Code of Conduct for services acting as relying parties to Government

1.1             Client Responsibilities

The Client will:

(a)       pay the Charges in accordance with clause 6;

(b)       co-operate with IdP personnel t in connection with its operation and safe-guarding of the Service/s;

(c)       comply with any standards or specifications issued by the IdP and any reporting obligations required by the IdP from time to time in accordance with any relevant legislation;

(d)       provide appropriate assistance, where reasonably requested by IdP, in carrying out any audit of the Client’s use of the Services or related systems or suppliers;

(e)       participate in progress reporting as specified in the Service Schedule;

(f)        advise IdP promptly of any Service anomalies, suspicious or unusual usage, or complaints relating to the Services and provide reasonable assistance to IdP in the investigation of such anomalies, usage or complaints;

(g)       ensure that the Client’s website terms and conditions explain the inter-relationship of the Services and the Client’s systems in terms agreed with IdP;

(h)       comply with all applicable laws including, without limitation, the Privacy Act 1993;

(i)         subject to clause XXX, use its best endeavours to promote the Services to its customer base to encourage service uptake and use;

(j)         maintain the Service Interface including the security between the Client’s systems and the Service System;

(k)       maintain certification as defined in the Service Integration Guide;

(l)         notify IdP of any network changes or certification renewals that may impact on any part of the Service;

(m)      ensure that the security and privacy of Service are protected to the greatest extent practicable; and

(n)       notify Service Users of the requirements and process published by IdP for Service Users to obtain a Login and verify their Identity.

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Excerpt for InCommon FOPs

6        Registration, Identification and Authentication of Participant's Trusted Officers

InCommon verifies the identity of all individuals who fill the Participant's trusted roles of Executive and Administrator (see the InCommon website for definitions). By constructing an independently verifiable, out-of-band communication path with these officers, the Registration Authority establishes a sufficiently strong level of assurance that the person is who he or she declares. Details on the registry process are available on the InCommon website.

7        Registration and Management of Participant Policies, Systems, and Technical Components

The Participant's trusted Administrator will be given credentials to manage Federation Participant data and requests in a secure manner.

7.1       Types of Registered Systems: Identity Providers and Service Providers

Within the Federation, participants may offer services as an Identity Provider for their respective user community, as a Service Provider to any participant organization's user community, or both. For instance, a Higher Education Institution serving primarily as an Identity Provider might also make online information or services available to other InCommon participants. Similarly, a Sponsored Partner that is primarily a provider of online services might also act as an Identity Provider.

Participants register identity management systems and/or service provider systems using the InCommon participant administrative interface. Higher Education Institutions and Sponsored Partners receive an initial quota for each system type and can purchase more as needed, subject to certain restrictions, as outlined in the Participation Agreement and Fee Schedule available on the InCommon website.

7.2       Relationship of Systems to Participant

Any identity management system or service provider system registered by a Participant must be under the management hierarchy of the Participant organization. The Participant is responsible for the actions of any system registered with the Federation. Participants may only register third party systems that operate services under contract to Participant and for which Participant will be responsible, in accordance with the provisions of the Participation Agreement. Such third party systems might, for example, include outsourced identity management services.

7.3       Required Information Components

7.3.1      Participant Operating Practices

A fundamental expectation of Federation Participants is that they provide authoritative and accurate attribute assertions to other participants and that participants receiving an attribute assertion protect it and respect any privacy constraints placed on it by the Federation or the source of that information.

To support this goal, each Participant must describe its relevant operations in a Participant Operating Practices (POP) statement and share this POP with Federation Participants. The template POP is available on the InCommon website. In some cases, multiple systems can be described in one POP. A current version of the POP must always be available to the Federation and Participant Administrators. InCommon does not review such Participant Operating Practices against any criteria of performance. The POP is a self-asserted declaration by each Participant of its current practices. More information about POP requirements is available on the InCommon website.

7.3.2      Metadata

A Participant Administrator registers its Identity Provider and Service Provider systems through the participant administrative interface by describing components of its systems. The data are collected and digitally signed by InCommon. Secure, up-to-date, trusted information about all Participants and their systems is a core service of the Federation. InCommon will make reasonable efforts to verify submitted data, and will act in accordance with the practices outlined in the InCommon Operations reference, available on the InCommon website.

Metadata may be removed or modified by Participant Administrators through the participant administrative interface. Changes to metadata are updated within one Internet2 business day following the submission. Under special circumstances, Participant Executives or Administrators may make removal requests via e-mail or telephone as listed on the InCommon website. InCommon will verify these requests using trusted communication channels before processing any removal requests.

Transmission of Federation metadata to Participants is not initiated by InCommon. Instead, Participants are expected to retrieve Federation metadata on a regular basis.

7.3.2.1     X.509 Certificates in metadata

X.509 Certificates in metadata are provided by Participant and are used to verify Participant's message-level signature and encrypt sensitive messages intended for Participant. Such certificates may be self-signed since certificate verification is provided by the secure handling and digital signing of all metadata by InCommon.

7.3.2.2     Declaration of Participant Assurance Program Certification

InCommon adds a declaration of certification status to the metadata of each Participant's certified identity providers. Only InCommon can supply or modify Assurance metadata declarations. InCommon will remove any declaration when necessary to effect suspension of a certification or termination of a Participant from the program.

8        Dispute Resolution procedure

Should disputes regarding Federation services or the use of those services arise among Participants or between a Participant and InCommon, the following procedure is intended to affect a resolution. This procedure will evolve as the Federation gains more experience with the types of disputes that may occur.

Upon resolution, a brief description of the dispute's issues and the resolution of those will be communicated to Federation Participants by email or protected website, unless non-publication is requested by any of the disputing Participants.

