You will soon deal with privacy stakeholders (and they won’t care about the GYRO method)

(Part of the biometric product marketing expert series)

I’ve written about the various stakeholders at government agencies who have an interest in biometrics procurements- not only in this post, but also in a post that is available to Bredemarket Premium subscribers. One of the stakeholders that appeared on my list was this one.

The privacy advocate who needs to ensure that the biometric data complies with state and national privacy laws.

Broken Liberty: Istanbul Archaeology Museum. By © Nevit Dilmen, CC BY-SA 3.0, https://commons.wikimedia.org/w/index.php?curid=1115936

If you haven’t encountered a privacy advocate in your marketing or proposal efforts…you will.

Utah Gov. Spencer Cox has appointed Christopher Bramwell as the Department of Government Operations’ first privacy officer….As privacy officer, Bramwell will be responsible for surveying and compiling information about state agencies’ privacy practices to discern which poses a risk to individual privacy. He will also work with the personal privacy oversight commission and state privacy officer to provide government privacy practice reports and recommendations.

Obviously this affects companies that work with government agencies on projects such as digital identity platforms. After all, mobile driver’s licenses contain a wealth of personally identifiable information (PII), and a privacy advocate will naturally be concerned about who has access to this PII.

But what about law enforcement? Do subjects in law enforcement databases have privacy rights that need to be respected? After all, law enforcement agencies legally share PII all the time.

However, there are limitations on what law enforcement agencies can share.

  • First off, remember that not everyone in a law enforcement database is an arrested individual. For example, agencies may maintain exclusion databases of police officers and crime victims. When biometric evidence is found at a crime scene, agencies may compare the evidence against the exclusion database to ensure that the evidence does not belong to someone who is NOT a suspect. (This can become an issue in DNA mixtures, by the way.)
  • Second off, even arrested individuals have rights that need to be respected. While arrested individuals lose some privacy rights (for example, prisoners’ cells can be searched and prisoners’ mail can be opened), a privacy advocate should ensure that any system does not deny prisoners protections to which they are entitled.

So expect to see a raised concern about privacy rights when dealing with law enforcement agencies. This concern will vary from jurisdiction to jurisdiction based upon the privacy (and biometric) laws that apply in each jurisdiction, but vendors that do business with government agencies need to stay abreast of privacy issues.

A little more about stakeholders, or actors, or whoever

Whether you’re talking about stakeholders in a government agency, stakeholders at a vendor, or external stakeholders, it’s important to identify all of the relevant stakeholders.

Or whatever you call them. I’ve been using the term “stakeholders” to refer to these people in this post and the prior posts, but there are other common terms that could be used. People who construct use cases refer to “actors.” Marketers will refer to “personas.”

Whatever term you use, it’s important to distinguish between these stakeholders/actors/personas/whatever. They have different motivations and need to be addressed in different ways.

When talking with Bredemarket clients, I often need to distinguish between the various stakeholders, because this can influence my messaging significantly. For example, if a key decision-maker is a privacy officer, and I’m communicating about a fingerprint identification system, I’m not going to waste a lot of time talking about the GYRO method.

My time wouldn’t be wasted effort if I were talking to a forensic examiner, but a privacy advocate just wouldn’t care. They would just sit in silence, internally musing about the chances that a single latent examiner’s “green” determination could somehow expose a private citizen to fraud or doxxing or something.

This is why I work with my clients to make sure that the messaging is appropriate for the stakeholder…and when necessary, the client and I jointly develop multiple messages for multiple stakeholders.

If you need such messaging help, please contact Bredemarket for advice and assistance. I can collaborate with you to ensure that the right messages go to the right stakeholders.

The Surfside building collapse may require a redefinition of “real-time” regarding rapid DNA

(Part of the biometric product marketing expert series)

I’ve previously noted that the definition of “real-time” can vary depending upon the use case. In the automated fingerprint identification systems world of the late 1990s, a definition of “real-time” in minutes was appropriate, but for the computer aided dispatch world, “real-time” was (and is) measured in seconds.

