Tag Archives: age verification

What Is Your Firm’s UK Online Safety Act Story?

It’s time to revisit my August post entitled “Can There Be Too Much Encryption and Age Verification Regulation?” because the United Kingdom’s Online Safety Bill is now the Online Safety ACT.

Having passed, eventually, through the UK’s two houses of Parliament, the bill received royal assent (October 26)….

[A]dded in (to the Act) is a highly divisive requirement for messaging platforms to scan users’ messages for illegal material, such as child sexual abuse material, which tech companies and privacy campaigners say is an unwarranted attack on encryption.

From Wired.
By Adrian Pingstone – Transferred from en.wikipedia, Public Domain, https://commons.wikimedia.org/w/index.php?curid=112727

This not only opens up issues regarding encryption and privacy, but also specific identity technologies such as age verification and age estimation.

This post looks at three types of firms that are affected by the UK Online Safety Act, the stories they are telling, and the stories they may need to tell in the future. What is YOUR firm’s Online Safety Act-related story?

What three types of firms are affected by the UK Online Safety Act?

As of now I have been unable to locate a full version of the final final Act, but presumably the provisions from this July 2023 version (PDF) have only undergone minor tweaks.

Among other things, this version discusses “User identity verification” in 65, “Category 1 service” in 96(10)(a), “United Kingdom user” in 228(1), and a multitude of other terms that affect how companies will conduct business under the Act.

I am focusing on three different types of companies:

  • Technology services (such as Yoti) that provide identity verification, including but not limited to age verification and age estimation.
  • User-to-user services (such as WhatsApp) that provide encrypted messages.
  • User-to-user services (such as Wikipedia) that allow users (including United Kingdom users) to contribute content.

What types of stories will these firms have to tell, now that the Act is law?

Stories from identity verification services

From Yoti.

For ALL services, the story will vary as Ofcom decides how to implement the Act, but we are already seeing the stories from identity verification services. Here is what Yoti stated after the Act became law:

We have a range of age assurance solutions which allow platforms to know the age of users, without collecting vast amounts of personal information. These include:

  • Age estimation: a user’s age is estimated from a live facial image. They do not need to use identity documents or share any personal information. As soon as their age is estimated, their image is deleted – protecting their privacy at all times. Facial age estimation is 99% accurate and works fairly across all skin tones and ages.
  • Digital ID app: a free app which allows users to verify their age and identity using a government-issued identity document. Once verified, users can use the app to share specific information – they could just share their age or an ‘over 18’ proof of age.
From Yoti.

Stories from encrypted message services

From WhatsApp.

Not surprisingly, message encryption services are telling a different story.

MailOnline has approached WhatsApp’s parent company Meta for comment now that the Bill has received Royal Assent, but the firm has so far refused to comment.

Will Cathcart, Meta’s head of WhatsApp, said earlier this year that the Online Safety Act was the most concerning piece of legislation being discussed in the western world….

[T]o comply with the new law, the platform says it would be forced to weaken its security, which would not only undermine the privacy of WhatsApp messages in the UK but also for every user worldwide. 

‘Ninety-eight per cent of our users are outside the UK. They do not want us to lower the security of the product, and just as a straightforward matter, it would be an odd choice for us to choose to lower the security of the product in a way that would affect those 98 per cent of users,’ Mr Cathcart has previously said.

From Daily Mail.

Stories from services with contributed content

From Wikipedia.

And contributed content services are also telling their own story.

Companies, from Big Tech down to smaller platforms and messaging apps, will need to comply with a long list of new requirements, starting with age verification for their users. (Wikipedia, the eighth-most-visited website in the UK, has said it won’t be able to comply with the rule because it violates the Wikimedia Foundation’s principles on collecting data about its users.)

From Wired.

What is YOUR firm’s story?

All of these firms have shared their stories either before or after the Act became law, and those stories will change depending upon what Ofcom decides.

But what about YOUR firm?

Is your firm affected by the UK Online Safety Act, and the future implementation of the Act by Ofcom?

