawed. 

As is often stated, it is difficult to prove an absence of effects.  However, despite evidence 

and concerns based on experiences with other species, it would seem that any risk of 

carcinogenesis in humans receiving RFID chip implants is at most minimal. 

6.3. Other Possible Dermal Effects 

There is a considerable body of evidence from the medical literature regarding adverse effects 

of subdermal implants for cosmetic (e.g. Alijotas-Reig et al, 2013) and other purposes. This 

is clearly a complex field given the wide variety of materials used and it is far from clear to 

what extent (if any) they might relate to RFID implants. For example, Frank et al (1993) 

reported on a study of the use of contraceptive implants inserted into the upper arm of 

patients. The vast majority of reported side-effects related to the contraceptives released by 

the implants. However, in a small minority of cases (2.7 %) there were reports of problems 

with the carrier rods themselves, including the rod migrating, being spontaneously expelled, 

or developing a localised infection. These could be relevant to RFID implants. 

The documented existence of such effects counsels caution in respect of RFID implants. 

Although the risk of carcinogenic effects may be minimal, there might be risks of other 

adverse dermal reactions which, although apparently rare (Kunjur & Witherow, 2013), should 

be explored. 

6.4. Possible Effects on MRI Use 

One concern expressed in some quarters relates to adverse reactions in MRI scanning. It is 

understood that the magnetic metallic content of RFID chips is very low and can be reduced 

further in chips specifically intended for implantation. 

In a brief review of possible risks associated with RFID implants, Rotter et al (2012) cite the 

FDA as raising the possibility of an incompatibility between RFID implants and the use of MRI 


In a small on-line publication, Lamberg (2004) reported on studies in which ‘several’ devices 

were tested. Although the circumstances of testing are unclear these do not appear to have 

been tested in-situ. The author refers to ‘device movement’ stating that the forces measured 

were low, with little chance of migration occurring as a result. There was no noticeable 

The Use of Chip Implants for Workers 

PE 614.209 33 

heating; and image distortion occurred only in the immediate vicinity of the chip. However, 

after MRI scanning one device failed to function. Given the very limited data presented and 

no corroboration of statements such as references to the force needed to tear a device from 

tissue, little reliance can be placed on this paper. 

Steffen et al (2010) reported on experimental studies in which they explored the effects of 

MRI exposure on RFID Chips (referred to as tags). By way of background they cite what 

appears to be the paper by Lamberg as showing ‘no adverse effects for patients” (p2/9). 

Although the main focus of the study was external tags the study does provide useful insight 

into the impact of MRI (and CT) scanning on the device itself. Passive transponder tags were 

used. Both 1.5 T and 3 T MRI scanners were used. 

With a large tag (76x45 mm, which is much larger than those currently implanted), some 

heating (max 3.6°C) was measured beneath the tag after 15 minutes of scanning using 1.5 

T MRI. Such temperatures exceed those defined in current guidelines or standards regarding 

implants.32,33 International standard ISO 14708-1:2014 E requires that no outer surface of 

an active implantable part of any medical device be greater than 2oC above the normal 

surrounding body temperature of 37oC during implantation, normal operation, or single-fault 

conditions. However, with the smaller tag (31x14 mm), which was still large by implantable 

tag standards (1.5°C max), or with the more powerful 3 T MRI system (<0.8°C), lower 

temperatures were obtained. Although possibly generating some awareness of heating, 

effects of this magnitude would be unlikely to result in tissue harm if repeated with an 

implanted chip. 

Measurements of induced accelerative force were recorded as <1 N kg-1, described by the 

authors as “generally not or minimally perceptible” (p 7/9). However, it is not known how 

these effects would relate to smaller implanted tags. 

The authors did report that the tag device did block the image underneath them, and distort 

the image for a short distance around the tag. As might be expected the effect was markedly 

less for the smaller tag. For an even smaller implanted tag, located in a peripheral area of 

the body, this is unlikely therefore to be of any clinical significance. 

