Checking the purported identity against private databases, such as credit records.
Checking the person’s driver’s license or other government document to ensure it’s real and not a fake.
Checking the purported identity against government databases, such as driver’s license databases. (What if the person presents a real driver’s license, but that license was subsequently revoked?)
Perform a “who you are” biometric test against the purported identity.
If you conduct all four tests, then you have used multiple factors of authentication to confirm that the person is who they say they are. If the identity is synthetic, chances are the purported person will fail at least one of these tests.
Do you fight synthetic identity fraud?
If you fight synthetic identity fraud, you should let people know about your solution.
AAL1 (some confidence). AAL1, in the words of NIST, “provides some assurance.” Single-factor authentication is OK, but multi-factor authentication can be used also. All sorts of authentication methods, including knowledge-based authentication, satisfy the requirements of AAL1. In short, AAL1 isn’t exactly a “nothingburger” as I characterized IAL1, but AAL1 doesn’t provide a ton of assurance.
AAL2 (high confidence). AAL2 increases the assurance by requiring “two distinct authentication factors,” not just one. There are specific requirements regarding the authentication factors you can use. And the security must conform to the “moderate” security level, such as the moderate security level in FedRAMP. So AAL2 is satisfactory for a lot of organizations…but not all of them.
AAL3 (very high confidence). AAL3 is the highest authenticator assurance level. It “is based on proof of possession of a key through a cryptographic protocol.” Of course, two distinct authentication factors are required, including “a hardware-based authenticator and an authenticator that provides verifier impersonation resistance — the same device MAY fulfill both these requirements.”
This is of course a very high overview, and there are a lot of…um…minutiae that go into each of these definitions. If you’re interested in that further detail, please read section 4 of NIST Special Publication 800-63B for yourself.
Which authenticator assurance level should you use?
NIST has provided a handy dandy AAL decision flowchart in section 6.2 of NIST Special Publication 800-63-3, similar to the IAL decision flowchart in section 6.1 that I reproduced earlier. If you go through the flowchart, you can decide whether you need AAL1, AAL2, or the very high AAL3.
One of the key questions is the question flagged as 2, “Are you making personal data accessible?” The answer to this question in the flowchart moves you between AAL2 (if personal data is made accessible) and AAL1 (if it isn’t).
So what?
Do the different authenticator assurance levels provide any true benefits, or are they just items in a government agency’s technical check-off list?
Perhaps the better question to ask is this: what happens if the WRONG person obtains access to the data?
Could the fraudster cause financial loss to a government agency?
Threaten personal safety?
Commit civil or criminal violations?
Or, most frightening to agency heads who could be fired at any time, could the fraudster damage an agency’s reputation?
If some or all of these are true, then a high authenticator assurance level is VERY beneficial.
The Prism Project’s home page at https://www.the-prism-project.com/, illustrating the Biometric Digital Identity Prism as of March 2024. From Acuity Market Intelligence and FindBiometrics.
With over 100 firms in the biometric industry, their offerings are going to naturally differ—even if all the firms are TRYING to copy each other and offer “me too” solutions.
I’ve worked for over a dozen biometric firms as an employee or independent contractor, and I’ve analyzed over 80 biometric firms in competitive intelligence exercises, so I’m well aware of the vast implementation differences between the biometric offerings.
Some of the implementation differences provoke vehement disagreements between biometric firms regarding which choice is correct. Yes, we FIGHT.
Let’s look at three (out of many) of these implementation differences and see how they affect YOUR company’s content marketing efforts—whether you’re engaging in identity blog post writing, or some other content marketing activity.
The three biometric implementation choices
Firms that develop biometric solutions make (or should make) the following choices when implementing their solutions.
Presentation attack detection. Assuming the solution incorporates presentation attack detection (liveness detection), or a way of detecting whether the presented biometric is real or a spoof, the firm must decide whether to use active or passive liveness detection.
Age assurance. When choosing age assurance solutions that determine whether a person is old enough to access a product or service, the firm must decide whether or not age estimation is acceptable.
Biometric modality. Finally, the firm must choose which biometric modalities to support. While there are a number of modality wars involving all the biometric modalities, this post is going to limit itself to the question of whether or not voice biometrics are acceptable.
I will address each of these questions in turn, highlighting the pros and cons of each implementation choice. After that, we’ll see how this affects your firm’s content marketing.