Do you have a story that you need to tell to achieve your firm’s goals?

Do you need an extra, experienced hand to help out?

Learn how Bredemarket can create content that drives results for your firm.

Click the image below.

Drive content results with Bredemarket Identity Firm Services.

The Imperfect Way to Enforce New York’s Child Data Protection Act

It’s often good to use emotion in your marketing.

For example, when biometric companies want to justify the use of their technology, they have found that it is very effective to position biometrics as a way to combat sex trafficking.

Similarly, moves to rein in social media are positioned as a way to preserve mental health.

By Marc NL at English Wikipedia – Transferred from en.wikipedia to Commons., Public Domain, https://commons.wikimedia.org/w/index.php?curid=2747237

Now that’s a not-so-pretty picture, but it effectively speaks to emotions.

“If poor vulnerable children are exposed to addictive, uncontrolled social media, YOUR child may end up in a straitjacket!”

In New York state, four government officials have declared that the ONLY way to preserve the mental health of underage social media users is via two bills, one of which is the “New York Child Data Protection Act.”

But there is a challenge to enforce ALL of the bill’s provisions…and only one way to solve it. An imperfect way—age estimation.

This post only briefly addresses the alleged mental health issues of social media before plunging into one of the two proposed bills to solve the problem. It then examines a potentially unenforceable part of the bill and a possible solution.

Does social media make children sick?

Letitia “Tish” James is the 67th Attorney General for the state of New York. From https://ag.ny.gov/about/meet-letitia-james

On October 11, a host of New York State government officials, led by New York State Attorney General Letitia James, jointly issued a release with the title “Attorney General James, Governor Hochul, Senator Gounardes, and Assemblymember Rozic Take Action to Protect Children Online.”

Because they want to protect the poor vulnerable children.

By Paolo Monti – Available in the BEIC digital library and uploaded in partnership with BEIC Foundation.The image comes from the Fondo Paolo Monti, owned by BEIC and located in the Civico Archivio Fotografico of Milan., CC BY-SA 4.0, https://commons.wikimedia.org/w/index.php?curid=48057924

And because the major U.S. social media companies are headquartered in California. But I digress.

So why do they say that children need protection?

Recent research has shown devastating mental health effects associated with children and young adults’ social media use, including increased rates of depression, anxiety, suicidal ideation, and self-harm. The advent of dangerous, viral ‘challenges’ being promoted through social media has further endangered children and young adults.

From https://ag.ny.gov/child-online-safety

Of course one can also argue that social media is harmful to adults, but the New Yorkers aren’t going to go that far.

So they are just going to protect the poor vulnerable children.

CC BY-SA 4.0.

This post isn’t going to deeply analyze one of the two bills the quartet have championed, but I will briefly mention that bill now.

  • The “Stop Addictive Feeds Exploitation (SAFE) for Kids Act” (S7694/A8148) defines “addictive feeds” as those that are arranged by a social media platform’s algorithm to maximize the platform’s use.
  • Those of us who are flat-out elderly vaguely recall that this replaced the former “chronological feed” in which the most recent content appeared first, and you had to scroll down to see that really cool post from two days ago. New York wants the chronological feed to be the default for social media users under 18.
  • The bill also proposes to limit under 18 access to social media without parental consent, especially between midnight and 6:00 am.
  • And those who love Illinois BIPA will be pleased to know that the bill allows parents (and their lawyers) to sue for damages.

Previous efforts to control underage use of social media have faced legal scrutinity, but since Attorney General James has sworn to uphold the U.S. Constitution, presumably she has thought about all this.

Enough about SAFE for Kids. Let’s look at the other bill.

The New York Child Data Protection Act

The second bill, and the one that concerns me, is the “New York Child Data Protection Act” (S7695/A8149). Here is how the quartet describes how this bill will protect the poor vulnerable children.

CC BY-SA 4.0.