“Hi, SCC folks, welcome to Printrak. You’re joining a company that sells REAL TIME AFIS that delivers results within one minute! Aren’t you impressed?”

“Hello, new corporate overlords. We provide computer aided dispatch systems that send police, fire, and medical personnel to crime scenes and emergency sites as soon as possible. If our CAD systems took AN ENTIRE MINUTE to dispatch personnel, PEOPLE WOULD DIE. We use really powerful computers to get personnel dispatched in a second. Enjoy your real time AFIS…amateurs.”

I also mentioned a two-hour “real-time” use case, which is (conservatively) the time it takes a rapid DNA instrument to do its work.

The rapid DNA vendors provide machines that can perform an automated DNA analysis in 90 minutes, a vast improvement over traditional DNA especially when existing backlogs are taken into account. And for the most part, 90 minutes is fine.

But the Surfside tragedy illustrates how 90 minutes may not be adequate.

There’s already been coverage of how rapid DNA can be, and is being, used to identify victims of the Surfside building collapse. NPR ran an article on this, and WFLA aired a news report.

To date I have not found a public source that lists how many rapid DNA machines are being used in the investigation, but let’s do a little math and see how many rapid DNA instruments could possibly be required.

Assume a conservative two hours is required to fully analyze each DNA sample and determine the possible identity of a deceased victim. Further assume that because of the importance of this case, the DNA instruments are being operated 24 hours a day, 7 days a week. No going home at 5:00 pm in this case, which is receiving international attention.

Now let’s look at the numbers. As of 2:00 pm Eastern Daylight Time today, 20 deaths are confirmed, and 128 people are still unaccounted for.

What happens if there is a sudden horrific discovery of 100 deceased? How long would it take to identify all of them?

If 3 rapid DNA instruments are available, and each is processing 12 DNA samples in a 24 hour day, then it would take about three days to run all the samples through the DNA instruments.

Three very long days for the families of the potential victims who are waiting for news.

So the authorities may need to move to plan B.

The Indian River County Sheriff’s Office has been notified it might be asked to respond with the agency’s rapid DNA test machines to the deadly condominium collapse in Surfside, Sheriff Eric Flowers said….

“They put our folks on standby last weekend to respond if theirs got overwhelmed,” Flowers said. “At this point, they’ve not called for that, but our folks are ready and our machines are ready that if they call us we will respond to assist in DNA identification.”

Yes, in this case you can throw more machines at a problem to solve it, provided that you have the proper personnel to support them. Luckily, the rapid DNA instruments themselves do not need a forensic background to operate them, since they are designed to operate in an automated fashion. However, if rapid DNA analysis has an inconclusive result, then additional traditional DNA analysis will have to be performed which will require forensic expertise. (That, however, is outside of the scope of this post.)

By Zephyris – Own work, CC BY-SA 3.0, https://commons.wikimedia.org/w/index.php?curid=15027555

So where do we stand after Surfside?

Previous rapid DNA identification efforts have just involved one person or less than a dozen people. But this case, in which potentially over 100 people may need to be identified, is truly pushing the limits of the technology.

(Come to think of it, it’s similar to how video analytic analysis was pushed to the limits by the Boston Marathon bombings. But I digress.)

And sadly, there have already been instances in which that many people, or more people, needed to be identified. Imagine, for example, the crash of a large airplane. Or worse still, the crash of two large airplanes into a skyscraper.

And now this 90 minute response time suddenly doesn’t seem so fast any more.

Is your home your castle when you use consumer doorbell facial recognition?

(Part of the biometric product marketing expert series)

For purposes of this post, I will define three entities that can employ facial recognition:

  • Public organizations such as governments.
  • Private organizations such as businesses.
  • Individuals.

