Yes, I think most of the developed world has something like a citizen register/family register. I think it is the Anglo-American culture that is the interesting diversion from the norm. For some historical reason, they have aversion to id numbers and central registers.
I'm not sure if there's a sardonic tone I'm missing from the last sentence, but for Americans, it's mostly just government run id numbers and central registers they have an issue with. Credit Card Accounts, Store Accounts, Website/Social Media Accounts, just put something free next to it and most Americans are more than happy to give you their life history.
But if the government is doing it, it's completely different. I understand that the basic idea is choosing to submit info versus being compelled by Government, but it's the exact same amount of collection and information, often more intrusive. It's an aversion to government, not an aversion to the idea of ID numbers and registers. There is probably a healthy level for this, but often times I hear about people taking it too far. My friends who have done census work have some of the worst stories about people trying to have a Braveheart moment when he had only just introduced himself.
> Credit Card Accounts, Store Accounts, Website/Social Media Accounts, just put something free next to it and most Americans are more than happy to give you their life history.
Which is somewhat ironic since the government pays for unlimited access to all that "privately" held data.
And yet, they can't help it, hence NSA. I doubt that anywhere in continental Europe there is a full-scale surveillance program like administered by NSA or GCHQ (or maybe we are unusually good at keeping secrets -- really doubt it, though).
>And yet, they can't help it, hence NSA. I doubt that anywhere in continental Europe there is a full-scale surveillance program like administered by NSA or GCHQ
> or maybe we are unusually good at keeping secrets -- really doubt it, though
France had two different services dedicated solely to internal intelligence/spying (until they got merged in 2008): the "RG"[0] (general intelligence) and the "DST"[1] (territorial surveillance directorate)
I don't think "having a service" has much meaning in this context? OP surely knows that the countries he referred to actually have intelligence services. Germany has at least two (BND and MAD) and depending on what exactly you mean more. I would say the point was to which lengths those services actually go.
Here in Britain we have compulsory registers of births, deaths and marriages and anyone can query them. You don't get a number or ID card but the data is collected.
It doesn't seem especially different to the continental systems.
Yeah, exactly like in Spain, where all these things are done in the Civil Registry (Registro Civil). I mean, the article is like a huge WTF... somebody needs to travel / read about other countries, etc...
In Spain we used to have the same system, called "Libro de Familia". It was abolished years ago because it simply does not work in a world where people don't live in the same place their parents do, people can get divorced and remarry several times and shared custody is a thing. Nowadays each person has his own birth certificate, marriage contract and the like.
That's not the same, because only you have it. In Japan it's the administration that holds the information (and gives you certificates when you need them).
Once you have lived in a country where you can get official documents for pretty much anything you care to prove, it feels like going back to the stone age when you move to a country where you can't.
Case in point: a Korean relative of mine was recently invited to join the board of an organization based in the UK. The UK org's bank wanted proof of address for the new board member, in the form of a notarized translation of a recent utility bill or credit card statement. In Korea, you can walk into any local government office and use a 24/7 self-serve kiosk to print out an official proof of your address. Not some random address like the Japanese koseki, but the actual address where you pay all your taxes and are registered to vote. You can even get it in English if you want. It comes with an official stamp and a cryptographic signature of its contents. But no, the UK bank won't take it. They want your fucking credit card statement.
Ditto for marriage certificates, death certificates, driving and other licenses, public education, land ownership, car and boat ownership, tax returns... pretty much anything a person might need to prove in the course of their lives. Lost the original? No big deal. You can get a new one whenever you want, wherever you want. You can even get the government to prove your employment history for you, if you're worried that your last employer might go bust and become unable to provide references.
And I don't think this makes us any more of a surveillance state than other countries, because the government is supposed to retain official records of all these things anyway. It's just a matter of letting citizens export their own information in a convenient and reliable format.
Had a similar culture clash when I moved from Sweden to the US, and some part of the process required a marriage license.
Marriage license... No, we don't have those, and we don't have birth certificates either.
But what you can get is a print-out from the government registry, complete with a signature from some clerk (important!) and a stamp (super important!), except it's all hilariously rudimentary, it looks like a print-out of an ascii text file, super basic, no care for formatting or line breaks to make it pretty or official-looking. The stamp is just the really basic logo of the Swedish Tax Authority, and some bored guy who did the print-out and stamped it, scribbled his or her initials next to the stamp.
It's a perfectly legal document of course, but it just reeks of "oh god, do we really have to deal with these uncivilized barbarians that want stuff on paper?"
The second culture clash was signing up for various services and having to give out my name and address, and getting my first electric bill with my name spelled wrong.
