This section is informative.
This section is intended to provide guidance to CSPs for assessing the risks associated with inequitable access, treatment, or outcomes for individuals using its identity services, as required in Sec. 5.1.3. It provides a non-exhaustive list of potential areas in the identity proofing process that may be subject to inequities, as well as possible mitigations that can be applied. CSPs can use this section as a starting point for considering where the risks for inequitable access, treatment, or outcomes exist within its identity service. It is not intended that the below guidance be considered a definitive, all-inclusive list of associated equity risks to identity services.
In assessing equity risks, a CSP starts by considering the overall user population served by its identity proofing and enrollment service. Additionally, the CSP further identifies groups of users within the population whose shared characteristic(s) can cause them to be subject to inequitable access, treatment, or outcomes when using that service. CSPs are encouraged to assess the effectiveness of any mitigations by evaluating their impacts on the affected user group(s). The usability considerations provided in Sec. 9 should also be considered when applying equity risk mitigations to help improve the overall usability and equity for all persons using an identity service.
Identity resolution involves collecting the minimum set of attributes to be able to distinguish the claimed identity as a single, unique individual within the population served by the identity service. Attributes are obtained from presented identity evidence, applicant self-assertion, and/or back-end attribute providers.
This section provides a set of possible problems and mitigations with the inequitable access, treatment, or outcomes associated with the identity resolution process:
Description: The identity service design requires an applicant to enter their name using a Western name format (e.g., first name, last name, optional middle name).
Possible mitigations include:
Description: The identity service cannot accommodate applicants whose name, gender, or other attributes have changed and are not consistently reflected on the presented identity evidence or match what is in the attribute verifier’s records.
Possible mitigations include:
Identity evidence and core attribute validation involves confirming the genuineness, currency, and accuracy of presented identity evidence and the accuracy of any additional attributes. These outcomes are accomplished by comparison of the evidence and attributes against data held by authoritative or credible sources. When considered together with the identity resolution phase, the result of successful validation phase is the confirmation, to some level of confidence, that the claimed identity exists in the real world.
This section provides a set of possible problems and mitigations with the inequitable access, treatment, or outcomes associated with the evidence and attribute validation process:
Description: Certain user groups do not possess the necessary minimum evidence to meet the requirements of a given IAL.
Possible mitigations include:
Description: Records held by authoritative and credible sources (e.g., mobile network operators and phone number verifiers) are insufficient to support the validation of core attributes or presented evidence for applicants belonging to certain user groups.
Possible mitigations include:
Description: Records held by authoritative and credible sources may include inaccurate or false information about persons who are the victims of identity fraud.
Possible mitigations include:
Identity verification involves proving the binding between the applicant undergoing the identity proofing process and the validated, real-world identity established through the identity resolution and validation steps. It most often involves collecting a picture (facial image capture) of the applicant taken during the identity proofing event and comparing it a photograph contained on a presented and validated piece of identity evidence.
This section provides a set of possible problems and mitigations with the inequitable treatment or outcomes associated with the identity verification phase:
Description: Image capture technologies lack the ability to capture certain skin tones or facial features of sufficient quality to perform a comparison.
Possible mitigations include:
Description: Facial coverings worn for religious purposes impede the ability to capture a facial image of an applicant.
Possible mitigations include:
Description: When using 1:1 facial image comparison technologies, biased facial comparison algorithms may result in false non-matches.
Possible mitigations include:
Description: When employing physical facial image comparison performed by CSP operators, human biases and inconsistencies in making facial comparisons may result in false non-matches.
Possible mitigations include:
The Usability Considerations section of this document (Sec. 9) provides CSPs with guidance on how to provide applicants with a smooth, positive identity proofing experience. In addition to the specific considerations provided in Sec. 9, this section provides CSPs with additional considerations when considering the equity of their user experience.
Description: Lack of access to needed technology (e.g. connected mobile device or computer), or difficulties in using required technologies, unduly burdens some user groups.
Possible mitigations include:
Description: The remote or in-person identity proofing process presents challenges for persons with disabilities.
Possible mitigations for remote identity proofing include:
Possible mitigations for in-person identity proofing include: