[WG-IDAssurance] Consolidated comments on TFS documents
andrewhughes3000 at gmail.com
Fri Dec 6 14:30:38 CST 2013
Hi all - here's the consolidated list of comments on the TFS drafts.
Joni - over to you for merging with the ARB comments
And here are the meeting notes if you'd like to see the discussion on some
of the items (also available in the IAWG Meeting Minutes for December 5
*FICAM TFS Program update comments from IAWG members - December 5 2013
- RF: the ATOS seems to be making the CSPs into Attribute Providers -
the current requirement is to only maintain core attributes - there seems
to be an extension into a new set of attributes - this would increase
costs, might knock smaller CSPs out of the running because they may not
have the resources to deal with the extra attributes.
- RF: Anil John referenced ANSI/NASPO Section 6
- MF: Read it as an optional requirement - if they are available then
provide the attributes, if not then no issue.
- RF: Verbal indications that the attribute provision is leaning towards
mandatory provision (because the Federal Agencies might ask for them)
- SS: There is a section in the RP Guidance on disambiguation of
identities - it recommends that the agency goes to an attribute provider
without any reference to LOAs.
- CT: Anil mentioned that this set of attributes is needed for the RPs
to perform account/identity disambiguation and linking to the right agency
- MF: most RPs don't identify their clients from these attributes - they
know them by other information
- RF: do the SAML assertions have to include the extra attribute data?
If yes, then the CSP will have to capture and maintain the extra attributes.
- SS: don't these attributes have to be collected and kept as proof of
the ID Proofing process?
- RF: yes. but they do an encrypted hash of the values
- MF: But there are many attributes that are not currently collected
- RF: The registration authority does not store the information - the
Certificate Authority keeps it if they want to or need to.
- SS: It appears that Verizon would meet the Bundle 1 requirements.
- Section 22.214.171.124 discusses how to resolve problems linking CSP-provided
identities to accounts. Recommended methods to resolve include:
- Trusted third party. This method redirects a user to a third-party
site (e.g., Experian) where he/she is prompted with several questions to
verify his/her identity.
- Help desk/call center. This method requires the user to call the
help desk to resolve linking issues. The help desk can ask a series of
questions to verify his/her identity.
- Now should those "several questions" or "series of questions"
correspond to the LOA of the identities in question?
- SS: If they are looking for verified attributes, then it has to be
- MF: It is unclear if the attributes SHALL be sent if the CSP has them
or if they are optional.
- RW: Are we making the assumption that the RP will be dictating the
attributes that the CSP will have to gather in the ID Proofing process?
- (RF: Yes)
- So, is this assumption correct?
- (RF: Vz reading is that if the RP asks for it, then the CSP pretty
much has to provide it)
- This needs clarification
- RW: The requirements are stated in terms of what the RP must do. The
implication that is not clearly stated is that the imposition on the RP
becomes an implication on the CSP. This is essentially a profile imposed on
800-63-2 -> "these are the things needed to sufficiently define an
- MF: consolidate Scott's item with Rich's item
- RW: There's also an issue with the footnote saying 'in order of
preference' -> this implies that beyond the core attributes, it is not
clear what weighting the additional attributes have (the core gets 96%
certainty, so what do the others provide?)
- RF: Danger is in who is interpreting this - CSP will see it one way,
Federal RP will interpret differently.
- RF: If adding Attribute Providers into the CSP process, it's possible
that the price of the CSP services will rise which might become an
inhibitor to RP uptake.
- ALL: review comments that have been circulated so far for tomorrow's
*FICAM TFS Program update comments from IAWG members - December 6 2013
Myisha Frasier-MacElveen (Chair), Rich Furr (Vice-Chair), Andrew Hughes
(Secretary), Peter McDonald (Symantec), Nathan Faut (KPMG), Cathy (Daon),
Scott Shorter (Electrosoft), Bill Braithwaite
- SS: gave overview for 1st eSoft comment
- PM: Submitted a question around what 'Verified' means - Verified is
probably distinct from Assurance Level
- SS: For these Verified Attributes - is there any difference between
- PM: Scenario: At LOA2 and LOA3 if a person gives a fingerprint and zip
code -> this uniquely identifies an individual. So is the zip code a
Verified Attribute or not?
- There's not enough clarity on how this is intended
- SS: Identity Proofing only establishes that the identity is a real
person - it does not actually say anything about the person being the
person claiming the identity
- Need to either include gradations of 'proof' so that this is not an
- Need to work out how post-registration identity changes should be
used to maintain the integrity of the initial proofed identity
- RF: CSPs do a pretty thorough process to establish that the identity
information relates to the actual person - either by in person or using
- Never 100% perfect but it is well-understood process
- SS: maybe the RPs would be served better by having ID Proofing process
metadata -> that gives hints about provenance -> so the RP can assess risks
- BB: the 'real person' establishment has been subsumed into the process
of 'identity resolution'/ 'identification of an individual'
- SS: general comments on use of more standardized requirements language
e.g. 'shall', 'should', etc
- MF: ATOS document p4 discussion - the reference to Financial
Institutions exemption. The identity vetting processes depends on the type
of account - so hard to deal with LOA equivalence
- PM: Definition of verification - e.g. Name - what is needed for name
variants? For some attributes variants might need to be allowable.
- PM: Concern that if CSPs need to become full-blown attribute providers
will require significant resources and investment
- PM: discussed Symantec's comment re verified attribute sources
- PM: if a CSP has to go to additional sources to verify attributes then
the CSP's financial model changes
*Andrew Hughes *CISM CISSP
*In Turn Information Management Consulting*
1249 Palmer Road,
Victoria, BC V8P 2H8
AndrewHughes3000 at gmail.com
*Identity Management | IT Governance | Information Security *
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