With few privacy protections in place for minors online, children are vulnerable to having their location and other personal data tracked and shared with third parties. To protect children’s privacy, the New York Child Data Protection Act will prohibit all online sites from collecting, using, sharing, or selling personal data of anyone under the age of 18 for the purposes of advertising, unless they receive informed consent or unless doing so is strictly necessary for the purpose of the website. For users under 13, this informed consent must come from a parent.

From https://ag.ny.gov/child-online-safety

And again, this bill provides a BIPA-like mechanism for parents or guardians (and their lawyers) to sue for damages.

But let’s dig into the details. With apologies to the New York State Assembly, I’m going to dig into the Senate version of the bill (S7695). Bear in mind that this bill could be amended after I post this, and some of the portions that I cite could change.

From https://www.nysenate.gov/legislation/bills/2023/S7695

The “definitions” section of the bill includes the following:

“MINOR” SHALL MEAN A NATURAL PERSON UNDER THE AGE OF EIGHTEEN.

From https://www.nysenate.gov/legislation/bills/2023/S7695, § 899-EE, 2.

This only applies to natural persons. So the bots are safe, regardless of age.

Speaking of age, the age of 18 isn’t the only age referenced in the bill. Here’s a part of the “privacy protection by default” section:

§ 899-FF. PRIVACY PROTECTION BY DEFAULT.

1. EXCEPT AS PROVIDED FOR IN SUBDIVISION SIX OF THIS SECTION AND SECTION EIGHT HUNDRED NINETY-NINE-JJ OF THIS ARTICLE, AN OPERATOR SHALL NOT PROCESS, OR ALLOW A THIRD PARTY TO PROCESS, THE PERSONAL DATA OF A COVERED USER COLLECTED THROUGH THE USE OF A WEBSITE, ONLINE SERVICE, ONLINE APPLICATION, MOBILE APPLICA- TION, OR CONNECTED DEVICE UNLESS AND TO THE EXTENT:

(A) THE COVERED USER IS TWELVE YEARS OF AGE OR YOUNGER AND PROCESSING IS PERMITTED UNDER 15 U.S.C. § 6502 AND ITS IMPLEMENTING REGULATIONS; OR

(B) THE COVERED USER IS THIRTEEN YEARS OF AGE OR OLDER AND PROCESSING IS STRICTLY NECESSARY FOR AN ACTIVITY SET FORTH IN SUBDIVISION TWO OF THIS SECTION, OR INFORMED CONSENT HAS BEEN OBTAINED AS SET FORTH IN SUBDIVISION THREE OF THIS SECTION.

From https://www.nysenate.gov/legislation/bills/2023/S7695

So a lot of this bill depends upon whether a person is over or under the age of eighteen, or over or under the age of thirteen.

And that’s a problem.

How old are you?

The bill needs to know whether or not a person is 18 years old. And I don’t think the quartet will be satisfied with the way that alcohol websites determine whether someone is 21 years old.

From https://www.budlight.com/

This age verification method is…not that robust.

Attorney General James and the others would presumably prefer that the social media companies verify ages with a government-issued ID such as a state driver’s license, a state identification card, or a national passport. This is how most entities verify ages when they have to satisfy legal requirements.

For some people, even some minors, this is not that much of a problem. Anyone who wants to drive in New York State must have a driver’s license, and you have to be at least 16 years old to get a driver’s license. Admittedly some people in the city never bother to get a driver’s license, but at some point these people will probably get a state ID card.

You don’t need a driver’s license to ride the New York City subway, but if the guitarist wants to open a bank account for his cash it would help him prove his financial identity. By David Shankbone – Own work, CC BY-SA 3.0, https://commons.wikimedia.org/w/index.php?curid=2639495
  • However, there are going to be some 17 year olds who don’t have a driver’s license, government ID or passport.
  • And some 16 year olds.
  • And once you look at younger people—15 year olds, 14 year olds, 13 year olds, 12 year olds—the chances of them having a government-issued identification document are much less.

What are these people supposed to do? Provide a birth certificate? And how will the social media companies know if the birth certificate is legitimate?