(I)nstead of capturing a true biometric from a person, the biometric sensor is fooled into capturing a fake biometric: an artificial finger, a face with a mask on it, or a face on a video screen (rather than a face of a live person).
This tomfoolery is called a “presentation attack” (becuase you’re attacking security with a fake presentation).
And an organization called iBeta is one of the testing facilities authorized to test in accordance with the standard and to determine whether a biometric reader can detect the “liveness” of a biometric sample.
(Friends, I’m not going to get into passive liveness and active liveness. That’s best saved for another day.)
Now I could cite a firm using active liveness detection to say why it’s great, or I could cite a firm using passive liveness detection to say why it’s great. But perhaps the most balanced assessment comes from facia, which offers both types of liveness detection. How does facia define the two types of liveness detection?
Active liveness detection, as the name suggests, requires some sort of activity from the user. If a system is unable to detect liveness, it will ask the user to perform some specific actions such as nodding, blinking or any other facial movement. This allows the system to detect natural movements and separate it from a system trying to mimic a human being….
Passive liveness detection operates discreetly in the background, requiring no explicit action from the user. The system’s artificial intelligence continuously analyses facial movements, depth, texture, and other biometric indicators to detect an individual’s liveness.
Pros and cons
Briefly, the pros and cons of the two methods are as follows:
While active liveness detection offers robust protection, requires clear consent, and acts as a deterrent, it is hard to use, complex, and slow.
Passive liveness detection offers an enhanced user experience via ease of use and speed and is easier to integrate with other solutions, but it incorporates privacy concerns (passive liveness detection can be implemented without the user’s knowledge) and may not be used in high-risk situations.
So in truth the choice is up to each firm. I’ve worked with firms that used both liveness detection methods, and while I’ve spent most of my time with passive implementations, the active ones can work also.
A perfect wishy-washy statement that will get BOTH sides angry at me. (Except perhaps for companies like facia that use both.)
If you need to know a person’s age, you can ask them. Because people never lie.
Well, maybe they do. There are two better age assurance methods:
Age verification, where you obtain a person’s government-issued identity document with a confirmed birthdate, confirm that the identity document truly belongs to the person, and then simply check the date of birth on the identity document and determine whether the person is old enough to access the product or service.
Age estimation, where you don’t use a government-issued identity document and instead examine the face and estimate the person’s age.
I changed my mind on age estimation
I’ve gone back and forth on this. As I previously mentioned, my employment history includes time with a firm produces driver’s licenses for the majority of U.S. states. And back when that firm was providing my paycheck, I was financially incentivized to champion age verification based upon the driver’s licenses that my company (or occasionally some inferior company) produced.
But as age assurance applications moved into other areas such as social media use, a problem occurred since 13 year olds usually don’t have government IDs. A few of them may have passports or other government IDs, but none of them have driver’s licenses.
But does age estimation work? I’m not sure if ANYONE has posted a non-biased view, so I’ll try to do so myself.
The pros of age estimation include its applicability to all ages including young people, its protection of privacy since it requires no information about the individual identity, and its ease of use since you don’t have to dig for your physical driver’s license or your mobile driver’s license—your face is already there.
The huge con of age estimation is that it is by definition an estimate. If I show a bartender my driver’s license before buying a beer, they will know whether I am 20 years and 364 days old and ineligible to purchase alcohol, or whether I am 21 years and 0 days old and eligible. Estimates aren’t that precise.
Fingerprints, palm prints, faces, irises, and everything up to gait. (And behavioral biometrics.) There are a lot of biometric modalities out there, and one that has been around for years is the voice biometric.
I’ve discussed this topic before, and the partial title of the post (“We’ll Survive Voice Spoofing”) gives away how I feel about the matter, but I’ll present both sides of the issue.
No one can deny that voice spoofing exists and is effective, but many of the examples cited by the popular press are cases in which a HUMAN (rather than an ALGORITHM) was fooled by a deepfake voice. But voice recognition software can also be fooled.
Take a study from the University of Waterloo, summarized here, that proclaims: “Computer scientists at the University of Waterloo have discovered a method of attack that can successfully bypass voice authentication security systems with up to a 99% success rate after only six tries.”
If you re-read that sentence, you will notice that it includes the words “up to.” Those words are significant if you actually read the article.