(In Sweden, you would just give whatever company your personal identification number, and then they can pull your name and official address. There's even a push service built into the system, so if I change my official address, most companies' computer systems would get the change, and just update my address automatically)
In Sweden anyone can look up where you live. And your earnings. And your grades from school. All government data is public, unless it is secret. (If you live under serious threats you can apply to get your data classified, in which case it is only allowed to be handled by people with clearance for that, which tend to make your life a bit complicated.)
Since it is the same for everyone, including the prime minister and the king which is kind of the point for a society that wishes to be transparent, it doesn't make much difference for the prevalence of spammy services. Except maybe lowering the market value of address registers.
Well the last two things are or should be illegal. If law enforcement in the US actually cared about enforcing the bulk of the law instead of only the parts which are personally profitable (drugs), you wouldn't really need to worry about them. Regarding debt collectors, well predatory lending practices are illegal as well, and beyond that its your personal responsibility to pay your debts.
Well, anyone can look up a person's census address, which isn't necessarily where you live, but it's probably an address you have control over, or someone else lives there who you trust.
When you interact with government or banks or anyone that needs to send you important documents, those are mailed to your census address, and nowhere else. It makes it much harder to do identity theft. (Basically, the whole transparent system makes it a lot easier to prevent identity theft)
I don't see how spammy services would benefit from this, for what it's worth I received a crapton more directly addressed spam when I lived in SF than when I lived in Stockholm.
Stalkers are handled by the system, as other commenters have pointed out, you can get a protected address, which means that very few can look up your census address.
Debt collectors... Explain to me in what way it is bad that someone whom you owe money can find you? Hiding to avoid paying debt you actually owe is illegal.
What's better, having one centralized database that's open and public or have thousands of databases kept by thousands of private companies and government offices some of which are incomplete or inaccurate?
Except there's all these companies who compile all these databases poorly. So the information ends up in one place anyways. It just ends up inaccurate and incomplete. It's also close to impossible to know who has what on you.
Yes, privacy is a problem. Of course not just anybody can look up anybody else, but the workers in the town office (who have to issue these forms) or police officers can look up a lot of information.
(In theory, they are prohibited from looking up information unrelated to their duty. In practice, I'm not sure how well that is enforced.)
On the other hand, as kijin said, government is going to have that information anyway. Better put it to some use. So it's a tradeoff, and the system has problems, but for the most part it's a reasonable tradeoff, IMHO.
(For example, all the current debate about "voter suppression" (aka voter ID law) in the US strikes me as completely bizarre. In Korea, if you're in the voting age you have a government-issued ID. You use that ID card to vote. End of story.)
Even if you're under the voting/driving age, any Korean citizen over 9 years old can ask to get an ID card for opening (non-credit) bank accounts, taking tests, getting discounts, and accessing various government services.
I live in a low-income area where lots of kids are on their own because their parents are alcoholic, disabled, always away, etc. The underage ID card helps them navigate the world.
It baffles my mind that anyone in the developed world in 2016 should be unable to prove such basic things as who they are and what country they belong to. If we're going to have pervasive surveillance, at least we should get some benefits out of it!
It baffles my mind that anyone in the developed world in 2016 should be unable to prove such basic things as who they are and what country they belong to.
In the U.S. the problem is not proving basic things, but preventing the government from building up a huge profile of everything about you, from what you ate and where you've been to the size and color of your underpants. Even that wouldn't be such a big deal if the government wasn't ultra paranoid and just constantly spied indiscriminately on everyone, actively trying to use that information against you, under the auspices of "protecting" you.
Bureaucracy in the U.S. is actually pretty simple and straightforward, and it works. For example, every time I compare how easy it is to buy, insure, register a vehicle, and renew its registration in the States, and then compare with a certain country in central Europe, I just want to scream and tear my hair out. In the States, it's a straightforward, practical, uncomplicated matter: after all, owning and driving a vehicle isn't a big deal, and shouldn't be one. The European country in question? WOE TO YOU: prepare for a protracted ping-pong between the local police station, the central police authority (ministry of internal affairs), the insurance company, back to the local police authority, then the technical inspection station, then the local police authority, and let's not forget at least two trips to a notary public. Oh yeah, and I almost forgot to mention at least one trip to the tax authorities. Payment to authorities? Not before you've been sent several times to a local newspaper kiosk, after waiting for up to two and a half hours in a line, to buy special government stamps, which then only the bureaucrat is allowed to affix and annul with a seal on the actual documents. And the entire time they all arrogantly stare at you wide-eyed, "but sir, what are you getting upset over?!?" Oh yeah, and your documents, like a birth certificate, aren't allowed to be older than six months. I mean that's "completely logical", because we all know that the place and time of one's birth is an ever changing variable, right? And yet, my driver's license which I've had since well into the last century isn't up for renewal until 2069... but get this, if you're tech savvy enough and get a login and a password(!!!) in a special governmental database (only in person at a physical teller, of course!), you can print some of these documents at home, SHA-1 check summed with a crypto key from the ministry of internal affairs, gratis... super consistent and fair to all citizens, huh?
