GUIDELINES FOR RESPONSIBLE USE OF IDENTITY MANAGEMENT SYSTEMS

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1 GUIDELINES FOR RESPONSIBLE USE OF IDENTITY MANAGEMENT SYSTEMS When used appropriately, identity management systems provide safety and security where they are needed. When used improperly, identity management systems can undermine privacy and security, as well as facilitate identity theft. The following guidelines are designed to allow organizations to obtain the benefits of identity management systems while mitigating the privacy and security risks they pose to individuals. Incorporating effective privacy and security protections from the outset in the design of an identification system is essential in striking this balance. Threshold question: Is the identification system necessary? Cost/Risk-Benefit Analysis There are many situations in which identity management is essential or beneficial for achieving a specific goal for example, authenticating employees in controlling access to a secured facility. Not all situations, however, require the use of identity management technology. Identify management, like all technology, has costs and creates risks. Identity management should be used only where there is a legitimate need, where the system chosen will be effective at meeting that need, and where the benefits the system presents justify the costs and risks involved. The first question that any entity both public and private sector considering a new system of identification should ask is whether an identity system is necessary and effective for solving the articulated and defined problem at hand. In answering this question, all organizations implementing identity management systems must conduct an analysis of the costs and risks of each alternative and weigh these costs and risks against the predicted benefits and effectiveness of the system for achieving the entity s goal. This analysis should consider all of the following factors: Benefits Effectiveness of the system at achieving the stated goal Cost Economic costs would include monetary costs of the entire lifecycle of the system (enrollment, issuance, revocation, reissuance) and would also include costs of equipment, employees, training, manufacturing of physical credential, required system environment for enrollment (e.g., if a biometric is used), security measures, and costs of allowing individual access to their PII and due process/redress in cases of false positives/negatives. Intrusiveness Risk to Privacy of Personal Information Risk of Identity Theft, fraud, system intrusion and cost of necessary security measures

2 Error rates/accuracy Consequences of errors, including both false positives and false negatives Necessary due process and redress mechanisms Three additional principles can help guide this analysis: 1. Diversity and decentralization: Use of a single, centralized system for identification or authentication may offer convenience and efficiency benefits. However, using a single credential for many different purposes or centralizing (including linking separate systems) identity information also increases privacy and security risks because it creates one point of vulnerability for privacy and security. To the extent possible, all entities should consider a diversity of identity systems designed for each specific articulated need or goal. In addition, to the extent possible, entities should use data loss prevention strategies such as decentralizing storage and access to identity information to decrease the likelihood of abuse or misuse. 2. Proportionality: The amount and sensitivity of identity information collected from individuals must be reasonable and proportional with respect to the purpose of the system. The amount and sensitivity of information collected will depend on, among other things, the significance of the transaction and the consequences of false positives or negatives. 3. Privacy and Security by Design: Privacy and security considerations should be assessed and incorporated into the system from the outset of the design process and throughout the project life cycle. This analysis shall be in writing and available to the public, along with all data used in conducting the analysis. The analysis shall indicate why the chosen system has the best cost/risk-benefit ratio among identified alternatives. In addition, the following general principles should be followed. The quantitative analysis shall include a discussion of each principle and the extent to which the chosen system complies with each principle. Where the organization s chosen system does not comply with one or more principles, the analysis shall explain why it was not feasible to comply. If the answer to the above threshold question is yes that is, if it is determined that the benefits of the system outweigh the costs and risks to privacy and security then the system can and should be designed in a way that helps mitigate the risks it presents. The following principles provide guidance for how to design identity systems in a privacy and security protective way. These principles can also serve as a framework for evaluating the privacy and security risks associated with a given identity system. The principles build on widely accepted fair information practices (FIPs).

