Comparable Alternative Criteria - Discussion Focus

Good afternoon, Thank you to everyone who participated in the initial conversation about Richard's comparable alternative criteria proposal. Our conversation has highlighted several fundamental questions that we need to address to make this framework well-understood and work effectively, particularly given our program's model of a single SAC leading to monolithic certification. To focus our discussion next week, I want to highlight the key areas where we need clarity and resolution: * Rationale for Alternatives: What is the intended policy for using comparable alternatives? Are they for specific necessity (where a barrier exists), or permissible for any equally effective approach? How should the required justification criteria (63A#0700/0710) reflect this policy? * Process & Approval: How will comparable alternative justifications be formally evaluated and approved within our assessment process? Who makes the final decision? * Certification Scope: How will certifications effectively represent services that use a mix of standard criteria and approved comparable alternatives across different flows? What exactly does the program's approval and the resulting certification guarantee regarding the specific alternatives to service providers and agencies? * Defining & Assessing Comparability: How will assessors consistently and objectively evaluate if an alternative truly achieves "same or better" risk management? What specific evidence is required? How is the assessment impacted if the rationale for the alternative was a specific barrier? * Program Value & Clarity for Agencies: What is the distinct value proposition of a Kantara-certified comparable alternative specifically for agencies? How does our certification interact with an agency's own authority and process for determining acceptable controls? * Operational Impact: What are the expected impacts on assessment time, cost, and resources with the introduction of these criteria, especially considering the need to potentially evaluate the rationale for the alternative and how it fits within a single certification scope? These questions aim to address the foundational purpose of comparable alternatives within our program and resolve the complexities that arise in their evaluation, approval, and communication to agencies, helping us move towards a clear and functional framework. Please come prepared to discuss these points next week. Best, Yehoshua -- Yehoshua Silberstein | Senior Counsel, Product Compliance R&D yehoshua@proof.com (857) 577-8144 Notarize is now a Proof brand 🎉 We hope you love our new look and feel as much as we do! NOTICE: This email may contain proprietary, business-confidential, and/or privileged material. If you are not the intended recipient, please delete this message and notify the sender immediately. Any unauthorized use is strictly prohibited. This email does not constitute a signed writing for purposes of a binding contract.
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Yehoshua Silberstein