Finally, the authors reported that neither MRI nor CT scan use had any negative effect on the 

integrity of the tags themselves which remained both readable and re-programmable after 


As noted, this study was carried out on larger RFID chips than would be implanted. Baker & 

MacDonald (2011) attempted to simulate in vivo conditions using a gel-filled ‘phantom’. As 

with the work of Steffen and colleagues the authors found limited heating effects (~0.4°C); 

forces around 2 000 times lower than the force found to be required to displace a device in 

a sheep; no damage to the function of the RFID chips; and MRI scan artefacts in the vicinity 

of the implant. 

Although restricted by the lack of specific in vivo studies (where objective measurement of 

factors such as force and temperature would be problematic) the available evidence appears 

to suggest that any negative impact of an RFID on subsequent MRI scanning of the individual 

would be minimal. 

6.5. Migration 

Chapter 6.3 briefly addressed the issue of migration in respect of the forces that would be 

exerted on an implanted RFID chip during MRI scanning. Some sources have also raised 


32 ICNIRP (1998) Guidelines for limiting exposure to time-varying electric, magnetic, and electromagnetic fields 

(up to 300 GHz). International Commission on Non-Ionizing Radiation Protection. Health Phys, 74, 494-522. 

33 ANSI/IEEE (2005) IEEE Standard for Safety Levels with Respect to Human Exposure to Radio Frequency 

Electromagnetic Fields, 3 kHz to 300 GHz. IEEE Std C95.1-2005 (Revision of IEEE Std C95.1-1991).  


Policy Department A: Economic and Scientific Policy 


 34 PE 614.209 

wider concerns regarding the passive (mechanical) migration of such devices within the body 

(e.g. Sade 2007). It is interesting to note here that the concern referred to by Sade is that 

such migration might make the RFID potentially difficult to extract rather than any concern 

regarding the adverse impact of the migrated device. 

In animal species, the risk of such migration appears to be recognised. Le Calvez et al (op 

cit) describes the use of chips fitted with a polypropylene sheath as an anti-migration 

measure; a feature also referred to by Albrecht (op cit). However, perhaps because of the 

use of such measures, there appears to be no published documentation regarding the extent 

to which migration occurs in animals, much less in humans. Anecdotally it has been 

suggested that the characteristics of human skin differ from those in other species and that, 

as a result, migration is much less likely to occur. However, again anecdotally, some 

recipients of RFID chips do refer to them re-orienting themselves, for example to be better 

aligned with the movement of structures in the hand and isolated reports from the literature 

of contraceptive rods migrating, referred to earlier, might also be relevant. 

A number of papers refer to implanted chips becoming encapsulated by connective tissue 

and, once this occurs, the risk of migration appears to be reduced. Reflecting this, Baker & 

MacDonald (op cit) recommend waiting three months before subjecting an implanted animal 

(dog) to an MRI scan to allow sufficient time for this encapsulation to occur. 

To date there is no formally collated information or systematic study available to document 

the extent to which sub-dermal chip migration is possible in humans, or the extent of any 

migration should it occur, although it seems to be a minimal risk. It is however recognised 

that migration of foreign bodies can occur within the body. For example, Lyons and Rockwood 

(1990) report on a review of reports of the migration of surgical pins used in shoulder 

surgery. In contrast, Hoffman et al (1999) report on studies of materials for use in cosmetic 

lip implantation where the implanted material becomes encapsulated by cell growth and 

therefore does not migrate. It would seem likely that the location of the implant within dermal 

or sub-dermal layers, rather than within deeper body tissues, as well as the material involved, 

are important factors here. 

6.6. Effect on Pharmaceuticals 

In suggesting possible concerns regarding the physical risks to patients posed by RFID chips, 

Sade (op cit) states that “It has not been determined whether RFID tags might affect the 

efficacy of pharmaceuticals.” In support of this the author cites two sources. The first of these 

(Ingeholm et al, 2006 as cited in Sade, 2007) could not be sourced but, from references 

elsewhere, it does not appear to focus specifically on implanted chips. The second 

(Wasserman 2006 as cited in Sade, 2007)) definitely does not, referring to the use of RFID 

chips in the supply chain to ensure the bone fide nature of drugs. In this context, the concern 

would appear to be that of direct exposure of the bulk drug to the radio frequencies of the 

reader, rather than the circulating drug within the human patient.  