Birth certificate of a B.H. Obama II. From https://obamawhitehouse.archives.gov/sites/default/files/rss_viewer/birth-certificate-long-form.pdf

But there’s another way to determine ages—age estimation.

How old are you, part 2

As long-time readers of the Bredemarket blog know, I have struggled with the issue of age verification, especially for people who do not have driver’s licenses or other government identification. Age estimation in the absence of a government ID is still an inexact science, as even Yoti has stated.

Our technology is accurate for 6 to 12 year olds, with a mean absolute error (MAE) of 1.3 years, and of 1.4 years for 13 to 17 year olds. These are the two age ranges regulators focus upon to ensure that under 13s and 18s do not have access to age restricted goods and services.

From https://www.yoti.com/wp-content/uploads/Yoti-Age-Estimation-White-Paper-March-2023.pdf

So if a minor does not have a government ID, and the social media firm has to use age estimation to determine a minor’s age for purposes of the New York Child Data Protection Act, the following two scenarios are possible:

  • An 11 year old may be incorrectly allowed to give informed consent for purposes of the Act.
  • A 14 year old may be incorrectly denied the ability to give informed consent for purposes of the Act.

Is age estimation “good enough for government work”?

Why Age-Restricted Gig Economy Companies Need Continuous Authentication (and Liveness Detection)

If you ask any one of us in the identity verification industry, we’ll tell you how identity verification proves that you know who is accessing your service.

  • During the identity verification/onboarding step, one common technique is to capture the live face of the person who is being onboarded, then compare that to the face captured from the person’s government identity document. As long as you have assurance that (a) the face is live and not a photo, and (b) the identity document has not been tampered, you positively know who you are onboarding.
  • The authentication step usually captures a live face and compares it to the face that was captured during onboarding, thus positively showing that the right person is accessing the previously onboarded account.

Sound like the perfect solution, especially in industries that rely on age verification to ensure that people are old enough to access the service.

Therefore, if you are employing robust identity verification and authentication that includes age verification, this should never happen.

By LukaszKatlewa – Own work, CC BY-SA 4.0, https://commons.wikimedia.org/w/index.php?curid=49248622

Eduardo Montanari, who manages delivery logistics at a burger shop north of São Paulo, has noticed a pattern: Every time an order pickup is assigned to a female driver, there’s a good chance the worker is a minor.

From https://restofworld.org/2023/underage-gig-workers-brazil/

An underage delivery person who has been onboarded and authenticated, and whose age has been verified? That’s impossible, you say! Read on.

31,000 people already know how to bypass onboarding and authentication

Rest of World wrote an article (tip of the hat to Bianca Gonzalez of Biometric Update) entitled “Underage gig workers keep outsmarting facial recognition.”

Outsmarting onboarding

How do the minors do it?

On YouTube, a tutorial — one of many — explains “how to deliver as a minor.” It has over 31,000 views. “You have to create an account in the name of a person who’s the right age. I created mine in my mom’s name,” says a boy, who identifies himself as a minor in the video.

From https://restofworld.org/2023/underage-gig-workers-brazil/
From https://www.youtube.com/watch?v=59vaKab4g2M. “Botei no da minha mãe não conta da minha.” (“I put it on my mother’s account, it doesn’t count on mine.”)

Once a cooperative parent or older sibling agrees to help, the account is created in the older person’s name, the older person’s face and identity document is used to create the account, and everything is valid.

Outsmarting authentication

Yes, but what about authentication?

That’s why it’s helpful to use a family member, or someone who lives in the minor’s home.

Let’s say little Maria is at home, during her homework, when her gig economy app rings with a delivery request. Now Maria was smart enough to have her older sister Irene or her mama Cecile perform the onboarding with the delivery app. If she’s at home, she can go to Irene or Cecile, have them perform the authentication, and then she’s off on her bike to make money.

(Alternatively, if the app does not support liveness detection, Maria can just hold a picture of Irene or Cecile up to the camera and authenticate.)

