KANTARA IAWG comments on 800-63-3  

Process of gathering comments within IAWG

FIRST SESSION

Key discussion items Feb 9th 2017:

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• Kolin Whitley, Experian - ID proofing strategies were put in place as part of multiyear contracts, how might that impact the component given that the new guidelines are significantly different.
• Russ Weiser, Zentry/Synchronoss - requirements for authoritative data sources, chasing identity documents to their source. The federal and state governments have failed to provide a verification service.  TFS work on standard operating procedures, the implication was that there were changes underway to make things easier for agencies to understand.  It's more unrealistic if agencies must grapple with new standard procedures from TFS at the same time that 800-63-3 hits.
• One problem with 800-63 has been lack of flexibility in the face of considerable CSP innovation in how services are provided, we shouldn't try to stand in the way.
• The simplification of the levels from 4 to 3 may have made it more difficult to obtain the levels. Removes the lower cost category and increased the cost to comply.
• The different numbers of levels in different countries may result in interoperability issues between the jurisdictions.

Reference: IAWG Meeting Minutes 2017-02-09

SECOND SESSION

Key discussion items February 16th

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• Continued use of bulleted lists - if the lists convey requirements, the implementer or the reviewer or the assessor needs to be able to refer to the requirements.  Richard has suggested numbers instead of bullets, so that requirements could be uniquely identified.
• Scott will include this among the recommended IAWG comments as well - uniqueness of requirements clauses is great assistance to implementers and assessors alike.

Reference: IAWG Meeting Minutes 2017-02-16

THIRD SESSION

Key discussion items February 23rd: 

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• Discussion of the need to uniquely identify clauses in the requirements.
• Ken Crowl shared his list of his organization's concerns: Level of Assurance vs Identity Assurance Levels; Document verification; "Issuing Source". Overview of Experian position on NIST 800-63-3.pdf
• Scott Shorter included a comment in support of the flow charts / decision trees included in 800-63-3.
• Discussion of requirement for document verification for all remote proofing.  Call for a need for intermediate verification options that don't require the full rigor of IAL2 (remote + document verification). Technical challenges to document verification.

Reference: IAWG Meeting Minutes 2017-02-23

FOURTH SESSION

Key discussion items March 2nd:

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• Richard mentioned that NIST has effectively taken away AL2.
• Discussion of the fact that there are no mechanisms for validating drivers license, although AAMVA would like to be in that business.
• Right now the only viable implementations are PKI or self-assertion.
• Russ has had discussion with someone at GSA has looked into expanding passport service to support this, but they run into funding problems for this.  Financial institutions will also have difficulty verifying those sources.  Would not be surprised if there was an order of magnitude increase in costs - negotiating individual contracts with different states for drivers license validation would expand costs considerably, even if it was possible. Will probably result in stagnating the online credential business, unless GSA were to step in and provide those services on behalf of the government (along the lines of the ACES program).
• Ken mentions the concern from CSPs about the implementation roadmap for when the new changes will be required. Colin says discussions have not taken place, but NIST are aware of Kantara's view on that.
• Richard Wilsher points out that the enrollment processes of most CSPs would need to be changed to meet the new standard, that will not be rapid. Furthermore the question from Kantara's perspective - how soon would Kantara be able to perform assessments?  Thirdly, what would Kantara do to set a deadline by which CSPs would be required to comply.
• Ken asks whether existing credentials would need to be re-proofed. Russ Weiser has mentioned that customers will be unhappy about that. Customers are already asking what to do about the standard. Something like that could result in a years of delay while credentials are updated.
• Richard inquires what will happen with the existing SAC aligned with 63-2 - would we continue it in parallel?  Would there be an overlap?  What about those who are not in the US who are approved against the current criteria

Reference: IAWG Meeting Minutes 2017-03-02

FIFTH SESSION

Key discussion items March 9th: 

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• Additional comments from RGW - section 4.1.2 - cryptographic authenticators at AAL1 shall use approved cryptography.  Scott suggests that this is in line with NIST's mission to push approved cryptography for all uses of government cryptography.
• Additional comment RGW - 4.1.4, 4.2.4, 4.3.4 there are references to 800-53 "or equivalent standard" but what is the method of judging what an equivalent standard is.
• Andrew has a comment on section 4.5 - summary of requirements, they don't have rows for records retention or privacy requirements.

Reference: IAWG Meeting Minutes 2017-03-09

SIXTH SESSION 

Key discussion items March 16th: 

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• Next steps: Thursday 243rd we will take the first cut at looking at the comments. We can package and submit them early if we're happy with them next week.

Reference: IAWG Meeting Minutes 2017-03-16

Archives: 

• Previous KI comments - 2016: Previous submission to NIST