Uysal et al (2010) reported on a systematic evaluation of this issue on pharmaceuticals with 

a protein base, in view of the well-documented sensitivity of protein-based materials to 

heating (denaturing). Using the five main frequencies of radio waves used in RFID, the 

authors subjected ‘multiple products’ (covering hormones, vaccines and immunoglobulins) 

to a level of radiation twice that permitted by the Federal Communications Commission (the 

US regulatory body for radio communications). Assays for purity and potency after 24 hours 

continuous irradiation found no detectable deterioration in any product.  

Given this evidence, combined with the radically different sphere of application (and the fact 

that most of the circulatory system would be unexposed), there would seem to be little 

justification for any such concerns being translated to the current application. 


The Use of Chip Implants for Workers 

PE 614.209 35 



• It would seem that, at present, the RFID chip technology (which is essentially similar 

to that used in credit cards and similar systems) is not entirely secure.  

• Security concerns include eavesdropping; cloning; disabling; and unauthorised tag 


• Although efforts are continuing to counter these concerns there remain doubts and 


7.1. The issues 

Citing a number of sources themselves, Darcy et al (2011) list what the authors refer to as 

the “most dominant [issues] with regard to RFID security” (p10): 

• Eavesdropping: The act of setting up an additional reader to record tag data. 

• Unauthorised Tag Cloning: Copying tag data onto an additional tag to gain the same 


• Man-in-the-Middle (MIM) Attack: When an external object pretends to be either a tag 

or reader between actual tags and readers. 

• Unauthorised Tag Disabling: When an external reader disables a tag not allowing it to 

be utilised again.  

• Unauthorised Tag Manipulation: Manipulating the tag data using an external reader.34 

In a more recent paper Singh et al (2017) suggest some further concerns including: 

• Further Eavesdropping: An intruder reader intercepts the signals between the chip 

and the legitimate reader. 

• Traffic Analysis: The existence and location of a chip is monitored, without necessarily 

interrogating the chip. 

• Spoofing: Also known as satirising, where another device is used to simulate a genuine 


• Denial of service attack: Chips can be adulterated to disable them. 

Roberts (2006) reports on the free availability of software that can read and reprogramme 

RFID tags, suggesting that the security issues are widespread. Although other papers (e.g. 

Dimitriou 2005) suggest that possible solutions for the most basic security concern of cloning 

might become available, current indications are that there continue to be problems. For 

example, while Baghery et al (2014) wrote of improvements to RFID authentication protocols 

to enhance security, these suggestions were soon countered by the presentation of flaws 

(Safkhani & Bagheri, 2016). Although there is an extensive body of literature, especially on 

software architecture and programming, these offer little additional insight into the broad 

issues of RFID chip security and will not be documented in detail here.  

Other than acknowledging their existence, such security issues do not appear to have been 

discussed in any detail specifically in respect of RFID chip implants, although papers such as 

that by Halamka et al (2006) suggest that some chips might be vulnerable to cloning. Despite 

this, there are perceptions that RFID chips offer a more secure means of ensuring workplace 

security, especially amongst younger adults (‘Millennials’) (Perakslis & Michael, 2012). 

This lack of focus possibly reflects the fact that human implanted chips remain very much a 

niche (some might say hobby or novelty) market. The vast majority of chip implants are 

made in animals and there would seem to be little value in cloning the chip code of a pet dog 


34  Source: Darcy et al (2011) pps 10-11 

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 36 PE 614.209 

(for example). However, if the applications of human RFID chips were to grow, and were to 

become associated with high level security applications then interest in their security (and in 

attacking that security) would be likely to increase. 