  • The onboarding process was completed by the account holder.
  • The authentication was completed by the account holder.
  • But the account holder isn’t the one that’s actually using the service. Once authentication is complete, anyone can access the service.

So how do you stop underage gig economy use?

According to Rest of World, one possible solution is to tattle on underage delivery people. If you see something, say something.

But what’s the incentive for a restaurant owner or delivery recipient to report that their deliveries are being performed by a kid?

By Marcello Casal Jr./Agência Brasil – http://www.agenciabrasil.gov.br/media/imagens/2008/02/20/1145mc0222a.jpg/view/normal, CC BY 2.5 br, https://commons.wikimedia.org/w/index.php?curid=3590294

“The feeling we have is that, at least this poor boy is working. I know this is horrible, but here in Brazil we end up seeing it as an opportunity … It’s ridiculous,” (psychologist Regiane Couto) said.

From https://restofworld.org/2023/underage-gig-workers-brazil/

A much better solution is to replace one-time authetication with continuous authentication, or at least be smarter in authentication. For example, a gig delivery worker could be required to authenticate at multiple points in the process:

  • When the worker receives the delivery request.
  • When the worker arrives at the restaurant.
  • When the worker makes the delivery.

It’s too difficult to drag big sister Irene or mama Cecile to ALL of these points.

This guy’s over 18. I think. By shopblocks – https://www.flickr.com/photos/155237687@N06/34720130102/, CC BY 2.0, https://commons.wikimedia.org/w/index.php?curid=89964934

As an added bonus, these authetications provide timestamps of critical points in the delivery process, which the delivery company and/or restaurant can use for their analytics.

Problem solved.

Except that little Maria doesn’t have any excuse and has to complete her homework.

This Post Has Nothing to Do With Age Verification

My previous post on the complexity of multi-purpose devices included the phrase “When I was a kid.”

Probably shouldn’t have done that.

By Vinther et al. – 3D Camouflage in an Ornithischian Dinosaur, Current Biology (2016), https://dx.doi.org/10.1016/j.cub.2016.06.065, CC BY 4.0, https://commons.wikimedia.org/w/index.php?curid=51767365

Can There Be Too Much Encryption and Age Verification Regulation?

Designed by Freepik.

Approximately 2,700 years ago, the Greek poet Hesiod is recorded as saying “moderation is best in all things.” This applies to government regulations, including encryption and age verification regulations. As the United Kingdom’s House of Lords works through drafts of its Online Safety Bill, interested parties are seeking to influence the level of regulation.

The July 2023 draft of the Online Safety Bill

On July 25, 2023, Richard Allan of Regulate.Tech provided his assessment of the (then) latest draft of the Online Safety Bill that is going through the House of Lords.

House of Lords chamber, Palace of Westminster, London. By UK government – https://civilservicelocal.blog.gov.uk/2015/02/26/learning-about-the-workings-of-parliament/, OGL 3, https://commons.wikimedia.org/w/index.php?curid=61679038

In Allan’s assessment, he wondered whether the mandated encryption and age verification regulations would apply to all services, or just critical services.

Allan considered a number of services, but I’m just going to hone in on two of them: WhatsApp and Wikipedia.

The Online Safety Bill and WhatsApp

WhatsApp is owned by a large American company called Meta, which causes two problems for regulators in the United Kingdom (and in Europe):

  • Meta is a large company.
  • Meta is an American company.

WhatsApp itself causes another problem for UK regulators:

  • WhatsApp encrypts messages.

Because of these three truths, UK regulators are not necessarily inclined to play nice with WhatsApp, which may affect whether WhatsApp will be required to comply with the Online Safety Bill’s regulations.

Allan explains the issue:

One of the powers the Bill gives to OFCOM (the UK Office of Communications) is the ability to order services to deploy specific technologies to detect terrorist and child sexual exploitation and abuse content….

But there may be cases where a provider believes that the technology it is being ordered to deploy would break essential functionality of its service and so would prefer to leave the UK rather than accept compliance with the order as a condition of remaining….