In some things, U.S. is light years ahead. And when I see how easy it is to do things like that in the U.S. I feel I'm completely justified to question why the process cannot be as simple and as uncomplicated as it is in some other countries. In Singapore for example, it's enough to fill out one paper and get a company registered in up to 15 minutes; if it works there, it can work everywhere.
The obsession with cars is part of the reason why the U.S. doesn't bother to come up with a better way to identify its citizens. Nearly everyone has a driver's license, so why use any other form of photo ID?
A good American just gets a license and buys a car.
As far as I know, all states in the United States union have a photographic identification card which is almost identical to the driver's license, except that it is not one.
the really slick thing about the States is that a driver's license doubles as an identity card. I can show my driver's license anywhere in the 50 states and immediately authenticate myself, but if I show any of my other driver's licenses in the countries of their issuance, not one will accept it for proving my identity; they all require me to show them their respective identity cards. Such bureaucractic nonsense!
This is what I referred to in one of my earlier posts when I wrote that if it can be less bureaucratic and streamlined somewhere else (I used Singapore as an example then, in this case, the States), then it can work elsewhere too. Instead, people just come up with nonsensical excuses why it cannot work, for example that's just the way it is here, accept it! Such nonsensical arguments infuriate me.
States also offer ID cards that are not driver's licenses. Usually you apply using the same information, at the same locations and pay a lower fee than for a driver's license.
East Europe there. My car dealer did all the registration and insurance stuff. Came in once, signed the papers. Came back few days later, picked up the car with insurance and papers in glovebox, numberplates attached. They did have to go to gov agency to pickup the numberplates for me though.
When selling my old car, I gave the papers with my names to the new owner. Uploaded our printed&signed agreement to gov-run website. the new owner did the same. He had to go in-person to pick up the new papers with his name. It'll get even easier next year, new papers will be mailed to the new owner.
What is registration renewal? Over there, as long as you have valid insurance and roadworthiness test, you're good forever.
"Registration renewal", as it is known in the United States, is the equivalent of renewing one's motor vehicle and license plate registration in one - Fahrzeugausweis / prometna dozvola / etcetera. This is trivial to do in the United States, and is as simple as paying around $30 per year to the department of transportation of the state one lives in (it's an extra income for the state). In some european countries, it's a bureaucratic nightmare. I'm purposely not mentioning which ones, so don't ask. I will mention that some european countries do not have registration renewal at all - a Fahrzeugausweis is forever and does not expire, and there is no such (idiotic) concept as a "license plate renewal".
In my state the car dealer can register your vehicle for you. You call up your insurance company to insure it and give the dealer your policy number. The dealer types a few things into the computer. Bam, you're vehicle is registered. They open up a drawer to get your new license plates, affix them to your car, hand you your proof of registration and you drive off the lot.
I am not in France; there are other countries in Europe which have the byzantine stamp system of paying for fees; several of them in fact.
As far as Japanese bureaucracy goes, I've only had the "pleasure" of dealing with the process of obtaining and converting the voucher for the Japanese Rail pass. "Interesting" procedure, to say the least, and I think it offered a view into the dealings with Japanese bureaucracy.
After the initial confusion, next time I go to Japan, it won't be nearly as confusing, but it's pretty clear that the Japanese society is pretty bureaucratic.
Most information is only available to the person whom it concerns, or close family members. Some information, such as land ownership, is publicly available.
If you're printing out a document for the purpose of proving something specific to someone else, you can often request that irrelevant information (such as ID numbers) be redacted for privacy.
> And I don't think this makes us any more of a surveillance state than other countries, because the government is supposed to retain official records of all these things anyway.
England has a frustrating situation where the government collects all this stuff, and stores it all on computers, but in separate data centres in different databases and in incompatible formats.
So anytime I need to interact with them I have to fill out bizarrely long paper forms.
I work a bit in suicide prevention, and the length and complexity of the disability benefits forms[1] are implicated in some deaths by suicide, as well as some attempts.
[1] as well the brutality of the system. They have a lot of rules, and fiercely enforce those rules, but the first two lines of advice workers often don't what those rules are.