7.2. Solutions 

As noted above, there has been virtually no focus on chip security as far as applications 

involving human implants are concerned. An approach understood to be commonly adopted 

by RFID chip manufacturers with non-implanted chips is that of ‘kill tag’ technology where 

the RFID chip is automatically disabled by illegal attempts to interrogate it (Roberts, 2006). 

Although this might be an effective approach for non-implanted chips this raises the prospect 

of defunct chips within the body needing to be removed (and a potential need for a 

replacement to be inserted). 

Another approach is where identifiers are exchanged between the reader and the chip and 

routinely updated, in a process called ‘mutual authentication’ (Dimitriou, 2005). Risalat et al 

(2017) have recently written of a new authentication protocol, based on a regularly updated 

‘secret key value’ (that seeks to ensure that only authorised readers can access chip 

information). The authors claim that this is “secure and immune to different kinds of attacks”. 

It remains to be seen whether this represents a breakthrough – or a challenge to others to 

break it, as appears to have been the case in the past. 

In broad terms, discussions for the purpose of this paper with individuals working in the 

industry suggest that, although efforts are being made to resolve such problems, they remain 

valid concerns at present. Although opinions vary as to the extent to which potential solutions 

might be forthcoming in a not too distant time-frame, it would seem that the technology 

itself is susceptible to security intrusion. For example, one long-term ‘user’ of the technology 

indicated that he adopts a second line of security such as a PIN where he feels that this is 

warranted. Interestingly he also indicated a reluctance to use biometric data stored on the 

chip for this purpose because of this perceived vulnerability and the consequent risk of 

personal identity theft (see also Kosta et al, 2007). Despite the ability to encrypt such 

information he felt that it remained vulnerable. 

Others suggest that it is not a significant issue at present – although this could be because 

the nature and extent of current applications do not warrant the effort involved. Halamka et 

al (2006) suggest that RFID chips remain free from ‘attack’ because there is relatively little 

to be gained from doing so (although, as some reports of computer system hacking suggest, 

some people do so ‘because they can’). Clearly however that could change if the technology 

became used more widely, or if it was known to be used in selected security applications 

where there was more value in gaining access. 

As a guide, the technology used is basically similar to that utilised in bank credit and debit 

cards using ‘chip and pin technology’ and the fact that such cards usually rely on a second 

form of ID (such as the PIN) is indicative of the security involved (See for example, Fan et al 

2005). Other applications of RFID chips include e-passports which, as Kosta et al (2007) 

discuss, have security issues which could also be applied to RFID implants.  

These issues are important, as the existence of such security concerns is likely to impact on 

consideration of the ethical and legal issues surrounding the use of RFID chip implants, given 

that enhanced security has sometimes been presented as a positive benefit from the use of 

implanted chips (and sometimes provides the main rationale for their use). 




The Use of Chip Implants for Workers 

PE 614.209 37 





• In existence for around 20 years, human implantable RFID chips come in passive and 

active forms. The passive form is considered here. 

• Advocates of the use of RFID chip implants suggest that they confer benefits in terms 

of ease and convenience compared to the alternative technologies (e.g. smart cards) 

that they replace. 

• Despite well-documented concerns about the possible adverse health effects of such 

implants (most notably reports of carcinogenetic activity) there is no evidence of such 

effects in humans (as opposed to experimental animal strains). However, although 

there is reasonable incidental evidence suggesting such effects as being unlikely, 

there is also no specific evidence of no effect. 

• Literature on surgical and cosmetic implants suggests that, although adverse 

reactions are rare (and do not appear to include carcinogenetic effects) both migration 

of implanted materials and adverse health reactions can occur and should be explored 


• One integrated theme would seem to be that of human rights; covering the 

inviolability of the human body and an individual’s right to privacy. These issues would 

seem to reflect both ethical concerns and the legal provisions safeguarding those 


• It would seem that legal efforts to overturn those rights for compulsory implant use 

in the workplace would need to reflect over-riding demands, perhaps on the grounds 

of national security. Here however, the evidence that the RFID technology is insecure, 

and the lack of specific assurances regarding adverse health effects can be seen as 

undermining the case for such a development. 