If OFCOM does issue this kind of order then we should expect to see some encrypted services leave the UK market, potentially including very popular ones like WhatsApp and iMessage.

From https://www.regulate.tech/online-safety-bill-some-futures-25th-july-2023/

And this isn’t just speculation on Allan’s part. Will Cathcart has been complaining about the provisions of the draft bill for months, especially since it appears that WhatsApp encryption would need to be “dumbed down” for everybody to comply with regulations in the United Kingdom.

Speaking during a UK visit in which he will meet legislators to discuss the government’s flagship internet regulation, Will Cathcart, Meta’s head of WhatsApp, described the bill as the most concerning piece of legislation currently being discussed in the western world.

He said: “It’s a remarkable thing to think about. There isn’t a way to change it in just one part of the world. Some countries have chosen to block it: that’s the reality of shipping a secure product. We’ve recently been blocked in Iran, for example. But we’ve never seen a liberal democracy do that.

“The reality is, our users all around the world want security,” said Cathcart. “Ninety-eight per cent of our users are outside the UK. They do not want us to lower the security of the product, and just as a straightforward matter, it would be an odd choice for us to choose to lower the security of the product in a way that would affect those 98% of users.”

From https://www.theguardian.com/technology/2023/mar/09/whatsapp-end-to-end-encryption-online-safety-bill

In passing, the March Guardian article noted that WhatsApp requires UK users to be 16 years old. This doesn’t appear to be an issue for Meta, but could be an issue for another very popular online service.

The Online Safety Bill and Wikipedia

So how does the Online Safety Bill affect Wikipedia?

Wikipedia article about the Online Safety Bill as of August 1, 2023. https://en.wikipedia.org/wiki/Online_Safety_Bill

It depends on how the Online Safety Bill is implemented via the rulemaking process.

As in other countries, the true effects of legislation aren’t apparent until the government writes the rules that implement the legislation. It’s possible that the rulemaking will carve out an exemption allowing Wikipedia to NOT enforce age verification. Or it’s possible that Wikipedia will be mandated to enforce age verification for its writers.

Let’s return to Richard Allan.

If they do not (carve out exemptions) then there could be real challenges for the continued operation of some valuable services in the UK given what we know about the requirements in the Bill and the operating principles of services like Wikipedia.

For example, it would be entirely inconsistent with Wikipedia’s privacy principles to start collecting additional data about the age of their users and yet this is what will be expected from regulated services more generally.

From https://www.regulate.tech/online-safety-bill-some-futures-25th-july-2023/

Left unsaid is the same issue that affects encryption: age verification for Wikipedia may be required in the United Kingdom, but may not be required for other countries.

It’s no surprise that Jimmy Wales of Wikipedia has a number of problems with the Online Safety Bill. Here’s just one of them.

(Wales) used the example of Wikipedia, in which none of its 700 staff or contractors plays a role in content or in moderation.

Instead, the organisation relies on its global community to make democratic decisions on content moderation, and have contentious discussions in public.

By contrast, the “feudal” approach sees major platforms make decisions centrally, erratically, inconsistently, often using automation, and in secret.

By regulating all social media under the assumption that it’s all exactly like Facebook and Twitter, Wales said that authorities would impose rules on upstart competitors that force them into that same model.

From https://www.itpro.com/business-strategy/startups/370036/jimmy-wales-online-safety-bill-could-devastate-small-businesses

And the potential regulations that could be imposed on that “global community” would be anathema to Wikipedia.

Wikipedia will not comply with any age checks required under the Online Safety Bill, its foundation says.

Rebecca MacKinnon, of the Wikimedia Foundation, which supports the website, says it would “violate our commitment to collect minimal data about readers and contributors”.

From https://www.bbc.com/news/technology-65388255

Regulation vs. Privacy

One common thread between these two cases is that implementation of the regulations results in a privacy threat to the affected individuals.