Some people are very concerned about facial recognition use by the first two categories of entities.

But what about the third category, individuals?

Can individuals assert a Constitutional right to use facial recognition in their own homes? And what if said individuals live in Peoria?

Concerns about ANY use of facial recognition

Let’s start with an ACLU article from 2018 regarding “Amazon’s Disturbing Plan to Add Face Surveillance to Your Front Door.”

Let me go out on a limb and guess that the ACLU opposes the practice.

The article was prompted by an Amazon 2018 patent application which involved both its Rekognition facial recognition service and its Ring cameras.

One of the figures in Amazon’s patent application, courtesy the ACLU. https://www.aclunc.org/docs/Amazon_Patent.pdf

While the main thrust of the ACLU article concerns acquisition of front door face surveillance (and other biometric) information by the government, it also briefly addresses the entity that is initially performing the face surveillance: namely, the individual.

Likewise, homeowners can also add photos of “suspicious” people into the system and then the doorbell’s facial recognition program will scan anyone passing their home.

I should note in passing that ACLU author Jacob Snow is describing a “deny list,” which flags people who should NOT be granted access such as that pesky solar power salesperson. In most cases, consumer products tout the use of an “allow list,” which flags people who SHOULD be granted access such as family members.

Regardless of whether you’re discussing a deny list or an allow list, the thrust of the ACLU article isn’t that governments shouldn’t use facial recognition. The thrust of the article is that facial recognition shouldn’t be used at all.

The ACLU and other civil rights groups have repeatedly warned that face surveillance poses an unprecedented threat to civil liberties and civil rights that must be stopped before it becomes widespread.

Again, not face surveillance by governments, but face surveillance period. People should not have the, um, “civil liberties” to use the technology.

But how does the tech world approach this?

The reason that I cited that particular ACLU article was that it was subsequently referenced in a CNET article from May 2021. This article bore the title “The best facial recognition security cameras of 2021.”

Let me go out on a limb and guess that CNET supports the practice.

The last part of author Megan Wollerton’s article delves into some of the issues regarding facial recognition use, including those raised by the ACLU. But the bulk of the article talks about really cool tech.

As I stated above, Wollerton notes that the intended use case for home facial recognition security systems involves the creation of an “allow list”:

Some home security cameras have facial recognition, an advanced option that lets you make a database of people who visit your house regularly. Then, when the camera sees a face, it determines whether or not it belongs to someone in your list of known faces. If the recognition system does not know who is at the door, it can alert you to an unknown person on your property.

Obviously you could repurpose such a system for anything you want, provided that you can obtain a clear picture of the face of the pesky social power salesperson.

Before posting her reviews of various security systems, and after a brief mention (expanded later in the article) about possible governmental misuse of facial recognition, Wollerton redirects the conversation.

But let’s step back a bit to the consumer realm. Your home is your castle, and the option of having surveillance cameras with facial recognition software is still compelling for those who want to be on the cutting edge of smart home innovation.

“Your home is your castle” may be a distinctly American concept, but it certainly applies here as organizations such as, um, the ACLU defend a person’s right against unreasonable actions by governments.

Obviously, there are limits to ANY Constitutional right. I cannot exercise my Fourth Amendment right to be secure in my house, couple that with my First Amendment right to freely exercise my religion, and conclude that I have the unrestricted right to perform ritual child sacrifices in my home. (Although I guess if I have a home theater and only my family members are present, I can probably yell “Fire!” all I want.)

So perhaps I could mount an argument that I can use facial recognition at my house any time I want, if the government agrees that this right is “reasonable.”

But it turns out that other people are involved.

You knew I was going to mention Illinois in this post

OK, it’s BIPA time.