This is really nothing special at all. Latin American countries based on Spanish Civil Law have the same system (registro civil). As do countries of French origin and even the province of Quebec.
* Koseki as a data structure: It seems to be an event-log from which you can get an official certificate (extract) relfecting the current state. This is better than a systems where you work with loose records of the events themselves. Other countries should do the same thing.
* Koseki as a rigid record of official categories: Soft cultural issues are important here. Koseki happens to force people to change their name upon marriage, but makes official gender-change easy. The Japanese shrug at both aspects.
But English-speaking polities would not shrug, because they have an expectation that legal categories reflect these personal preferences [1]. This is a cultural thing that no data structure will fix.
* Koseki as an alternative to the courts: As long as people will get upset about the categories, and as long as people are allowed to have their legal say, these things will end up in court.
[1] For example, in the UK a "civil partnership" was a marriage-by-another-name arrangment for gay couples (before full marriage was extended to them in 2013). This resulted in complaints from heterosexual couples who wanted to get civil partnerships too.
Where other countries means "US", where everybody is paranoid and doesn't want government to have any kind of database on people.
In Ukraine we have this level of crazy people who refuse to obtain personal tax number citing religious beliefs (something-something chipization, devil numbers) that for some reason are promoted by Moscow Church, but not by local one.
> and doesn't want government to have any kind of database on people.
Yet you have to register to vote, and this registration allows you to optionally declare which political party your affiliated with.
...which is the completeopposite to Sweden. We have a system similar to the Koseki in the article, but it is expressly illegal for any part of government to make a registry of people's political opinions or sexual orientation, or a bunch of other sensitive characteristics. I even think race is one such category.
The color of skin is no more relevant to anything than color of hair. You can know the percentage of, say, red-haired people in your country, but what for? The only thing where that could be needed is to fight e.g. some Dark Ages prejudices against red-haired people, and this is expected to be a marginal issue, not some all-encompassing national program.
The same goes for religion. In Europe, religion is inherently private endeavour.
There are, of course, race-motivated crimes, as well as, say, anti-Semitism. However, if some newspaper suddenly started publishing something along the lines of "in northern Paris, there are now more than 4.8% Jewish residents, an increase of 0.3% compared to the last year", the Jews would be offended, and rightfully so (perhaps not so much in the US, but definitely in Europe).
There is no need for public knowledge for racial or "country of origin" statistics. There is no need to specifically hide or distort this information, of course, but it is of interest only for law enforcers. Anybody else who asks for it usually have questionable motivations.
It's important to know that government dealings in Sweden, and that includes databases, falls under the principle of publicity unless specifically exempt. That means government officials must make the information available to anyone who asks without delay or imposing a fee. (It's often a surprise to newcomers that information about earnings and taxes is public to anyone, but you get used to it being an equal right for all.) That's part of the reason policial and religious afflictions are forbidden to store.
Europe has had a lot of bad experiences when it comes to how we've treated our minorities, and the census has often been used as a tool for finding "undesirables". And I'm not only talking about countries like Germany here; Sweden had a policy of forced sterilisation for reasons of "racial hygiene", that it didn't discontinue until 1975.
I think you misunderstood. Sweden has a census, they just don't have a voter roll you can look up to see what race your neighbour is or what party they belong to.
Yes, you can collect racial statistics, but the thing that is expressly prohibited is to make a registry where you connect a person with these attributes.
The idea is that it should be impossible to, for example, get a list of all the communists in an area, or all the homosexuals, or all the moslems, or everyone of African descent.
It's a defense of minorities against a future fascist government. Which I think is kind of neat.
As far as I can tell, this anti-government paranoia in the US is just an internet bogeyman. It doesn't seem to stop the elite from doing anything, whether good or bad. It certainy hasn't prevented the US from compiling databases about its citizens.
Japan is the first country I've heard of that records family info in this way. But Australian states do have central land registries, these are maps which have the final say own who owns what.
In the US this system is rare, and the resistance has not come from Tea Partyers. Rather from the industry of title-insurers who benefit from the unceratin property rights created by the title-deed system.
By European standards it's good old corruption, but in US it's suddenly an "industry".
Whenever we have problem here, first mentioned solution would be Single National Registry of Whatever.
VAT returns fraud - make registry of all refunds. VAT evasion - log all VAT transaction in tax office database. Land disputes and corruption - make a map with all registered land plots and their owners and make it open. Voter suppression and voting fraud - make voter registry, have it always up to date and let voters check if they are on list online.