  • For WhatsApp users, the privacy threat is obvious. If WhatsApp is forced to fully or partially disable encryption, or is forced to use an encryption scheme that the UK Government could break, then the privacy of every message (including messages between people outside the UK) would be threatened.
  • For Wikipedia users, anyone contributing to the site would need to undergo substantial identity verification so that the UK Government would know the ages of Wikipedia contributors.

This is yet another example of different government agencies working at cross purposes with each other, as the “catch the pornographers” bureaucrats battle with the “preserve privacy” advocates.

Meta, Wikipedia, and other firms would like the legislation to explicitly carve out exemptions for their firms and services. Opponents say that legislative carve outs aren’t necessary, because no one would ever want to regulate Wikipedia.

Yeah, and the U.S. Social Security Number isn’t an identificaiton number either. (Not true.)

I Changed My Mind on Age Estimation

(Part of the biometric product marketing expert series)

I’ll admit that I previously thought that age estimation was worthless, but I’ve since changed my mind about the necessity for it. Which is a good thing, because the U.S. National Institute of Standards and Technology (NIST) is about to add age estimation to its Face Recognition Vendor Test suite.

What is age estimation?

Before continuing, I should note that age estimation is not a way to identify people, but a way to classify people. For once, I’m stepping out of my preferred identity environment and looking at a classification question. Not “gender shades,” but “get off my lawn” (or my tricycle).

Designed by Freepik.

Age estimation uses facial features to estimate how old a person is, in the absence of any other information such as a birth certificate. In a Yoti white paper that I’ll discuss in a minute, the Western world has two primary use cases for age estimation:

  1. First, to estimate whether a person is over or under the age of 18 years. In many Western countries, the age of 18 is a significant age that grants many privileges. In my own state of California, you have to be 18 years old to vote, join the military without parental consent, marry (and legally have sex), get a tattoo, play the lottery, enter into binding contracts, sue or be sued, or take on a number of other responsibilities. Therefore, there is a pressing interest to know whether the person at the U.S. Army Recruiting Center, a tattoo parlor, or the lottery window is entitled to use the service.
  2. Second, to estimate whether a person is over or under the age of 13 years. Although age 13 is not as great a milestone as age 18, this is usually the age at which social media companies allow people to open accounts. Thus the social media companies and other companies that cater to teens have a pressing interest to know the teen’s age.

Why was I against age estimation?

Because I felt it was better to know an age, rather than estimate it.

My opinion was obviously influenced by my professional background. When IDEMIA was formed in 2017, I became part of a company that produced government-issued driver’s licenses for the majority of states in the United States. (OK, MorphoTrak was previously contracted to produce driver’s licenses for North Carolina, but…that didn’t last.)

With a driver’s license, you know the age of the person and don’t have to estimate anything.

And estimation is not an exact science. Here’s what Yoti’s March 2023 white paper says about age estimation accuracy:

Our True Positive Rate (TPR) for 13-17 year olds being correctly estimated as under 25 is 99.93% and there is no discernible bias across gender or skin tone. The TPRs for female and male 13-17 year olds are 99.90% and 99.94% respectively. The TPRs for skin tone 1, 2 and 3 are 99.93%, 99.89% and 99.92% respectively. This gives regulators globally a very high level of confidence that children will not be able to access adult content.

Our TPR for 6-11 year olds being correctly estimated as under 13 is 98.35%. The TPRs for female and male 6-11 year olds are 98.00% and 98.71% respectively. The TPRs for skin tone 1, 2 and 3 are 97.88%, 99.24% and 98.18% respectively so there is no material bias in this age group either.

Yoti’s facial age estimation is performed by a ‘neural network’, trained to be able to estimate human age by analysing a person’s face. Our technology is accurate for 6 to 12 year olds, with a mean absolute error (MAE) of 1.3 years, and of 1.4 years for 13 to 17 year olds. These are the two age ranges regulators focus upon to ensure that under 13s and 18s do not have access to age restricted goods and services.

From https://www.yoti.com/wp-content/uploads/Yoti-Age-Estimation-White-Paper-March-2023.pdf

While this is admirable, is it precise enough to comply with government regulations? Mean absolute errors of over a year don’t mean a hill of beans. By the letter of the law, if you are 17 years and 364 days old and you try to vote, you are breaking the law.