• However, even where such technological challenges are to be overcome, it must be 

recognised that the use of such implants evokes strong objections (including religious 

concerns) and any compulsion would need to provide for appropriate exemptions in 

such circumstances. 

• Where implant use is voluntary (as is the case at present) then legal considerations 

in respect of data protection still apply with regard to any information regarding 

access, patterns of use, etc. which might be collected as part of such use. 

• There are also cross-cutting issues regarding legal and ethical considerations, where 

supposedly voluntary use included any degree of perceived coercion or where those 

with such implants might be considered to receive different treatment. 

8.1. Overall implications 

From the preceding chapters it will be apparent that there are legal, ethical, health and 

security issues surrounding the potential use of RFID implants. It will also be apparent that 

these issues often overlap and are interrelated. However, these have to be seen against the 

convenience that such devices are regarded as providing compared to, for example, having 

to retain and use a smart card. 


Policy Department A: Economic and Scientific Policy 


 38 PE 614.209 

8.2. Health issues 

Probably foremost amongst the issues are those relating to health. Legal and ethical 

considerations are often predicated on the assumption that there are either no risks to human 

health, or those risks are relatively minor and at a level where they can be regarded as 

acceptable, subject to informed consent. However, the challenge here is that the case in 

respect of potential health risks can be regarded at best, in the terms of the (uniquely) 

Scottish verdict of ‘not proven’. There are clearly concerns about health risks, some of which, 

such as those relating to interference with or adverse effects from MRI use and interactions 

with pharmaceuticals, can it seems be discounted.  

Probably the main health concern which can less readily be discounted is that of potential 

carcinogenic effects. Conflicting opinions and evidence, summarised earlier, suggest that, on 

balance, there is no significant risk of carcinogenetic activity of RFID chip implants in humans. 

However, all such evidence can be regarded as inferential and it would be difficult to provide 

categorical assurances of safety. The principle of informed consent requires a good and clear 

understanding of the risks to which the individual is consenting. At present it would be difficult 

to formulate a clear and unequivocal statement of those risks, sufficient to justifiably permit 

compulsion without an overriding need. Even where implantation was voluntary this should 

only be undertaken with a clear explanation (and acceptance by the recipient) of the potential 


Although no case reports have been seen regarding other adverse health effects of implanted 

RFID chips there is evidence from the field of cosmetic surgery in particular to suggest that, 

in a small minority of cases, adverse health reactions or migration of materials from the 

implant site can occur. Although the materials used obviously differ (which is likely to 

significantly impact on the degree of risk) the demonstrated occurrence of such effects does 

at least suggest a need for caution, especially before any provisions for compulsory 

implantation are contemplated. 

Application of the precautionary principle would seem to suggest that, if we do not know 

RFID chip implants to be safe (as opposed to knowing that they are unsafe, or perhaps how 

unsafe they are), then can we ethically implant them, even on the basis of ‘informed 

consent’? Legal arguments would suggest that, in order to legitimately obtain informed 

consent, we would need confidence in the information we were providing as the basis for that 

consent. However, where implantation is truly voluntary (without any suggestion of coercion) 

then informed consent on the basis of current knowledge (and uncertainty) is likely to be 

considered acceptable. 

8.3. Security concerns 

The issue of overriding need presents a connection to the next cross-cutting issue, that of 

security. Considerations of legal and ethical issues suggest that compulsory use of implants 

would need to have a very strong justification, such as a matter of national security, to 

warrant the personal intrusion involved. The test of no alternative viable solution would also 

be important here. Many of the press and informal reports surrounding the use of RFID chips 

focus on the convenience of the technology, of not having to carry a card for example, rather 

than enhanced security. This appears to stem from a recognition amongst those promoting 

the use of the technology that they are inherently insecure (in the same way as bank card 

PIN technology is vulnerable). Until such concerns are successfully addressed it would 

therefore appear to be difficult to justify a requirement for a chip implant on the grounds of 

security, as such an implant would perhaps be no more secure than the card it replaces.  

