Thanks for this Jimmy - it's the long-standing major flaw in the 800-63-3
'collections of evidence' - everyone knows about it, but nobody has been
able to convince the NIST maintainers that they should fix the problem. I
and others been muttering, complaining, pointing out, commenting about
invalid requirements like this forever.
There is no way to resolve this issue within the current
documentary-evidence structure of 800-63. The underlying assumption that
"proofing organizations" have total access to data sources and 100%
effective physical credential validation machinery is and has been wrong
for many years.
Similarly, the fact that commercial vendors who are not doing business with
US Federal or State governments see 800-63 as somehow valid in
non-government scenarios is quite astonishing. At least with the Kantara
SAC we have taken efforts to modify/strip out most (hopefully all) of the
government dependencies that make no sense in B2B scenarios.
As assessors, I would be very interested to hear about your actual
experience with actual assessments. Just like the 'components' argument,
where I was surprised by your recounting what happens in the field (I
should not have been surprised, but I was) - I'd like to hear how companies
have worked around the tight restrictions and convinced their assessors
too. Just in case I have to change my understanding in this situation as
well.
andrew.
————————
*Andrew Hughes *CISM
m +1 250.888.9474
AndrewHughes3000@gmail.com
On Fri, Jun 28, 2024 at 7:27 AM Jimmy Jung
Here is a fun bit of nonsense.
I gave NIST’s notional strength of evidence page to a client to help them expand on their approaches to IAL2, thinking that the notional strength of evidence page, which we have adopted; identifies and classifies many additional options for identity evidence. But as we dug in, things got murky. https://pages.nist.gov/800-63-3-Implementation-Resources/63A/resolution/
SP 800-63 and Kantara require that “The CSP SHALL validate identity evidence with a process that can achieve the same strength as the evidence presented. For example, if two forms of STRONG identity evidence are presented, each piece of evidence will be validated at a strength of STRONG.(63 4.4.1.3; see also 63A#0200)” This is compared with verification which is only compared to the strongest piece of identity evidence. (63 5.3.1))
And, validating evidence at STRONG requires having “*all personal details and evidence details confirmed as valid by comparison with information held or published by the issuing source or authoritative source(s).”*
Thank god for AAMVA, but out of curiosity, what issuing, authoritative, or even credible source would validate a Permanent Resident Card, Native American Enhanced Tribal Card, “Enhanced ID cards,” U.S. Military ID, Permanent Resident Card or Native American Tribal Photo Identification Cards? Calling them SUPERIOR or STRONG isn’t really meaningful, if they cannot be validated that way.
There are some cool implementations that can read a passport and verify digital signatures, but for PIV, CAC, PIV-I (and TWIC?) you are going to need a card reader, so that mostly leaves out unsupervised. I think validating a digital signature is a fairly strong validation, even if it does not really COMPARE information with an issuing or authoritative source?
Things really seemed odd to me, when we came to the conclusion that you would have to consider a US Navy CAC card a “FAIR” piece of evidence, because the DoD doesn’t validate CAC cards.
For an unsupervised proofing, and working from NIST’s notional strength of evidence page, which TWO items can you compare with information held by an issuing or authoritative source?
US Passport
SUPERIOR
Foreign e-Passport
SUPERIOR
Personal Identity Verification (PIV) card
SUPERIOR
Common Access card (CAC)
SUPERIOR
Personal Identity Verification Interoperable (PIV-I) card
SUPERIOR
Transportation Worker Identification Credential (TWIC)
SUPERIOR
Permanent Resident Card
SUPERIOR
Native American Enhanced Tribal Card
SUPERIOR
REAL ID cards
STRONG+
Enhanced ID cards
STRONG+
U.S. Uniformed Services Privilege and Identification Card (U.S. Military ID)
STRONG+
Permanent Resident Card
STRONG
Native American Tribal Photo Identification Card
STRONG
Driver’s License or ID card (REAL ID non-compliant)
STRONG
Jimmy
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