As I previously explained in a January 2021 post about the Kami Doorbell Camera, “BIPA” is Illinois’ Biometric Information Privacy Act. This act imposes constraints on a private entity’s use of biometrics. (Governments are excluded in Illinois BIPA.) And here’s how BIPA defines the term “private entity”:

“Private entity” means any individual, partnership, corporation, limited liability company, association, or other group, however organized. A private entity does not include a State or local government agency. A private entity does not include any court of Illinois, a clerk of the court, or a judge or justice thereof.

Did you see the term “individual” in that definition?

So BIPA not only affects company use of biometrics, such as use of biometrics by Google or by a theme park or by a fitness center. It also affects an individual such as Harry or Harriet Homeowner’s use of biometrics.

As I previously noted, Google does not sell its Nest Cam “familiar face alert” feature in Illinois. But I guess it’s possible (via location spoofing if necessary) for someone to buy Nest Cam familiar face alerts in Indiana, and then sneak the feature across the border and implement it in the Land of Lincoln. But while this may (or may not) get Google off the hook, the individual is in a heap of trouble (should a trial lawyer decide to sue the individual).

Let’s face it. The average user of Nest Cam’s familiar face alerts, or the Kami Doorbell Camera, or any other home security camera with facial recognition (note that Amazon currently is not using facial recognition in its consumer products), is probably NOT complying with BIPA.

A private entity in possession of biometric identifiers or biometric information must develop a written policy, made available to the public, establishing a retention schedule and guidelines for permanently destroying biometric identifiers and biometric information when the initial purpose for collecting or obtaining such identifiers or information has been satisfied or within 3 years of the individual’s last interaction with the private entity, whichever occurs first.

I mean it’s hard enough for Harry and Harriet to get their teenage son to acknowledge receipt of the Homeowner family’s written policy for the use of the family doorbell camera. And you can forget about getting the pesky solar power salesperson to acknowledge receipt.

So from a legal perspective, it appears that any individual homeowner who installs a facial recognition security system can be hauled into civil court under BIPA.

But will these court cases be filed from a practical perspective?

Probably not.

When a social media company violates BIPA, the violation conceivably affects millions of individuals and can result in millions or billions of dollars in civil damages.

When the pesky solar power salesperson discovers that Harry and Harriet Homeowner, the damages would be limited to $1,000 or $5,000 plus relevant legal fees.

It’s not worth pursuing, any more than it’s worth pursuing the Illinois driver who is speeding down the expressway at 66 miles per hour.

What is an “antimicrobial” contact fingerprint reader? And what is it NOT?

(Part of the biometric product marketing expert series)

In the COVID and (soon) post-COVID area, people don’t want to touch things. That impacts how identity products are marketed, including biometric readers.

Why contactless biometrics are “better” than contact biometrics

In the biometric world, this reluctance to touch things has served to promote CONTACTLESS biometric technologies, such as facial recognition, other other technologies. The loser in this has been fingerprint-based technologies, as several facial and iris vendors have made the claim that face/iris biometrics are contactless, while fingerprint biometrics are NOT contactless.

Well, my friends at my former employer IDEMIA might take issue with that claim, since you literally do NOT touch the fingerprint reader in IDEMIA’s MorphoWave product. IDEMIA does not (to my knowledge) make any medical claims about MorphoWave, but the company does emphasize that its contactless fingerprint reader allows for fast capture of four-finger slaps.

To protect their premises, organizations need access control solutions that are efficient, fast, and convenient. A contactless fingerprint scanner provides an optimum answer high throughput workplaces. IDEMIA’s MorphoWave contactless fingerprint solution scans and verifies 4 fingerprints in less than 1 second, through a fully touchless hand wave gesture. Thanks to the simplicity of this gesture, the throughput can reach up to 50 people per minute.

An antimicrobial contact fingerprint reader?

But what if there were a CONTACT solution that allowed you to capture prints with a reduced fear of “bad things”?

That’s what Integrated Biometrics appears to be claiming.

Integrated Biometrics (IB), the world leader in mobile, FBI-certified biometric fingerprint scanners, and NBD Nanotechnologies (NBD Nano), the surface coating experts, today announced the inclusion of NBD’s RepelFlex MBED transparent coating on IB’s entire line of fingerprint scanners.