Corrupt officials - make open registry of tax declarations of all officials, MPs and their family members. Property and corporate ownership fraud - make registries of companies and properties and make it open.
Passports take longer than 30 days to issue - registry of all citizens, residents and everybody who entered country. And the first thing you do, if you are foreigner or citizen, you get tax number and keep that ugly piece of paper with you. Without tax number you don't even exists.
Curious, is it possible that the restrictive Soviet rule (beginning with Josef and ending with the death of Brezhnev or, if you will, Gorbachev's glasnost+peretroika) caused this, or does it go much further back to Zarist times? What's the underlying explanation?
Explanation for what exactly? To have your civil acts written in book kept by government - it's definitely not soviet invention, before USSR it was kept by church at least since 18th century.
No. It's just cheaper to make identity fraud without centralized database.
You pay few thousands to regional officer in any district and they issue you a handwritten internal id book [0] with whatever name you want and there is no trace of it. If something happens they would claim that id form was fraudulent or stolen.
However, when you get tax number, it goes through central office and leaves paper trail and entry in some database that records such issuance.
Sweden didn't have any problems with "y2gay", noone from the tax authority complained about massive changes there.
However, the whole transsexual/intersex phenomenon is causing more issues. Basically, gender is encoded in your ID number, and stored in the census database, so people who change gender won't get a new ID number, so there will be a discrepancy between their number and the (correct) database value, but some systems don't bother checking the database, they just infer it from the number, and choke when the gender is "wrong" for something, usually systems around registering parents.
I think the long-term solution will be to just stop registering the gender of people, and not make any system care about it anymore, thereby reflecting the current cultural norm. :-)
>Basically, gender is encoded in your ID number, and stored in the census database, so people who change gender won't get a new ID number, so there will be a discrepancy between their number and the (correct) database value
You do, in fact, get a new personal identification number when undergoing gender reassignment surgery.
Italy has the same, called "anagrafe", you need to update the registry every time you move to another city or even if you change street, since the registry not only tracks the relationships between individuals but the historical movements of single persons, and is also used in order to make you pay taxes about producing trash. Similarly when a child is born, the first thing to do for the parents is to go to the office and register the newborn, with the ability to recognize it, or not, for both the father and mother, as your child. That is, the mother can pretend that the child she just gave birth is not her, legally, if she is not ready to have a family, and this is considered by Italians a fundamental right of women, even if it is rarely used. It's a bit annoying to deal with this registry normally but it's an useful thing.
Interesting case: Poland has an address register that is slowly being deprecated -- it is no longer necessary to ever update it and in increasingly fewer situations a record from that registry is required (and it would be very unpopular if people actually had to report to the government that they've moved).
I wonder what are trends related to such registers in other countries.
Lithuanian there. I think we inherited a very similar system from soviet times.
Various things are slowly decoupled off the address registry. Major thing left is voting in election. Someone is eligible to vote for municipality. As in, for mayor of that municipality or it's parliament member. There're also optional municipality services that run off the same registry. For example, your kids may be rejected from municipality-sponsored kindergarten if you're not registered in the same municipality. This is to ensure another municipality is not receiving your taxes while you leech off neighbouring one. I guess that will get centralised sooner or later.
It is unlikely that it gets deprecated here. It's used for too many things. For instance one part of the free healthcare you get is a local doctor usually a few blocks from where you live where you can go for basic needs. This is also assigned based on your current address.
This also used to be the case in Poland. Now you can choose the GP you go to and change that decision IIRC twice a year. Choosing a doctor that's far away makes no sense, so there's no or little reason to restrict that choice to close doctors.
[T]he koseki ... is an integral part of Japanese family
law that doesn’t actually care about families beyond
ensuring that the legally significant aspects of them
are identifiable to the Rest of the World. Thus, a
koseki extract today will show a marriage, but not
whether the spouses are living together. The system
also doesn’t care (i.e., show) if the registered
father is not the biological father. It doesn’t care
whom the kids live with after a divorce or if a
divorced parent is paying maintenance or how often
(or if) he sees his children.
Thanks for letting me know! Too late to update the original, so here's the text again:
> [T]he koseki ... is an integral part of Japanese family law that doesn’t actually care about families beyond ensuring that the legally significant aspects of them are identifiable to the Rest of the World. Thus, a koseki extract today will show a marriage, but not whether the spouses are living together. The system also doesn’t care (i.e., show) if the registered father is not the biological father. It doesn’t care whom the kids live with after a divorce or if a divorced parent is paying maintenance or how often (or if) he sees his children.
That interested me as well. Is there another system to record biological ancestry (potentially important for medical reasons), child custody (and who decides which gets custody in case of a conflict), and child support?