In a recent test against Amazon Connect’s voice authentication system, they achieved a 10 per cent success rate in one four-second attack, with this rate rising to over 40 per cent in less than thirty seconds. With some of the less sophisticated voice authentication systems they targeted, they achieved a 99 per cent success rate after six attempts.
Other voice spoofing studies
Similar to Gender Shades, the University of Waterloo study does not appear to have tested hundreds of voice recognition algorithms. But there are other studies.
The 2021 NIST Speaker Recognition Evaluation (PDF here) tested results from 15 teams, but this test was not specific to spoofing.
A test that was specific to spoofing was the ASVspoof 2021 test with 54 team participants, but the ASVspoof 2021 results are only accessible in abstract form, with no detailed results.
Another test, this one with results, is the SASV2022 challenge, with 23 valid submissions. Here are the top 10 performers and their error rates.
You’ll note that the top performers don’t have error rates anywhere near the University of Waterloo’s 99 percent.
So some firms will argue that voice recognition can be spoofed and thus cannot be trusted, while other firms will argue that the best voice recognition algorithms are rarely fooled.
What does this mean for your company?
Obviously, different firms are going to respond to the three questions above in different ways.
For example, a firm that offers face biometrics but not voice biometrics will convey how voice is not a secure modality due to the ease of spoofing. “Do you want to lose tens of millions of dollars?”
A firm that offers voice biometrics but not face biometrics will emphasize its spoof detection capabilities (and cast shade on face spoofing). “We tested our algorithm against that voice fake that was in the news, and we detected the voice as a deepfake!”
There is no universal truth here, and the message your firm conveys depends upon your firm’s unique characteristics.
And those characteristics can change.
Once when I was working for a client, this firm had made a particular choice with one of these three questions. Therefore, when I was writing for the client, I wrote in a way that argued the client’s position.
After I stopped working for this particular client, the client’s position changed and the firm adopted the opposite view of the question.
Therefore I had to message the client and say, “Hey, remember that piece I wrote for you that said this? Well, you’d better edit it, now that you’ve changed your mind on the question…”
Bear this in mind as you create your blog, white paper, case study, or other identity/biometric content, or have someone like the biometric content marketing expert Bredemarket work with you to create your content. There are people who sincerely hold the opposite belief of your firm…but your firm needs to argue that those people are, um, misinformed.
I’m going to describe one example of how Bredemarket has helped its customers, based upon one of my client projects from several years ago.
Stupid Word Tricks. Tell your brother, your sister and your mama too. See below.
I’ve told this story before, but I wanted to take a fresh look at the problem the firm had, and the solution Bredemarket provided. I’m not identifying the firm, but perhaps YOUR firm has a similar problem that I can solve for you. And your firm is the one that matters.
The problem
This happened several years ago, but was one of Bredemarket’s first successes.
The firm that asked for my help is one that focuses on one particular biometric modality, and provides a high-end solution for biometric identification.
In addition, the firm’s solution has multiple applications, crime solving and disaster victim identification being two of them.
The firm needed a way to perform initial prospect outreach via budgetary quotations, targeted to the application that mattered to the prospect. A simple proposal problem to be solved…or so it seemed.
Why the obvious proposal solution didn’t work
I had encountered similar problems while employed at Printrak and MorphoTrak and while consulting here at Bredemarket, so the solution was painfully obvious.
Qvidian, one proposal automation software package that I have used. But there are a LOT of proposal automation software packages out there, including some new ones that incorporate artificial intelligence. From https://uplandsoftware.com/qvidian/.
Have your proposal writers create relevant material in their proposal automation software that could target each of the audiences.
So when your salesperson wants to approach a medical examiner involved in disaster victim identification, the proposal writer could just run the proposal automation software, create the targeted budgetary quotation, populate it with the prospect’s contact information, and give the completed quotation to the salesperson.
Unfortuntely for the firm, the painfully obvious solution was truly painful, for two reasons:
This firm had no proposal automation software. Well, maybe some other division of the firm had such software, but this division didn’t have access to it. So the whole idea of adding proposal text to an existing software solution, and programming the solution to generate the appropriate budgetary quotation, wasn’t going to fly.
In addition, this firm had no proposal writers. The salespeople were doing this on their own. The only proposal writer they had was the contractor from Bredemarket. And they weren’t going to want to pay for me to generate every budgetary quotation they needed.
