The Iranian government’s “Seventh Development Plan” bill, which was passed in the past month, is one of the most significant and influential laws affecting Iran’s digital realm. It contains a key section called the “Lifestyle Assessment System”, a far-reaching initiative that aims to monitor and control the activities and behaviors of Iranian users. This system is based on various technologies and policies that Iran has been pursuing for years, such as facial recognition, e-government services, and developing surveillance tools under the prosecutor’s office to spy on Iranian citizens. The bill was approved between 9th Shahrivar to 9th Mehr 1402 (August 31, 2023 to September 30, 2023), and it marks a major step by the Iranian government towards becoming a surveillance state.
The Iranian government’s efforts to increase control over internet access have also seen it localize internet infrastructure, including applications, cloud services, web hosting, and national open-source repositories. Moreover, they have integrated user information from different sectors, such as healthcare, housing, civil registration, and tracking imported products. Simultaneously, the government is pursuing other measures that will severely impact privacy, such as the SIAM system, the “hijab and chastity” bill, tiered internet access, and hardware equipment tracking.
Overall, the Iranian government’s data collection efforts are advancing rapidly without any legal protection for citizens’ privacy, giving the government, judicial, and security institutions the power to misuse the data in any way they want. This report argues that through the new “People’s Lifestyle Assessment System,” Iran’s government is moving towards becoming a surveillance state that violates the privacy of Iranian citizens extensively and monitors every aspect of their lives.
This system aims to gather all kinds of data on citizens’ daily lives by various sources, such as government agencies (e.g., the Ministry of Culture and Islamic Guidance, the Islamic Republic of Iran Broadcasting, the Statistical Center, and the Supreme Council of the Cultural Revolution) and private entities (e.g., online taxi services, payment service providers, navigation apps, and any other apps that gather user data).
The data is intended to be used for continuous surveillance, tracking, measuring, and future studies on topics such as “public culture indicators, people’s lifestyle, media reach, and the state of the country’s communications,” as well as for “constant observation, monitoring, and measurement of public culture indicators, levels of religiosity, spirituality, ethics, and people’s lifestyle with an Iranian-Islamic approach, and the constant assessment of values, tendencies, and cultural and social institutions in Iranian society.” These terms are vague and undefined, and they do not specify what kind of data will be collected, how, and by what means. Moreover, it is unclear how non-quantitative issues such as spirituality and religiosity can be measured at all.
Importantly, the Seventh Development Plan bill does not clarify the structure of the data holders and whether they include private companies. These are the main issues that critics of this proposed “Lifestyle System” in the parliament and legal experts have raised. They argue that this system is a tool for spying on people’s everyday lives.
The Legal Problem of the “Lifestyle System”
The Digiato website reported on November 7, 2023, that the Lifestyle System was approved with a clause that requires compliance with Article 25 of the Constitution. This clause was added on October 21, 2023, by parliamentarians in Article 75 of the Seventh Development Plan bill.
Of note, Article 25 of the Constitution of the Islamic Republic bans any form of eavesdropping and spying, unless authorized by the law.
However, experts who have examined this bill say that the term “authorized by the law” is vague and ambiguous, and that a judge cannot issue a legal authorization for the whole population.
Ali Akbar Mousavi Khoeini, a former parliament representative and the Vice Chairman of the Communications Commission, told Filterban that this clause does not specify a particular person, and that this gives judges more room to justify their decisions. He added that this increases the risk of widespread abuse of the legal authorization and the violation of citizens’ privacy.
Moreover, the clause is unclear about the definition of “database” and whether it encompasses private companies. It also lacks clarity on how data, especially qualitative data like spirituality levels, will be collected and assessed. These ambiguities could lead to potential misuse of the law.
Ali Akbar Mousavi Khoeini expressed concerns in this regard: “General indicators such as public culture, media authority, and the state of national communications, which are explicitly mentioned in this clause, make [law] abuse possible, and these very terms leave room for interpretation.”
Government Access to Citizens’ Data: Scope and Concerns
The Iranian government has long sought access to citizens’ data, leading to disputes with the private sector over access to citizens’ data. Abolhassan Firouzabadi, former Secretary of the Supreme Council of Cyberspace, suggested on May 24, 2022, that governmental access to such data in the “National Data Exchange Center” can be achieved through “economic interaction” between private businesses and the government.
