The Barbados-Guyana Digital Identity Card Travel Initiative: Identifying the data protection gaps

In May, Barbados and Guyana announced an agreement allowing their citizens to travel between the two countries using only their digital identity card beginning 1 July 2026. The agreement marks a seminal step in both countries' efforts to expand their digital transformation initiatives. 

The journey toward the passport-free travel system began in 2021, when Barbados rolled out its national digital identification card system through the Barbados Identity Management Act. The system relies on the Data Protection Act, passed in 2019, to provide a data protection and data privacy governance framework. Guyana followed in August 2023, passing its Digital Identity Card Act (No. 19 of 2023) alongside its Data Protection Act (No. 18 of 2023). 

Underlying this bilateral agreement are data protection legal frameworks modeled on the EU General Data Protection Regulation, although they are at varying stages of maturity. The Barbados Data Protection Act adopts all of the core principles on which the GDPR is founded, and its operational provisions are closely aligned with those of the GDPR. 

Although the Barbados Act came into force on 26 March 2021, the sections regarding the registration of data controllers and data processors are not yet operational. Shortly after the act came into force, it appointed a data protection commissioner to implement the act's operational, compliance, regulatory and enforcement requirements. 

By contrast, although Guyana's Data Protection Act is closely aligned with the GDPR, it appears to have been a more ad hoc legislative response enacted primarily to facilitate the implementation of the country's e-ID card system. The majority of the act is not operational and will require staggered implementation.