I mean, taking normal prose and putting it in a pre tag is kind of a silly practice. I know we're hackers here and everything but that's actually not a great way to display anything but what it's intended for.
Legal systems define an abstract interface between individuals in a society. It's interesting how Japan's registration system choose different entities and different 'ACL rules' compared to, say, US common law.
Seems like it'd be tricky to build a koseki-like registration here. Legal abstractions have a lot of inertia, and usually requires some sort of war or revolution to precipitate change.
For example, most of Western Europe's legal systems are based on the Napoleonic code, spread by conquest, and was largely written after the French Revolution to sweep away the last vestiges of the monarchy and feudalism. Japan's modern koseki system was created right after the Meiji Restoration.
Sure, the federal government could set something up, but I think the tricky part is getting all the individual states to adopt the system.
Two things to note though: the Japanese registry system was originally set up so the government could keep track of its people, and given the level of anti-government paranoia in the US, I highly doubt that sort of change would get support.
A majority of Americans don't even support a uniform ID card for all citizens, which almost every other country has.
>Sure, the federal government could set something up, but I think the tricky part is getting all the individual states to adopt the system.
It doesn't even need to be on federal level. Just think about it - koseki was designed mid-19 century and used paper records held by municipality. Churches in Europe kept paper books noting marriages, births and deaths even before that.
The downsides are obvious:
- in case of need you should go to same municipality and get extract from same book where event was recorded;
- you only can make record in book of municipality where you are resident.
Also possible in implementing such a system are a variety of accidents or abuses that may unfairly benefit or harm different groups. "Seeding" the central database from the existing patchwork of forms, licenses, decisions, databases and other records would be inherently messy and even a quasi-legal database could cause a bureaucratic nightmare once any process starts depending upon it.
Seems like another article where Americans finding out how the rest of the world doesn't use the same retarded systems as they do. What's next, an article about this marvelous invention called 'the metric system' that is used in Bolivia ?
Exactly my thought. Every European country I've lived in works in pretty much the same way. Of course saying it comes from Japan makes it look more sophisticated ;)
Actually no, the koseki system or similar can be found in other Asian countries like South Korea but not in Europe.
In France you can get a birth certificate, a marriage certificate, and you have a "livret de famille" that regroups all these information but that's a document that you own, not the administration. There is no registry that regroups all the information about a given family.
Also note that in Japan, a women getting married will be transferred from her parents' koseki to her husband's koseki. There is no such thing in Europe.
European countries don't have a family-centered system like the Koseki (or Chinese Hukou; Wikipedia says South Korea abolished their system a decade ago) where a document represents a family.
But several of them do have a population register (which is individual-centered, but with references up and down in the family tree). In Sweden you don't get birth or marriage certificates. If you want to prove your birth or marriage, you get your population registry extract which shows that you are registered as existing (proves birth) or married.
So they're the same in that they are based on current state rather than collecting event documents. But they're different in that one represents families, whereas the other represents individuals.
Japan also has a separate residency register. While the koseki shows who is in a family (birth/parents, marriage/children), the residency register shows where you live now/before (and is used for taxation). European countries with a population register simply use the same registry for both purposes.
>event-based” Official Documents (birth certificates, divorce decrees and so forth) that prevail in places like America
Almost all other developed countries have comprehensive civil registration system that is not event based (The first country to establish a nationwide population register was Sweden in 1631).
In United States some of these functions are divided between Office of Vital Records in each state and clerk of court of each individual county, but you need official document trail for most things.
As a recent immigrant to Finland the population system there is pretty fascinating. Seeing how many men/women share my forename was pretty cool, for example.
One of the immediate perks was moving house - I updated my address in the population index and suddenly all the companies that bill me and send me mail had new details. No extra effort.
(Of course then I had to update my contact details on domains, and online stores outside Finland, but it was a great timesaver.)
In The Netherlands the civil registry is considered privacy sensitive information and not publicly accessible. You can get an extract of your personal information but you can't access the information of others, not even family or people who are already dead for use in genealogical research. Your records are opened to the public 100 years after death.
There are two ways handling registration processes. One way is to develop a registration system as little as possible, but then hoping not to deal with the papers later, because of the mess made in the process. Or, you develop a system thoroughly in the first place so that you don't have to deal much with the papers later, because the system was developed to avoid mess. Why patch fundamentally broken systems anyway? Why develop an interdependent system for personal data? There are different questions which reflect exactly the philosophy of eastern and western bureaucracy.
It is still impossible for couples to register a marriage without one legally assuming the other’s surname, an antediluvian restriction that was nonetheless found constitutional by the Supreme Court last year.