An ultra-thin, transparent coating, RepelFlex MBED is designed to provide outstanding antimicrobial, anti-scratch, and anti-stain protection to devices. Long-lasting and multi-functional, RepelFlex MBED is ideal for surfaces that must stand up to high throughput and harsh conditions without compromising accuracy.

So what exactly does “antimicrobial” mean?

cluster of Escherichia coli bacteria magnified 10,000 times. By Photo by Eric Erbe, digital colorization by Christopher Pooley, both of USDA, ARS, EMU. – This image was released by the Agricultural Research Service, the research agency of the United States Department of Agriculture, with the ID K11077-1 (next)., Public Domain, https://commons.wikimedia.org/w/index.php?curid=958857

Let’s see how NBD Nano describes it.

Preventing the presence and growth of microbials on surfaces is becoming increasingly important. Antimicrobial performance is especially critical on surfaces that are accessible to the public in order to prevent the spread of stain and odor causing bacteria and microbes.

And if you drill further down in NBD Nano’s website, you find this information in a technical data sheet (PDF).

Antimicrobial Performance: Japanese Industrial Standard (JIS) Z 2801 – PASS*
*as tested by Microchem Laboratory, Round Rock, TX

Now since I’m not up to date on my Japanese Industrial Standards, I had to rely on the good folks at the aforementioned Microchem Laboratory to explain what the standard actually means.

The JIS Z 2801 method tests the ability of plastics, metals, ceramics and other antimicrobial surfaces to inhibit the growth of microorganisms or kill them. The procedure is very sensitive to antimicrobial activity and has a number of real world applications anywhere from the hospital/clinical environment to a household consumer company concerned with the ability of a material they have to allow bacterial growth.

The JIS Z 2801 method is the most commonly chosen test and has become the industry standard for antimicrobial hard surface performance in the United States.

It may be antimicrobial, but what about preventing the “C” word?

Now you may have noticed that Microchem Laboratory, NBD Nano, and Integrated Biometrics did not make any medical claims regarding their products. None of them, for example, used the “C” word in any of their materials.

There’s a very, very good reason for that.

If any of these product providers were to make specific MEDICAL claims, then any sales in the United States would come under the purview of the U.S. Food and Drug Administration.

This is something that temperature scanner manufacturers learned the hard way.

Digression: if fever scanners are fever scanners, does that mean they are fever scanners?

Remember “fever scanners”? Those devices that were (and in some cases still are) pointed at your forehead as you enter a building or another secure area? I won’t get into the issues with these devices (what happens when the scanner is placed next to a building’s front entrance on a hot day?), but I will look at some of the claims about those scanners.

About a year ago, John Honovich of IPVM began asking some uncomfortable questions about the marketing of those devices, especially after the FDA clarified what thermal imaging systems could and could not do.

When used correctly, thermal imaging systems generally have been shown to accurately measure someone’s surface skin temperature without being physically close to the person being evaluated….

Thermal imaging systems have not been shown to be accurate when used to take the temperature of multiple people at the same time. The accuracy of these systems depends on careful set-up and operation, as well as proper preparation of the person being evaluated….

Room temperature should be 68-76 °F (20-24 °C) and relative humidity 10-50 percent….

The person handling the system should make sure the person being evaluated…(h)as waited at least 15 minutes in the measurement room or 30 minutes after exercising, strenuous physical activity, bathing, or using hot or cold compresses on the face.

Let’s stop right there. For any of you who have undergone a temperature scan in the last year: how many of you have waited in a measurement room for at least 15 minutes BEFORE your temperature was taken?

Last summer I had a dentist appointment. My dentist is in Ontario, California, where the summers can get kind of hot. The protocol at this dentist’s office was to have you call the office from your car when you arrived in the parking lot, then wait for someone from the office to come outside and take your temperature before you could enter the building.

