Andrew,
I am assuming you refer to lines 768/769. That being so, I would agree with you IF one was talking about an Approved CSP, i.e., the fact that it has undergone an assessment has established confidence that its service can be relied-upon, i.e. its outputs are ‘credible’.
However, I’d say that is wrong in the context of what it takes to be an identity-proofing service iaw 63A rev.4 since the ‘credible sources’ must surely be external to the service which is seeking conformity against the requirements of that standard ? Those ‘credible sources’ are what allows the CSP’s identity-proofing operations able to validate the evidence being offered by the Applicant.
And what would be the regulatory oversight? I don’t think the IAF would qualify as ‘regulatory’.
Do you have your tongue in your cheek? J
Richard G. WILSHER
CEO & Founder, Zygma Inc.
www.Zygma.biz
+1 714 797 9942
From: Andrew Hughes [mailto:andrewhughes3000@gmail.com]
Sent: Wednesday, September 18, 2024 16:33
To: Marc L. Aronson
Cc: Richard G. WILSHER (@Zygma Inc.); yehoshua@proof.com; wg-idassurance@kantarainitiative.org
Subject: [WG-IDAssurance] Re: Working on 63-4 comments; authoritative and credible sources
Reading 63A 2.4.2.4 about validation sources.
It occurs to me that a "credible source" is, in effect, a CSP that is subject to regulatory oversight. Am I wrong?
————————
Andrew Hughes CISM
m +1 250.888.9474
mailto:AndrewHughes3000@gmail.com AndrewHughes3000@gmail.com
On Wed, Sep 18, 2024 at 5:27 AM Marc L. Aronson via WG-IDAssurance wrote:
Is this what you are looking for: https://www.dhs.gov/real-id
So where does one go to retrieve the REAL-ID information
Marc Aronson
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From: Lorrayne Auld
Sent: Wednesday, September 18, 2024 06:36
To: 'Richard G. WILSHER (@Zygma Inc.)' ; yehoshua@proof.com; 'Jimmy Jung'
Cc: wg-idassurance@kantarainitiative.org
Subject: [WG-IDAssurance] Re: Working on 63-4 comments; authoritative and credible sources
So where does one go to retrieve the REAL-ID information as well as for those states AAMVA doesn’t have a connection agreement with those states? Perhaps AAMVA is more of an attribute service, or a trusted intermediary, going to each of the authoritative data sources (DMV) to obtain the data requested of the CSP.
From: Richard G. WILSHER (@Zygma Inc.)
Sent: Tuesday, September 17, 2024 2:14 PM
To: 'Lorrayne Auld' ; yehoshua@proof.com; 'Jimmy Jung'
Cc: wg-idassurance@kantarainitiative.org
Subject: RE: [WG-IDAssurance] Re: Working on 63-4 comments; authoritative and credible sources
Isn’t it authoritative to the extent that issuers allow it to access their data? It just isn’t authoritative across all 54 (55?) issuing sources.
But it isn’t authoritative about REAL-ID status, so caveat.
Richard G. WILSHER
CEO & Founder, Zygma Inc.
www.Zygma.biz https://link.edgepilot.com/s/fd5f0c55/wq7TYlZNLUaIuIdZco6reA?u=http://www.zy...
+1 714 797 9942
From: Lorrayne Auld [mailto:lorraynejs@gmail.com]
Sent: Tuesday, September 17, 2024 17:39
To: yehoshua@proof.com; 'Jimmy Jung'
Cc: wg-idassurance@kantarainitiative.org
Subject: [WG-IDAssurance] Re: Working on 63-4 comments; authoritative and credible sources
I just finished reviewing this section of 63A this morning so is fresh in my mind. I view AAMVA as a credible source for physical driver's licenses as it’s a private corporation and not a government entity. Also of note is their DLDV that was noted in the document. To my knowledge, not all states participate in this service so how can this be deemed authoritative?
AAMVA may eventually become an authoritative source for mDLs if and when the States look to them as the issuer of the Digital Trust Service (DTS). mDL implementation and DTS participation by state is here near the bottom of the page: https://www.aamva.org/jurisdiction-data-maps https://link.edgepilot.com/s/e6f06a76/ZIYs2hnA6EeXB6OvwGuRWA?u=https://www.a...
From: Yehoshua Silberstein via WG-IDAssurance
Sent: Tuesday, September 17, 2024 12:54 PM
To: Jimmy Jung
Cc: wg-idassurance@kantarainitiative.org
Subject: [WG-IDAssurance] Re: Working on 63-4 comments; authoritative and credible sources
Two points -
1. The Social Security Number Verification Service is another authoritative source.
2. Arguably, being subject to regulatory oversight isn't clear enough to mean anything substantial. All these entities are subject to numerous privacy-related regulations, and depending on the specific database, can be subject to regulations related to KYC/AML or FTC data security requirements to name a few.
On Tue, Sep 17, 2024 at 12:17 PM Jimmy Jung wrote:
.. but there was one I kind of wanted to get out there early.
CSPs SHOULD collect core attributes, but SHALL validate them with authoritative or credible sources, which seems to point to some perverse incentives.
But more critically, looking at the definitions of authoritative and credible sources; am I mistaken, but is AAMVA the ONLY accessible authoritative source? And does linking “regulatory oversight” to the credible sources severely limit it to the big 3 credit bureaus and maybe a few more? (did MNO aggregators just drop out?)
jimmy
2.4.2.4. Validation Sources
The CSP SHALL use authoritative or credible sources that meet the following criteria. 760
An authoritative source is the issuing source of identity evidence or attributes, or has 761
direct access to the information maintained by issuing sources, such as state DMVs for 762
driver’s license data and the Social Security Administration for Social Security Cards 763
and Social Security Numbers. An authoritative source may also be one that provides or 764
enables direct access to issuing sources of evidence or attributes, such as the American 765
Association of Motor Vehicle Administrators’ Driver’s License Data Verification (DLDV) 766
Service. 767
A credible source is an entity that can provide or validate the accuracy of identity 768
evidence and attribute information. In addition to being subject to regulatory oversight 769
(such as the Fair Credit Reporting Act (FCRA)), a credible source has access to attribute 770
information that can be traced to an authoritative source, or maintains identity attribute 771
information obtained from multiple sources that is correlated for accuracy, consistency, 772
and currency. Examples of credible sources are credit bureaus that are subject to the 773
FCRA. 774
13
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