Interestingly, a workaround for this is to marry a foreigner. Japanese who marry non-japanese citizens don't need to switch their surnames.
As a data format, koseki are interesting because they are tied up with citizenship in a weird way. [1] The spouse variable only holds values of type citizen so people who marry foreigners have their spouse listed in the free-form description section. :-)
This has some drawbacks but in the case of having different surnames it gets you around the restriction.
The real weirdness in the US vs the rest of the world is not that you have to get a court to issue a divorce or that there isn't a central registry, but rather there are literally fifty separate systems, all with slight variations, and you're not locked into a particular one. Divorces used to easier to obtain in Nevada, so people would go there. Certain states adopted same sex marriage before others, so you'd go there.
In the US, there is a certain history of suspiciously convenient courthouse fires destroying property records. And then there are accidental fires---my mother late in life could not attend college classes because her high school had burned in the '50s and she had no way of providing she graduated. (I suppose there would be ways around the issue, but she didn't want to bother and thought it was funny.)
Anyway, seems like a good way to completely erase someone's existence.
I'm sure it's far less true than it used to be but historically, yes, a lot of US records existed only in paper form in some school or courthouse or town hall where they were subject to being lost in a fire, natural disaster, or just carelessness. Certainly it's been a plot point in many a book or movie where someone assumes an identity chosen because records concerning a person had been lost in some manner.
Based on stories I've head over the years, it can actually be quite challenging to get a passport if you can't lay your hands on your birth certificate or if that birth certificate doesn't match up with you because of some mistake or whatever.
It's pretty much same in ex-USSR countries. Even if you get divorce papers in court, you would still need to go with them to registry office and that's where divorce would really happen.
The downside is, that sometimes you would need to go to that exact registry office where your marriage was registered, name changed or your child born and it can be thousands of kilometers away from where you live now.
Austria has the same basically. The interior ministry runs a few central registries for these things. You have a unique number hat follows you around and your records are linked through it. It's very convenient.
Not only does it simolify tings, it also has some other advantages. For instance becayse your car license olate is through that system linked to your home adress that automatically updates people with Austrian licdnse placea typically do not get clamped.
Nice as this all seems, the process for accessing the information in one's koseki is amazingly primitive. Most times that you need to do something official in Japan as a Japanese citizen, a copy of your koseki is required. Open a bank account and you'll need one. Apply for a passport and you'll need one etc. You'll not only need an original hard copy transcript of your koseki (tōhon/short-form or shōhon/long-form), but it will need to be dated within the last 3 months.
How do you get one? Online? No. Got to visit your city/village/ward office. Any local city/village/ward office? No, it's got to be within the district where your koseki is held. OK, let's take a trip back to our hometown in the evening - surely there's a 24 hour kiosk in the lobby where I can print one out? No. Come during business hours, fill out a paper form requesting a transcript, take a number, wait in line to submit the request form. Go over what you wrote in the request form with an extremely nice and polite bureaucrat. Take another number to wait in line to pay about US$1.50 for the hard copy. Then a final number to pick up the hard copy. Wow.
Why's this so hard? Well, although the contents of the koseki are of course computerized, these records are held at the ward/village/city office level and not nationally. Sure, the police, immigration authorities and others likely have a way to access each ward office's system, but as a citizen you have to physically trudge down to the office in the region where your koseki is held and request a copy. Not so bad if you're living near your family (since your koseki is typically kept at the ancestral home of your family, not necessarily where you live day-to-day), but if you've moved across Japan or internationally, you're screwed. Hope you have a family member you can deputise to go get one for you or that you have a good number of frequent flyer points to burn.
The article seems to say it's pretty straight forward from overseas at any Japanese consulate. Well, not so much. Strangely enough, write access from overseas is pretty easy. Read access from overseas doesn't exist.
Case in point - my wife and I recently had a baby born in the Bay Area who is eligible for Japanese citizenship. No problems, we head to the consulate and fill out the paperwork, provide all the birth proof documents and pay a small fee. The consulate sends the birth details to the city/village/ward office where our koseki is held and that ward office adds our baby to it a week or two later. Now, we need a passport. Can we just ask the consulate to authenticate our baby since they just added him to our koseki? Nope. We have to fly to Japan to visit the city/ward office where our koseki is held, or deputize a family member in Japan to do so for us, obtain a hard-copy of the updated koseki, have it posted to us in California and we then bring it into the consulate to prove our baby's citizenship - citizenship that they themselves just authenticated a few weeks ago. Wow. On top of that, there's no way of knowing when our baby has been added, so we just need to ask our family members to go down once a week for the next few weeks, request and pay for a copy and when our son appears, claim success.