I was no dummy. I left my car and its air conditioner running while waiting for my temperature to be taken. Otherwise, who knows what my temperature reading would have been? (I also chose NOT to walk to the dentist’s office that day for the same reason.)

Back to John Honovich. He had read the FDA advice on the medical nature of thermal imaging systems, and then noted that some of the manufacturers of said systems were sort of getting around this by stating that their devices were not medical devices.

Even though the manufacturers still referred to them as “fever cameras.”

For example, one vendor (who has since changed its advertising) declared at the time that “thermal temperature-monitoring technology assists in reducing the spread of viral diseases,” even though that vendor’s device “is not a medical device and is not designed or intended for diagnosis, prevention, or treatment of any disease or condition.”

Fever scanners, testosterone supplements…and fingerprint readers

Yes, that language is similar to the language used by providers of natural supplements that, according to anecdotal evidence, work wonders. The FDA really polices this stuff.

So you really don’t want to make medical claims about ANY product unless you can back them up with the FDA. You can say that a particular product passed a particular antimicrobial standard…but you’d better not say anything else.

In fact, Integrated Biometrics only mentions the “antimicrobial” claim in passing, but spends some time discussing other benefits of the NBD Nano technology:

The inclusion of RepelFlex MBED coatings enable IB’s scanners to deliver an even higher level of performance. Surfaces are tougher and more difficult to scratch or stain, increasing their longevity while maintaining print quality even when regular cleaning is not possible due to conditions or times of heavy use.

So the treated Integrated Biometrics products are tough…like those famous 1970s crime fighters Kojak, Columbo, and Danno and the other people from Five-O. (Not that Sherlock and Watson were slouches.)

Book ’em, Danno! By CBS Television – eBay item photo front photo back, Public Domain, https://commons.wikimedia.org/w/index.php?curid=19674714

When biometric readers are “magic” (it’s a small face after all)

(Part of the biometric product marketing expert series)

The news coming across the wire is that Disney’s Magic Kingdom in Florida is testing facial recognition. (H/T International Biometrics + Identity Association.)

“At Walt Disney World Resort, we’re always looking for innovative and convenient ways to improve our guests’ experience—especially as we navigate the impact of COVID-19. With the future in mind and the shift in focus to more touchless experiences, we’re conducting a limited 30-day test using facial recognition technology.”

If the test is successful and facial recognition is implemented, it would be a replacement for (touch) fingerprint technology, which the Disney parks suspended last July for health reasons. (Although touchless fingerprint options are available.)

Disney’s biometric history extends back to 2006, when it used hand geometry.

The five authentication factors

(Part of the biometric product marketing expert series)

I thought I had blogged about the five factors of authentication, either here or at jebredcal, but I guess I haven’t explicitly written a post just on this topic. (You’d expect an identity content marketing expert to do that.)

And I’m not going to do that today either (at least in any detail), because The Cybersecurity Man already did a good job at that (as have many others).

However, for those like me who get a little befuddled after authentication factor 3, I’m going to list all five authentication factors.

  • Something You Know. Think “password.” And no, passwords aren’t dead. But the use of your mother’s maiden name as an authentication factor is hopefully decreasing.
  • Something You Have. I’ve spent much of the last ten years working with this factor, primarily in the form of driver’s licenses. (Yes, MorphoTrak proposed driver’s license systems. No, they eventually stopped doing so. But obviously IDEMIA North America, the former MorphoTrust, has implemented a number of driver’s license systems.) But there are other examples, such as hardware or software tokens.
  • Something You Are. I’ve spent…a long time with this factor, since this is the factor that includes biometrics modalities (finger, face, iris, DNA, voice, vein, etc.). It also includes behavioral biometrics, provided that they are truly behavioral and relatively static.
  • Something You Do. The Cybersecurity Man chose to explain this in a non-behavioral fashion, such as using swiping patterns to unlock a device. This is different from something such as gait recognition, which supposedly remains constant and is thus classified as behavioral biometrics.
  • Somewhere You Are. This is an emerging factor, as smartphones become more and more prevalent and locations are therefore easier to capture. Even then, however, precision isn’t always as good as we want it to be. For example, when you and a few hundred of your closest friends have illegally entered the U.S. Capitol, you can’t use geolocation alone to determine who exactly is in Speaker Pelosi’s office.