Clearly, they do offer ‘security’ in the sense that the chip is harder to lose than a separate 

card or other device might be – although a chip embedded into a close-fitting ring would offer 

a degree of such security unless deliberately removed.  

The Use of Chip Implants for Workers 

PE 614.209 39 

Apart from the adverse implications on security grounds for their application, the fact that 

the implanted chip can be detected by others raises uncertainties over what personal security 

vulnerabilities might be created in those who have them implanted. This was apparent in the 

comments of one long-term user (and advocate for the technology) regarding the 

vulnerability of personal identifiers held on the chip.  

8.4. Ethical barriers 

Ethically, those receiving such an implant voluntarily should also be made aware of the 

potential security limitations and risks. Chapter 5 identified a number of potential ethical 

barriers to compulsory use of RFID chip implants. Whatever the security applications (and 

assuming that the health and RFID security concerns can be adequately addressed) it must 

be acknowledged that there will be some individuals who will be opposed to their use on 

religious or other grounds.  

Some such views appear to be quite vehemently held (e.g. viewing the RFID chip as ‘the 

mark of the beast’35,36). There is no way of knowing how many people hold such views, but 

they must be recognised and accommodated as appropriate. 

8.5. Legal issues 

There is no specific, tailored and/or comprehensive legislation, case law or regulatory regime 

banning, restricting or controlling the use of microchip implants by employers in the EU or in 

any of the member states of the EU (“Member States”). As such, whether employers have 

the power to coerce their workers to accept such implants is a matter that is governed by 

the general principles and rules of EU labour law and human rights law, as well as the National 

laws of each of the Member States. Some of these provisions apply to both compulsory and 

voluntary applications of the technology. Thus: 

• The GDPR demands a very high standard of consent to microchipping from workers, 

which must be given by clear affirmative action establishing a freely given, specific, 

informed and unambiguous indication of the worker’s agreement to their personal 

data being processed. 

• There is no definitive answer to the question whether microchipping is unlawful as a 

breach of a worker’s human rights, since the appropriate response will depend on the 

nature and extent of the harm done to the worker, which is weighed against the 

employer’s need to engage in microchipping to fulfil a legitimate commercial objective. 

• If the implantation of a microchip gives rise to health and safety issues, there is a 

strong argument that such a managerial instruction would be unreasonable and 


• A managerial instruction to a worker to implant a microchip without consent can give 

rise to a constructive dismissal based on health and safety concerns. 

• In terms of EU indirect religious discrimination law, if the microchipping is not 

‘appropriate’, ‘necessary’, or ‘proportionate’ to achieve a real need, objective or aim 

that the employer has identified, its objective justification defence will not be satisfied. 

• It will only be in exceptional circumstances that (i) the ownership of the microchip 

would be vested in the worker, or (ii) the employer would have the legal authority to 

insist that it and other third parties retain any data collected and stored on the 

microchip at all times, including once the worker has moved on to another employer. 



36 Revelation 13:16-17 & 14:9-10 

Policy Department A: Economic and Scientific Policy 


 40 PE 614.209 

8.6. Overall outcome 

The possible use of RFID chips in the workplace raises a complex interaction between health, 

security, ethical and legal issues. In relation to their possible compulsory use, there is no 

specific legal instrument relating to such compulsory implantation of RFID chips into workers. 

However, it appears that such implants would encounter significant legal challenges in 

respect of current EU law, in particular relating to data protection and human rights (including 

the sanctity of the human body). Clearly, although laws can be changed or amended, the 

current uncertainties over the health implications of such implants and the wider security 

issues of RFID chips  tend to run counter to any such use that could be sanctioned at present. 

Although it is theoretically possible to sanction their use on the grounds of overriding security, 

current concerns regarding the security of the chips themselves would tend to obviate any 

such arguments. In addition, although there is evidence to suggest that they are over-

estimated, present uncertainties over possible health effects makes it impossible to give 

assurances regarding adverse health impacts. It seems likely that the same aspects would 

undoubtedly leave such applications vulnerable to legal and ethical challenge in the future, 

without a fundamental rethink of personal human rights and the sanctity of the human body. 