3 I. Purpose Specification At the outset of design of the system, the organization should specify the purpose of the system as a whole and the purposes for collecting and using identity information at the time of collection. The purposes for collecting and using identity information should be directly linked to the ultimate purpose of the system. These specifications of purpose should guide all further decisions about how the organization will design and implement the system, along with the overarching principle of proportionality. II. Limit Identity Management to Verification The amount and sensitivity of identity information collected from individuals must be reasonable and proportional with respect to the purpose of the system. In most cases, all that is required is that the system verifies that an individual is among those authorized to have access to a physical or virtual space. Identification of individual identity should be restricted to situations where it is needed. III. Avoid Identity Databases The greatest risk of harm from the use of identity management systems comes from unauthorized access to identity databases. In most cases, a database of biometric or similarly sensitive information is not required for the system to achieve its objective. Retention of such information in identity databases should only be used where it are needed. IV. Security - Protect Identity Databases Security measures must include reasonable technical, physical, and administrative safeguards to protect against loss or unauthorized access, destruction, misuse, modification, or disclosure. Ideally, identity systems and associated databases should be protected through strong encryption, the use of biotokens, or equally effective security systems. V. Data minimization - Collect only information that is relevant and necessary to accomplish specified purposes The organization should collect only identity information that is necessary and relevant for the functioning of the identity management system and for accomplishing specified purposes. No additional information should be collected and technologies that have the capability of revealing other information about the individual, especially medical information, should not be used. The

4 organization should only retain the identity information for as long as is necessary to fulfill the specified purposes. VI. Use Limitation Information about individuals collected for use in identity management systems should be used and retained only for the specific purpose for which it was gathered, by the organization that collected the information. Information should not be used for purposes other than for which it was collected or disclosed to other organizations except as required by law. VII. Minimize Records of Transactions In many identity system applications, all that is necessary is to ensure that an individual is among those authorized to enter an area, have access to information, or take some other action. In such applications, it is not necessary to maintain records of the identities of the individuals who receive specific authorizations or the times at which the authorization took place. Such records have the potential to compromise privacy and enable tracking and profiling, and should not be maintained. Where it is necessary to maintain access records for accountability, security, or other legitimate reasons, information about individuals should be accessible only to those who need this information to perform their job responsibilities. VIII. Voluntary; individual access and participation Enrollment in identity management programs should be voluntary whenever possible. When the primary beneficiary of the program is the individual, the individual should be permitted to forego the benefit by not participating. Where possible a system of identity should also offer individuals reasonable, granular control over the information they must disclose in order to enroll, and how that information can be used or disclosed to third parties. To the extent possible, individuals should be provided reasonable access to the personal data the organization maintains about them, and given the opportunity to rectify any errors. To the extent possible, individuals should also be notified of when their identity information has been disclosed to third parties and to whom.

5 IX. Notice and Transparency; No Covert Use Participating in an identity management program, even where participation is mandatory, should require a conscious act on the part of the individual. Covert systems should not be used except by law enforcement in the course of Constitutional investigations. Organizations should provide individuals enrolled or to be enrolled with clear and timely notice about the collection, use, and disclosure of their personal information. X. Accuracy and Data Quality Identity management systems should use technology whose accuracy and allowable failure rates are commensurate with the consequences of mistakes, both to the organization and the individual. Organizations should, to the extent possible, ensure that identity information they hold are accurate, relevant, timely, and complete. XI. Confirmation Techniques; Due Process and Redress Where errors in the system may lead to negative consequences for an individual, organizations must implement appropriate confirmation and due process systems before any adverse action is taken. The more serious the consequences, the more reliable the confirmation techniques must be, and the more due process should be required before final adverse action is taken. Organizations should also implement standard operating procedures for redress cases involving false positives or false negatives. XII. Physical Intrusiveness Identity management systems should minimize psychological discomfort for individuals by choosing the effective technology which is least physically intrusive. XIII. Disclosure and Secondary Use Secondary use, disclosure, or sale of identity information can jeopardize privacy and security. Information about individuals in identity management systems should be disclosed only to others within the same organization with a legitimate need for the information and only for the specific purposes for which it was collected; for legitimate law enforcement purposes; or with the voluntary and informed consent of the individual. If identity information is shared with third parties, to the extent possible, the organization should limit the use of the information by third

6 parties to only for the specific purpose for which the information was collected, and limit the retention by third parties for only until the purpose for which it was shared has been completed. XIV. Collective Bargaining In the employment context, the implementation of identity management systems affects the terms and conditions of employment. Employers should negotiate the implementation of such a system, including the manner and use of the system, the type of information collected, and how such information is recorded and stored, with the employees bargaining agent as part of the collective bargaining process. XV. Legal and Constitutional Rights Identity management must be used in a manner than does not violate individuals legal rights. Government entities must ensure that identification does not violate individuals constitutional rights to privacy or their rights to speak, read, and associate anonymously.

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