Why did I change my mind?

Over the last couple of months I’ve thought about this a bit more and have experienced a Jim Bakker “I was wrong” moment.

I was wrong for two reasons.

Kids don’t have government IDs

Designed by Freepik.

I asked myself some questions.

  • How many 13 year olds do you know that have driver’s licenses? Probably none.
  • How many 13 year olds do you know that have government-issued REAL IDs? Probably very few.
  • How many 13 year olds do you know that have passports? Maybe a few more (especially after 9/11), but not that many.

Even at age 18, there is no guarantee that a person will have a government-issued REAL ID.

So how are 18 year olds, or 13 year olds, supposed to prove that they are old enough for services? Carry their birth certificate around?

You’ll note that Yoti didn’t target a use case for 21 year olds. This is partially because Yoti is a UK firm and therefore may not focus on the strict U.S. laws regarding alcohol, tobacco, and casino gambling. But it’s also because it’s much, much more likely that a 21 year old will have a government-issued ID, eliminating the need for age estimation.

Sometimes.

In some parts of the world, no one has government IDs

Over the past several years, I’ve analyzed a variety of identity firms. Earlier this year I took a look at Worldcoin. While Worldcoin’s World ID emphasizes privacy so much that it does not conclusively prove a person’s identity (it only proves a person’s uniqueness), and makes no attempt to provide the age of the person with the World ID, Worldcoin does have something to say about government issued IDs.

Online services often request proof of ID (usually a passport or driver’s license) to comply with Know your Customer (KYC) regulations. In theory, this could be used to deduplicate individuals globally, but it fails in practice for several reasons.

KYC services are simply not inclusive on a global scale; more than 50% of the global population does not have an ID that can be verified digitally.

From https://worldcoin.org/blog/engineering/humanness-in-the-age-of-ai

But wait. There’s more:

IDs are issued by states and national governments, with no global system for verification or accountability. Many verification services (i.e. KYC providers) rely on data from credit bureaus that is accumulated over time, hence stale, without the means to verify its authenticity with the issuing authority (i.e. governments), as there are often no APIs available. Fake IDs, as well as real data to create them, are easily available on the black market. Additionally, due to their centralized nature, corruption at the level of the issuing and verification organizations cannot be eliminated.

Same source as above.

Now this (in my opinion) doesn’t make the case for Worldcoin, but it certainly casts some doubt on a universal way to document ages.

So we’d better start measuring the accuracy of age estimation.

If only there were an independent organization that could measure age estimation, in the same way that NIST measures the accuracy of fingerprint, face, and iris identification.

You know where this is going.

How will NIST test age estimation?

Yes, NIST is in the process of incorporating an age estimation test in its battery of Face Recognition Vendor Tests.

NIST’S FRVT Age Estimation page explains why.

Facial age verification has recently been mandated in legislation in a number of jurisdictions. These laws are typically intended to protect minors from various harms by verifying that the individual is above a certain age. Less commonly some applications extend benefits to groups below a certain age. Further use-cases seek only to determine actual age. The mechanism for estimating age is usually not specified in legislation. Face analysis using software is one approach, and is attractive when a photograph is available or can be captured.

In 2014, NIST published a NISTIR 7995 on Performance of Automated Age Estimation. The report showed using a database with 6 million images, the most accurate age estimation algorithm have accurately estimated 67% of the age of a person in the images within five years of their actual age, with a mean absolute error (MAE) of 4.3 years. Since then, more research has dedicated to further improve the accuracy in facial age verification.

From https://pages.nist.gov/frvt/html/frvt_age_estimation.html

Note that this was in 2014. As we have seen above, Yoti asserts a dramatically lower error rate in 2023.

NIST is just ramping up the testing right now, but once it moves forward, it will be possible to compare age estimation accuracy of various algorithms, presumably in multiple scenarios.

Well, for those algorithm providers who choose to participate.

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