In this case, the firm needed a way for the salespeople to generate the necessary budgetary quotations as easily as possible, WITHOUT relying on proposal automation software or proposal writers.
Bredemarket’s solution
To solve the firm’s problem, I resorted to Stupid Word Tricks.
I created two similar budgetary quotation templates: one for crime solving, and one for disaster victim identification. (Actually I created more than two.) That way the salesperson could simply choose the budgetary quotation they wanted.
The letters were similar in format, but had little tweaks depending upon the audience.
Using document properties to create easy-to-use budgetary quotations.
The Stupid Word Tricks came into play when I used Word document property features to allow the salesperson to enter the specific information for each prospect, which then rippled throughout the document, providing a customized budgetary quotation to the prospect.
The result
The firms’ salespeople used Bredemarket’s templates to generate initial outreach budgetary quotations to their clients.
And the salespeople were happy.
I’ve used this testimonial quote before, but it doesn’t hurt to use it again.
“I just wanted to truly say thank you for putting these templates together. I worked on this…last week and it was extremely simple to use and I thought really provided a professional advantage and tool to give the customer….TRULY THANK YOU!”
Comment from one of the client’s employees who used the standard proposal text
While I actively consulted for the firm I maintained the templates, updating as needed as the firm achieved additional certifications.
Why am I telling this story again?
I just want to remind people that Bredemarket doesn’t just write posts, articles, and other collateral. I can also create collateral such as these proposal templates that you can re-use.
The identity/biometric company never formally learned how its references to renamed companies and non-existent companies were repelling those very companies…and the prospects who knew the website information was inaccurate.
It could have learned…if it had met with me. But it chose not to do so.
NOTE TO SELF: INSERT STRONG FEAR UNCERTAINTY AND DOUBT PARAGRAPH HERE. TAKE OUT THESE TWO SENTENCES BEFORE POSTING THE FINAL VERSION!!!
(By the way…while the identity/biometric company never received this information formally, it did receive it informally…because such information is presumably critically important to the company.)
How many other companies are in the same situation, with:
My mini-survey shows that of the 40+ identity firms with blogs, about one-third of them HAVEN’T SAID A SINGLE THING to their prospects and customers in the last two months.
Is there a 29-year veteran of the identity industry, an identity content marketing expert who can help the companies fix these gaps?
The so-called experts say that a piece of content should only have one topic and one call to action. Well, it’s Sunday so hopefully the so-called experts are taking a break and will never see the paragraphs below.
This is my endorsement for Cultivated Cool. Its URL is https://cultivated.cool/, which I hope you can remember.
Cultivated Cool self-identifies as “(y)our weekly guide to the newest, coolest products you didn’t know you needed.” Concentrating on the direct-to-consumer (DTC or D2C) space, Cultivated Cool works with companies to “transform (their) email marketing from a chore into a revenue generator.” And to prove the effectiveness of email, it offers its own weekly email that highlights various eye-catching products. But not trendy ones:
Trends come and go but cool never goes out of style.
Bredemarket isn’t a prospect for Cultivated Cool’s first service—my written content creation is not continuously cool. (Although it’s definitely not trendy either). But I am a consumer of Cultivated Cool’s weekly emails, and you should subscribe to its weekly emails also. Enter your email and click the “Subscribe” button on Cultivated Cool’s webpage.
And Cultivated Cool’s weekly emails lead me to the point of this post.
The day that Stella sculpted air
Today’s weekly newsletter issue from Cultivated Cool is entitled “Dig It.” But this has nothing to do with the Beatles or with Abba. Instead it has to do with gardening, and the issue tells the story of Stella, in five parts. The first part is entitled “Snip it in the Bud,” and begins as follows.
Stella felt a shiver go down her spine the first time the pruner blades closed. She wasn’t just cutting branches; she was sculpting air.
The pruner blades featured in Cultivated Cool are sold by Niwaki, an English company that offers Japanese-inspired products. As I type this, Niwaki offers 18 different types of secateurs (pruning shears), including large hand, small hand, right-handed, and left-handed varieties. You won’t get these at your dollar store; prices (excluding VAT) range from US$45.50 to US$280.50 (Tobisho Hiryu Secateurs).
But regardless of price, all the secateurs sold by Niwaki have one thing in common: an age restriction on purchases. Not that Niwaki truly enforces this restriction.