Now when these factors are combined via multi-factor authentication, there is a higher probability that the person is who they claim to be. If I enter the password “12345” AND I provide a picture of my driver’s license AND I provide a picture of my face AND I demonstrate the secret finger move AND I am within 25 feet of my documented address, then there is a pretty good likelihood that I am me, despite the fact that I used an extremely poor password.

I don’t know if anyone has come up with a sixth authentication factor yet. But I’m sure someone will if it hasn’t already been done. And then I’ll update to update this post in the same way I’ve been updating my Bredemarket 2021 goals.

Identity assurance levels (IALs) and digital identity

(Part of the biometric product marketing expert series)

There is more and more talk about digital identity, especially as COVID-19 accelerates the move to contactless and remote transactions. However, there are many types of digital identity, ranging from a Colorado, Louisiana, or Oklahoma digital driver’s license to your Facebook, Google, or Microsoft ID to the online equivalent of my old Radio Shack Battery Club card.

All of these different types of digital identities suggest that some identities are more rigorous than others. For example, I’ve lost track of how many digital identities I’ve created with Google over the years, but if California ever gets around to implementing a digital driver’s license, I’ll only have one of them. (And I won’t be able to get another license in Nevada.)

In this particular case, the government IS here to help.

The U.S. National Institute of Standards and Technology has defined “identity assurance levels” (IALs) that can be used when dealing with digital identities. It’s helpful to review how NIST has defined the IALs. (I’ll define the other acronyms as we go along.)

Assurance in a subscriber’s identity is described using one of three IALs:

IAL1: There is no requirement to link the applicant to a specific real-life identity. Any attributes provided in conjunction with the subject’s activities are self-asserted or should be treated as self-asserted (including attributes a [Credential Service Provider] CSP asserts to an [Relying Party] RP). Self-asserted attributes are neither validated nor verified.

IAL2: Evidence supports the real-world existence of the claimed identity and verifies that the applicant is appropriately associated with this real-world identity. IAL2 introduces the need for either remote or physically-present identity proofing. Attributes could be asserted by CSPs to RPs in support of pseudonymous identity with verified attributes. A CSP that supports IAL2 can support IAL1 transactions if the user consents.

IAL3: Physical presence is required for identity proofing. Identifying attributes must be verified by an authorized and trained CSP representative. As with IAL2, attributes could be asserted by CSPs to RPs in support of pseudonymous identity with verified attributes. A CSP that supports IAL3 can support IAL1 and IAL2 identity attributes if the user consents.

Interestingly, the standard assumes that pseudonymous identity can be proofed…but this requires that SOMEONE know the actual identity.

And in practice, the “physical presence” requirement of IAL3 can be met by either being “in-person,” or in a “supervised remote” case. (This is needed to make sure that I don’t register with someone else’s face, for example.)

So when considering the robustness of any digital identity scheme, it’s necessary to ascertain whether the digital identity can reliably be mapped to a real life identity. This doesn’t necessarily mean that IAL1 is bad per se; in some cases, such as my old Radio Shack Battery Club example, a robust mapping to a real life identity is NOT necessary.

But in other cases, such as a need to gain entrance to a nuclear power plant, that reliable mapping IS essential.

Someone once said that I look like this guy. By US Embassy London – https://www.flickr.com/photos/usembassylondon/27595569992/, Public Domain, https://commons.wikimedia.org/w/index.php?curid=49663171