So yes, it's a great system, but it's so very paper and physical presence based that it hurts.
Surprisingly enough, especially for Japan, foreigners have it easier. Since foreign residents are not on a koseki (well, they are in the case that they're married to a Japanese citizen but only in the "comments" section of the koseki, not the actual core of it and that's a whole 'nother story), none of this paperwork is required when foreigners want to deal with the Japanese bureaucracy. Instead, foreigners are required to carry a plastic ID card (called a "Zairyu card" in its latest permutation) and this has all the necessary information. No 3 month expiry, no ward office visit. So, there's at least one area that non-Japanese have it easier in Japan that citizens!
As someone who carries a Zairyu card, I can attest to the weirdness of Japanese bureaucracies. The silver lining is that, in my experience, most (all?) ward offices are staffed with helpful people who generally are good about chasing down answers and maintaining a can-do attitude about bureaucratic matters. The waits aren't usually too long either. You can definitely get caught in some Kafkaesque loops though.
Damn, what bank would require a koseki? For that kind of stuff, it's usually based on the residency system (and you can print a 住民票 at any convenience store copy machine in Japan with the proper RFID-equipped ID card). Those still have to be printed within 3 months to be valid.
But yeah, for matters of marriage, birth and residency, it's all based on the koseki, and it's painfully distributed. My wife's koseki is held in the tiny village where her father was born, and where they haven't lived in many decades. "Luckily", since it's within the prefecture they can have it mailed to the central city hall, but it's still a completely pointless paper exercise. Must be kept around as a jobs program in all these dying rural villages...
Meanwhile I can print out my Swedish residency registry information by logging in to the tax office via a 2 factor authentication smartphone app and downloading a PDF.
There are a lot of examples here, here's one more;
In Turkey, there has been a sort of central family-record keeping thingy for ages. It's centrally held, you don't need to go to your hometown to get one, but you had to go to a government office in your district of residence(you still need to, if you want an official hard-copy) (some records are, like place of residence, are kept locally though(. There was a project to computerize all of the process, mernis, it started in the early 90s and finished sometime around 2007. Since then, for most official businesses, you don't need the official document, just your ID card will do (or for emergencies, just the ID number printed on your ID card).
The real odd thing about this system is, for non-usual stuff, you actually need to go to court and sue the government agency for the change. Filing for a divorce? You need to sue NVI for that. Changing your official name? Sue them. Sex change? Not sure about that, but probably yes.
Disadvantage to that is having all the state records kept centrally, and knowing how Turkey works, probably under very lax security. In fact, the entire database(at least a copy of it made for the 2009 elections) got leaked earlier this year.
This is analogous to the Torrens system of land registration (called a "land registry" in the article), pioneered in South Australia in the mid 1800s. It has almost totally replaced Common Law title everywhere that the Common Law operates.
Prior to Torrens, land ownership was under Common Law. You owned land by buying a title or deed from the previous owner, who had bought from someone else, and so on.
If the chain was broken, you ran the risk that some day, someone would show up with an unbroken chain that ran back further than yours.
Naturally this created an ocean of bitter legislation, often populated by jaunty fleets of fraudulent documents.
The Torrens system essentially says: unless it's in the government register, no land ownership or change of ownership is valid. You can sign anything you like, say anything you like, join pinkies and make a pinky promise. Until you update the register, it doesn't matter.
It's a simple and effective system. Given that enforcing the law of property is one of the fundamental purposes of governments, it makes sense that they would simplify enforcement for themselves and their citizens.
I gather that it may vary by state, but in some places in the US it's apparently not even required to register births--which can cause problems for the children involved later on:
Basically then, event sourced rather than OO CRUD. Not surprisingly, it makes things easier when distributed, just like in micro-service architectures.
I like this a lot. England's Common Law system was created as a means for the powerful to remain powerful, not because it made any sense.
I haven't been to Asia (yet), but I can say that in the "Western World" courts are overloaded with cases that should probably not go further than your local ombudsman which in itself is a very old concept found in millenia old civilizations, predating the court system as we know it. This is probably why courts in the US have quick processing of a group of independent, alleged criminal offenders. It's unfair to those accused of breaking the law as it is to the lawyers and maybe even the judge who has to decide in two minutes whether the accused should go to jail/prison while the case is progressing. I'm afraid to suggest fixing the latter, because law enforcement organizations would likely push for legislation to make it quicker and easier to put people in real prison without a hearing or trial.
https://en.wikipedia.org/wiki/Family_register