Public Comments: WPF files comments on proposed national identity standard, recommends changes


The World Privacy Forum filed technical comments on the IDPV National Standard Project today, offering key privacy recommendations on the proposed standard, Requirements and Implementation Guidelines for Assertion, Resolution, Evidence, and Verification of Personal Identity, version 5.3.1. WPF analyzed the proposed standard carefully, and sees the need for several changes to the standard to improve consumer privacy. In our comments, the intent is to help create a standard that increases security, trustworthiness of identities, and identity credentials while protecting individual privacy.

Identity thieves and fraudsters are creative and will continue to be, and those who detect fraud and protect against it should be as well. That being said, we recognize that a national standard for identity verification and proofing is important, but it must strike a better balance between the need for fraud detection and privacy protection for individuals. Identity standards are challenging to write, because in order to prove identity, much information is typically collected. The impact of an imbalance in the standard could have deleterious consequences for consumers by permitting or encouraging extensive collection of personal information that can, in itself, act as attractive targets for fraudsters.

WPF’s three key recommendations are:

  1. Identity assurance levels need to be better defined.
  2. The Standard needs to offer evidence that proposed standards options offer equivalent levels of assurance and fraud protection.
  3. The Data Minimization principle needs to apply to all parts of the proofing process, not just to the initial set of attributes used to identify individuals.


Read the comments of WPF re IDPV National Standard Project