Meanwhile, the Seventh Development Law mandates that data from “databases” be continuously accessible to its proposed Lifestyle System. Yet, it fails to clarify which entities, beyond government entities, are included in these databases. This ambiguity grants legislators broad access to citizens’ data through the National Information Network (the domestic intranet being established by the Iranian government).
Currently, the government gathers data from over 40 databases, including civil registration, property records, law enforcement, social security, the central bank, and tax affairs, compiling it in the Iranian Welfare Database. This data is used for the “means test” to determine economic strata and allocate government subsidies.
The Seventh Development Plan’s Lifestyle Assessment System, however, proposes more extensive monitoring of Iranians’ lives, extending beyond economic factors. The table below outlines the government organizations tasked with data collection under this proposed system. It is important to note that the term “private databases” remains undefined, leaving uncertain which organizations or data are included.
| Legal Clause | Apparent Name of the Project | Collected Data | Organization Responsible or Involved in the Project |
| Subsection 5, Clause ‘Z’, Article 48 | Creation and issuance of a unique postal identifier for use in the national goods distribution platform | Postal information of individuals and specifications of goods sent through the postal network | National Post Company |
| Part 5 of Clause ‘D’ of Article 48 | Establishment of a National Platform for Distribution of Goods and Products | Information related to the producers of industrial, agricultural products, and e-commerce goods | Ministry of Communications – Postal Operators and Stakeholders in the Goods Transportation Sector |
| Clauses ‘A’ and ‘B’ of Article 108 | National Database of Cadastral Documents and Properties of the Country | Information on property ownership documents (excluding motor vehicles). | Judiciary |
| Clauses ‘G’ and ‘S’ of Article 85 | Prevention of Crime Using SIM Cards | Receiving information about deceased SIM card owners, dissolved or closed legal entities, non-Iranian nationals who have left the country with temporary residence, and prisoners from mobile operators (or organizations holding the aforementioned information) | Ministry of Communications |
| Clause ‘A’ of Article 115 | Establishment of an Electronic System for Providing Legal Medical Services | Receiving medical information of individuals from the Ministry of Health, insurance organizations, law enforcement agencies, and the judiciary + Sending medical information of examinations and inquiries of legal medicine | Legal Medicine Organization |
| Clause ‘A’ of Article 114 | Improvement of the Comprehensive System for Properties and Documents | All information related to the properties of the country and their legal status should be recorded | Organization for Registration of Deeds and Properties |
| Subsection ‘8-0’ of the Addendum to Article 153 | Electronic System for Vehicle License Plate Registration | Registration of vehicles equipped with an Iranian-made localizer should be conducted. (According to a report by Borna News Agency quoting Asghar Jahangir, Deputy of the Judiciary, on December 27, 2023, this localizer or position finder, designed by the Ministry of Defence, is intended to be installed on domestic vehicles | Law Enforcement Command (Police Force) and Ministry of Communications |
| Addendum 3 of Article 128 | Updating information and faster access to data for security purposes | Receiving information from smart surveillance and monitoring systems (cameras) installed in main and secondary urban streets and intercity highways | Law Enforcement Command (Police Force) |
| Note 2 of Article 69 | Updating the Iranian Electronic Health Record System | Medical information of all Iranian and non-Iranian individuals who receive services in Iran from natural persons (medical staff) and legal entities (hospitals and clinics) | Ministry of Health |
Parliamentary Debate on the Lifestyle System: Key Points of Proponents and Opponents
Supporters of the “Lifestyle System” include MPs Mohsen Zanganeh, Ahmad Rastineh, and Seyed Naser Mousavi Largani. According to a report by the Mizan News Agency, in the public session of the parliament on November 6, 2023, all three defended the “research” aspect of the Lifestyle Assessment System. Ahmad Rastineh stated that in this system, “big data” is analyzed, not the personal data of people. Later, Parliamentary Speaker Mohammad Bagher Ghalibaf also said that personal data access requires a judicial warrant.
Meanwhile, Jalal Rashidi Koochi and Gholamreza Nouri Qazlje are among the members of parliament who have been critical of the Lifestyle Assessment system. Nouri Qazlje told the website Digiato on November 8, 2023 that, according to bill’s text, anyone who has any data about the population is obliged to give it to the government, whether it is a government agency or a private entity. Jalal Rashidi Koochi, who is representative of Marvdasht and Pasargad, criticized the ambiguity of the terms in this bill on July 20, 2023 in an interview with ILNA News Agency. He stated that it is unclear how the “spiritual level” of the people is supposed to be measured in this system.