In respect of voluntary use in the workplace, it should be established that such use is entirely 

voluntary and that no coercion exists (for example in the form of preferential treatment of 

wearers – other than perhaps the convenience imparted to the wearer through using the 

chip). In such cases, potential wearers should be fully informed of the possible health risks 

(and the doubts and uncertainties regarding those risks) and of the security liabilities relating 

to RFID chip technologies. 

Finally, there is no specific regulatory provision currently in place regarding the process of 

implantation; in the form of minimum hygiene standards or other requirements. Although 

the current voluntary use is outside the scope of this paper it is noted that at least some of 

the advocates for the use of the technology believe such controls to be necessary and, if 

compulsory workplace use were to be sanctioned, such considerations would be a definite 


8.7. Future considerations 

As noted above it appears likely that any attempt to formally permit or sanction the 

compulsory use of RFID chip implants in workers would be subject to considerable opposition, 

especially in respect of human rights and the sanctity of the human body. As part of this it 

would seem likely that there would be challenges on religious grounds leading to claims of 

religious discrimination. 

With the present state of knowledge it would seem that there would be strong grounds for 

legal challenges on the basis of potential or perceived adverse health effects; and on the 

grounds that such implants would not offer the looked for additional security (over non-

implanted solutions) which could otherwise form part of any justification for their use. 

On this basis, unless there are significant pressures and priorities relating to advancing this 

technological application, it would seem defensible to adopt a watching brief and re-assess 

knowledge after an appropriate time. 

However, although this would seem to be a viable solution in relation to technological 

developments in enhanced security (where there does seem to be a significant and ongoing 

research community), the same does not appear to apply in respect of possible health effects. 

Current applications appear to be relatively piecemeal and uncoordinated, with little focus on 

claimed health effects. It would seem likely that no significant advances in knowledge in 

respect of possible health impacts in humans are likely to emerge without some form of 

positive action being taken. 

Two avenues of investigation would seem to be worth investigating in this regard.  


The Use of Chip Implants for Workers 

PE 614.209 41 

Desk-top medical research 

The first is to commission desk-top research from appropriate experts (in, for 

example, dermal medicine and oncology) to formally explore the scientific and medical 

literature relating to sub-dermal implantation to provide an authoritative evidence-

based theoretical review on the health risks potentially associated with the 

implantation of RFID chips. This would encompass carcinogenicity and other dermal 


Longitudinal study of health effects 

Secondly, although the logistics of such a study would be challenging, definitive 

answers on possible health effects would best be provided through a longitudinal 

(prospective) study of chip recipients. Given the expectation that, based on the 

reported animal studies, the incidence of such effects would be low, care must be 

taken to ensure that any such study is large enough to have sufficient statistical power 

to identify any such effects (or their absence) with any certainty. Given the recognised 

inter-species differences in cancer susceptibility there would seem to be little merit in 

pursuing studies in animal models, unless an appropriate surrogate species can be 

identified. Even here, if shorter-lived species such as rats or mice were employed it 

might be difficult to replicate the effects of implantation over the longer term. 

Even if definitive evidence was available to demonstrate that such devices were both secure 

and safe, it would seem to be highly likely that significant challenges would remain on ethical, 

moral and religious grounds; and that stringent data management regulations and guidance 

would be required. 

On this basis, unless there is seen to be an overwhelming need or demand for the compulsory 

implementation of implantable RFID chips in the workplace then adopting a waiting game 

would seem to be the preferred option.  

However, even in voluntary systems, workers (and others) need some protection. With self-

administered chip injection kits available on the internet, consideration should be given to a 

need to regulate their implantation (in the same way as others such as acupuncturists and 

tattooists come under appropriate controls). Whether such controls should be national or EU-

based is beyond the scope of this paper, but with clear potential risks of infection, 

contamination, etc., both from the chip itself and the implantation procedure, some provision 

for such protection would seem to be justified. 

Policy Department A: Economic and Scientific Policy 


 42 PE 614.209 


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