Please note: By law, we are not permitted to sell a knife or blade to any person under the age of 18. By placing an order for one of these items you are declaring that you are 18 years of age or over. These items must be used responsibly and appropriately.
I hope you’re sitting down as I reveal this to you: underage people can bypass the age assurance scheme on alcohol websites by inputting any year of birth that they wish. Just like anyone, even a small child, can make any declaration of age that they want, as long as their credit card is valid.
Now I have no idea whether Ofcom’s UK Online Safety Act consultations will eventually govern Niwaki’s sales of adult-controlled physical products. But if Niwaki finds itself under the UK Online Safety Act, or some other act in the United Kingdom or any country where Niwaki conducts business, then a simple assurance that the purchaser is old enough to buy “a knife or blade” will not be sufficient.
Niwaki’s website would then need to adopt some form of age assurance for purchasers, either by using a government-issued identification document (age verification) or examining the face to algorithmically surmise the customer’s age (age estimation).
Age verification. For example, the purchaser would need to provide their government-issued identity document so that the seller can verify the purchaser’s age. Ideally, this would be coupled with live face capture so that the seller can compare the live face to the face on the ID, ensuring that a kid didn’t steal mommy’s or daddy’s driver’s license (licence) or passport.
Age estimation. For example, the purchaser would need to provide their live face so that the seller can estimate the purchaser’s age. In this case (and in the age verification case if a live face is captured), the seller would need to use liveness dectection to ensure that the face is truly a live face and is not a presentation attack or other deepfake.
And then the seller would need to explain why it was doing all of this.
How can a company explain its age assurance solution in a way that its prospects will understand…and how can the company reassure its prospects that its age assurance method protects their privacy?
Companies other than identity companies must explain their identity solutions
Which brings me to the TRUE call to action in this post. (Sorry Mark and Lindsey. You’re still cool.)
I’ve stated ad nauseum that identity companies need to explain their identity solutions: why they developed them, how they work, what they do, and several other things.
In the same way, firms that incorporate solutions from identity companies got some splainin’ to do.
This applies to a financial institution that requires customers to use an identity verification solution before opening an account, just like it applies to an online gardening implement website that uses an age assurance method to check the age of pruning shear purchasers.
So how can such companies explain their identity and biometrics features in a way their end customers can understand?
The Georgia bill explicitly mentions Identity Assurance Level 2.
Under the bill, the age verification methods would have to meet or exceed the National Institute of Standards and Technology’s Identity Assurance Level 2 standard.
So if you think you can use Login.gov to access a porn website, think again.
There’s also a mention of mobile driver’s licenses, albeit without a corresponding mention of the ISO/IEC 18013-5:2021.
Specifically mentioned in the bill text is “digitized identification cards,” described as “a data file available on a mobile device with connectivity to the internet that contains all of the data elements visible on the face and back of a driver’s license or identification card.”
So digital identity is becoming more important for online access, as long as certain standards are met.
I won’t give away all the information about the Fischer Identity-AWS effort at Baylor—you have to opt in to access a gated case study to obtain that—but I will say that the case study claims a 12-week implementation of an IAM system that stores “several hundred thousand identities.”
I assume the alumni at Baylor are a generous segment of the university community.
Um, thanks but no thanks. When the first sentence doesn’t even bother to define the acronym “B2B,” you know the content isn’t useful to explain the topic “what is B2B writing.”
Before I explain what B2B writing is, maybe I’d better explain what “B2B” is. And two related acronyms.
B2B stands for business to business. Bredemarket, for example, is a business that sells to other businesses. In my case, marketing and writing services.
B2G stands for business to government. Kinda sorta like B2B, but government folks are a little different. For example, these folks mourned the death of Mike Causey. (I lived outside of Washington DC early in Causey’s career. He was a big deal.) A B2G company, for example, could sell driver’s license products and services to state motor vehicle agencies.
B2C stands for business to consumer. Many businesses create products and services that are intended for consumers and marketed directly to them, not to intermediate businesses. Promotion of a fast food sandwich is an example of a B2C marketing effort.
I included the “B2G” acronym because most of my years in identity and biometrics were devoted to local, state, federal, and international government sales. My B2G experience is much deeper than my B2B experience, and way deeper than my B2C expertise.
Let’s NOT make this complicated
I’m sure that Ubersuggest could spin out a whole bunch of long-winded paragraphs that explain the critical differences between the three marketing efforts above. But let’s keep it simple and limit ourselves to two truths and no lies.
