Where’s the Benefit?

Inspired by Gene Volfe. People of a certain age will get the reference.

But even if you don’t know the difference between Clara Peller and Clara Barton, remember this: 

Prospects don’t care about features that excite you. They care about benefits that excite them. 

If you only list features, you might as well be talking to yourself…because you are.

Where’s the Benefit?

Federal Trade Commission Age Verification (and estimation?) Workshop January 28

A dizzying array of federal government agencies is interested in biometric verification and biometric classification, for example by age (either age verification or age estimation). As Biometric Update announced, we can add the Federal Trade Commission (FTC) to the list with an upcoming age verification workshop.

Rejecting age estimation in 2024

The FTC has a history with this, having rejected a proposed age estimation scheme in 2024.

“Re: Request from Entertainment Software Rating Board, Yoti Ltd., Yoti (USA) Inc., and Kids Web Services Ltd. for Commission Approval of Children’s Online Privacy Protection Rule Parental Consent Method (FTC Matter No. P235402)

“This letter is to inform you that the Federal Trade Commission has reviewed your group’s (“the ESRB group”) application for approval of a proposed verifiable parental consent (“VPC”) method under the Children’s Online Privacy Protection Rule (“COPPA” or “the Rule”). At this time, the Commission declines to approve the method, without prejudice to your refiling the application in the future….

“The ESRB group submitted a proposed VPC method for approval on June 2, 2023. The method involves the use of “Privacy-Protective Facial Age Estimation” technology, which analyzes the geometry of a user’s face to confirm that the user is an adult….The Commission received 354 comments regarding the application. Commenters opposed to the application raised concerns about privacy protections, accuracy, and deepfakes. Those in support of the application wrote that the VPC method is similar to those approved previously and that it had sufficient privacy guardrails….

“The Commission is aware that Yoti submitted a facial age estimation model to the National Institute of Standards and Technology (“NIST”) in September 2023, and Yoti has stated that it anticipates that a report reflecting NIST’s evaluation of the model is forthcoming. The Commission expects that this report will materially assist the Commission, and the public, in better understanding age verification technologies and the ESRB group’s application.”

You can see the current NIST age estimation results on NIST’s “Face Analysis Technology Evaluation (FATE) Age Estimation & Verification” page, not only for Yoti, but for many other vendors including my former employers IDEMIA and Incode.

But the FTC rejection was in 2024. Things may be different now.

Grok.

Revisiting age verification and age estimation in 2026?

The FTC has scheduled an in-person and online age verification workshop on January 28.

  • The in-person event will be at the Constitution Center at 400 7th St SW in Washington DC.
  • Details regarding online attendance will be published on this page in the coming weeks.

“The Age Verification Workshop will bring together a diverse group of stakeholders, including researchers, academics, industry representatives, consumer advocates, and government regulators, to discuss topics including:  why age verification matters, age verification and estimation tools, navigating the regulatory contours of age verification, how to deploy age verification more widely, and interplay between age verification technologies and the Children’s Online Privacy Protection Act (COPPA Rule).”

Will the participants reconsider age estimation in light of recent test results?

Access and “Somewhat You Why”

In case you missed it, I’ve been pushing a sixth factor of authentication called “Somewhat You Why.”

“As I refined my thinking, I came to the conclusion that “why” is a reasonable factor of authentication, and that this was separate from the other authentication factors (such as “something you do”).”

And now Identity Jedi Harvey Lee is also asking the “why” question, but specifically in terms of access control.

“[B]ecause we couldn’t determine why someone needed access, we built systems that tried to guess the answer for us….

“Roles were never about “least privilege.” Roles were our attempt to predict intent at scale. And like most predictions, especially in complex systems, they were right until they weren’t….

“Instead of front-loading permissions for every possible future scenario, we authorize the current scenario. Identity might still be the new perimeter — but intent is the new access key.”

Read “Intent Is the New Access Key.”

For example, if a dehydrated man wants to unlock a water tank, I have a pretty good idea of his intent.

Google Gemini.

How Do You Make Cash Payments to the CORRECT People?

In the United States, we forget that much of the world does NOT fill out W-9 forms.

Take the apparel industry in Jordan.

“In Jordan, the apparel sector relies heavily on a large migrant workforce, many of whom lack access to bank accounts and remain unbanked. Wage payments have traditionally been cash-based…”

To facilitate cash payments to unbanked apparel workers in Jordan, IrisGuard stepped in with its EyePay product.

“Cairo Amman Bank (CAB) Jordan…has launched a national-scale biometric cash salary payment network for unbanked workers. 

“With just a simple iris scan, employees can securely access their wages instantly, without the need for a bank account, PIN, or physical ID.”

I don’t think this is tied to an iris-based time and attendance system, but that is the obvious next step.

Bredemarket’s Biggest Accomplishments in 2025 (So Far)

I’m jumping ahead in the year-end post ridiculousness to cite Bredemarket’s two most notable accomplishments this year. Not to detract from my other accomplishments this year, but these two were biggies.

The first was my Biometric Update guest post in May, “Opinion: Vendors must disclose responsible uses of biometric data.” I discussed elsewhere my reasons for writing this, and created a Bredemarket-hosted video summarizing my main points.

Biometric vendors…

The second was my go-to-market effort for a Bredemarket client in September, which I discussed (without mentioning my participation) here. And there’s a video for that effort also.

Recent go-to-market.

I’ve accomplished many other things this year: client analyses, blog posts (both individually and in series), consultations, presentations, press releases, proposals, requirements documents, sales playbooks, and many more.

And I still have three more weeks to accomplish things.

Order in the Court: California AI Policies

Technology is one thing. But policy must govern technology.

For example, is your court using artificial intelligence?

If your court is in California, it must abide by this rule by next week:

“Any court that does not prohibit the use of generative AI by court staff or judicial officers must adopt a generative AI use policy by December 15, 2025. This rule applies to the superior courts, the Courts of Appeal, and the Supreme Court.”

According to Procopio, such a policy may cover items such as a prohibition on entering private data into public systems, the need to verify and correct AI-generated results, and disclosures on AI use.

Good ideas outside the courtroom also.

For example, the picture illustrating this post was created by Google Gemini—as of this week using Nano Banana.

Which is not a baseball team.

Google Gemini.