TRUTH ONE: When you market B2B or B2G products or services, you have FEWER customers than when you market B2C products or services.
That’s pretty much it in terms of differences. I’ll give you an example.
If Bredemarket promoted its marketing and writing services to all of the identity verification companies, I would target less than 200 customers.
If IDEMIA or Thales or GET Group or CBN promoted their driver’s license products and services to all of the state, provincial, and territorial motor vehicle agencies in the United States and Canada, they would target less than 100 customers.
If McDonald’s resurrects and promotes its McRib sandwich, it would target hundreds of millions of customers in the United States alone.
The sheer scale of B2C marketing vs. B2B/B2G marketing is tremendous and affects how the company markets its products and services.
But one thing is similar among all three types of writing.
TRUTH TWO: B2B writing, B2G writing, and B2C writing are all addressed to PEOPLE.
Well, until we program the bots to read stuff for us.
This is something we often forget. We think that we are addressing a blog post or a proposal to an impersonal “company.” Um, who works in companies? People.
(Again, until we program the bots.)
Whether you’re marketing a business blog post writing service, a government software system, or a pseudo rib sandwich, you’re pitching it to a person. A person with problems and needs that you can potentially solve.
So solve their needs.
Don’t make it complex.
But what IS B2B writing?
Let’s return to the original question. Sorry, I got off on a bit of a tangent. (But at least I didn’t trail off into musings about “the dynamic and competitive world.”)
When I write something for a business:
I must focus on that business and not myself (customer focus). The business doesn’t want to hear my talk about myself. The business wants to hear what I can do for it.
I must acknowledge the business’ needs and explain the benefits of my solution to meet the business needs. A feature list without any benefits is just a list of cool things; you still have to explain how the cool things will benefit the business by solving its problem.
My writing must address one, or more, different types of people who are hungry for my solution to their problem. (This is what Ubersuggest and others call a “target audience,” because I guess Ubersuggest aims lasers at the assembled anonymous crowd.)
The Digital Trust & Safety Partnership (DTSP) consists of “leading technology companies,” including Apple, Google, Meta (parent of Facebook, Instagram, and WhatsApp), Microsoft (and its LinkedIn subsidiary), TikTok, and others.
DTSP appreciates and shares Ofcom’s view that there is no one-size-fits-all approach to trust and safety and to protecting people online. We agree that size is not the only factor that should be considered, and our assessment methodology, the Safe Framework, uses a tailoring framework that combines objective measures of organizational size and scale for the product or service in scope of assessment, as well as risk factors.
We’ll get to the “Safe Framework” later. DTSP continues:
Overly prescriptive codes may have unintended effects: Although there is significant overlap between the content of the DTSP Best Practices Framework and the proposed Illegal Content Codes of Practice, the level of prescription in the codes, their status as a safe harbor, and the burden of documenting alternative approaches will discourage services from using other measures that might be more effective. Our framework allows companies to use whatever combination of practices most effectively fulfills their overarching commitments to product development, governance, enforcement, improvement, and transparency. This helps ensure that our practices can evolve in the face of new risks and new technologies.
But remember that the UK’s neighbors in the EU recently prescribed that USB-3 cables are the way to go. This not only forced DTSP member Apple to abandon the Lightning cable worldwide, but it affects Google and others because there will be no efforts to come up with better cables. Who wants to fight the bureaucratic battle with Brussels? Or alternatively we will have the advanced “world” versions of cables and the deprecated “EU” standards-compliant cables.
So forget Ofcom’s so-called overbearing approach and just adopt the Safe Framework. Big tech will take care of everything, including all those age assurance issues.
Incorporating each characteristic comes with trade-offs, and there is no one-size-fits-all solution. Highly accurate age assurance methods may depend on collection of new personal data such as facial imagery or government-issued ID. Some methods that may be economical may have the consequence of creating inequities among the user base. And each service and even feature may present a different risk profile for younger users; for example, features that are designed to facilitate users meeting in real life pose a very different set of risks than services that provide access to different types of content….
Instead of a single approach, we acknowledge that appropriate age assurance will vary among services, based on an assessment of the risks and benefits of a given context. A single service may also use different approaches for different aspects or features of the service, taking a multi-layered approach.
Bredemarket 