8.1       Disputes Among Participants

Participants are expected to make every reasonable effort to settle disputes among themselves, especially if contractual issues among the Participants are involved. If circumstances warrant, (for example, if the dispute centers on the interpretation of Attribute values or the implementation of standards) InCommon may be asked to act as referee in helping the Participants come to resolution.

The OM will serve as the Referee in working with Participants. The Referee will gather as much information as possible from each disputing party and then, if necessary, ask for additional information or advice from other operational staff or advisors. The Referee will then document in writing a proposed solution and submit it to the disputing parties for comment. The Referee then will submit a final draft to the Steering Committee.

8.2       Disputes Between Participant(s) and the Federation

Any Participant may submit a written Notice of Dispute to the OM regarding any aspect of the operation or services supported by the Federation. The OM will make certain that sufficient information exists to define the dispute and then shall inform the Chair of the Steering Committee. The Chair will appoint a Steering Committee Member to serve as Negotiator with the disputing Participant(s).

The Negotiator will gather all the facts and rationales for the dispute and, as necessary, seek advice from any Federation advisors or other relevant parties. The Negotiator will prepare a written report, which shall include a recommended resolution of the dispute. The report shall be submitted to the Chair of the Steering Committee within 30 days of the appointment of the Negotiator unless delayed by the required fact finding.

The Chair shall bring the report to a quorum of the Steering Committee. The Committee, after reviewing the report, may ask for additional information or request the Negotiator to take into account further considerations and prepare a modified recommendation. Resolution of the dispute must be approved by affirmative vote of a quorum of the Steering Committee as defined in the Bylaws. If the Steering Committee is unable to affirm a resolution, the status quo is maintained. The OM shall report the Steering Committee's final action to the disputing Participant(s) in writing as soon thereafter as is practical. If any disputing party believes it cannot accept the outcome of this process, its only recourse is to discontinue participation in the Federation as stated in the Participation Agreement.

9        Operations

The operation and performance of the Federation infrastructure are paramount to maintaining its trust fabric. InCommon supports certain operational services, including the secure collection and distribution of participant metadata, a registration authority to identity-proof and credential Participant organizations and officers, communications and outreach, and a Help Desk. As the Federation gains more experience with federated identity and access management and as requirements for other federation services emerge, the InCommon Federation's operations will evolve to meet new functional criteria.

9.1       Operational Assurance Level

9.1.1      Central Operations

Complete procedures were developed detailing InCommon's central operations. Information security industry standards and practices[1] were used to establish the necessary level of assurance. These operations and procedures were approved by a technical advisory group of Internet2 Middleware Architects. A public listing of these procedures can be found on the InCommon website.

9.1.2      Operations Staff Credentials and Authorization

Operations staff who perform actions critical to security or trustworthiness of Federation operations or services are issued strong identity credentials, commensurate with the risk incurred by unauthorized access to such actions.

9.2       Communications and Support

All InCommon operating documents and Participant Operating Practices statements are made accessible via the InCommon website.

InCommon provides a Help Desk for Participant administrative and technical support. The Help Desk is staffed during normal Internet2 business hours as described on the InCommon website. InCommon also supports a community electronic mailing list for building community involvement and partnerships. Any end users who inadvertently contact the Federation Help Desk will be referred to their home organization for support in online access to other Participants.

Software guidelines are provided or referenced on the website, along with deployment guides, attribute policies, testing facilities, and other federation-specific information for the operation of Identity Providers and Service Providers in the Federation.

9.3       Federation Technical Infrastructure

InCommon is responsible for the secure operation of a number of technology platforms including: a Shibboleth "Discovery Service" (DS) server; a Metadata distribution service; a participant administrative interface; a Certification Authority; and other necessary infrastructure. Operation of the technical infrastructure is described in greater detail in the technical documents available on the InCommon website.

9.3.1      Discovery Service (DS)

The Discovery Service, an optional user interface component, is responsible for allowing users to specify their appropriate Identity Provider for the services they intend to use on-line. Upon selecting an Identity Provider, the user is redirected to the Identity Provider's log in service to authenticate. InCommon operates a redundant DS service and Web page on which all Identity Providers are listed.

9.3.2      Metadata Distribution

InCommon digitally signs and makes available to Participants metadata submitted by all Participants for interoperation of Identity Provider and Service Provider systems. The metadata is maintained on redundant servers.

9.3.3      Participant Administrative Interface

Federation Participant Administrators use the Participant Administrative Interface to securely manage the data relevant to their organization's participation in the Federation. The particular tasks include submitting certificate signing requests, Participant Operating Practices, and submitting or modifying Participant metadata.

9.3.4      Suspension of Federation Services

If InCommon suspects compromise of any of its service components, it may take immediate action to remedy the situation or verify non-compromise, including taking components out of service for a limited time for diagnosis and repair. The OM always will endeavor to minimize interruption or inconvenience to Participants. Any critical compromise will be communicated to Participants in a timely manner.

9.4   Disaster Recovery

InCommon disaster recovery practices ensure the minimum interruption of availability of Federation services in the event of a disaster. This includes providing redundant hardware and secure data backups. Public versions of disaster recovery practices are available on the InCommon website.

10    Participation Status: Renewal, Withdrawal, Termination, and Suspension

10.1   Renewal

10.1.1   Renewal of Participant Status

Renewal of Participation is automatic as long as the Participant remains in good standing and pays its fees in a timely manner.

10.1.2   Renewal of Assurance Program Certification

Renewal of certification under the InCommon Identity Assurance Program requires notification and submittal of documentation by Participant as defined in the InCommon Assurance Program description and the Assurance Addendum to the InCommon Participation Agreement.

10.2    Withdrawal or Termination

Participant may withdraw from the Federation at any time upon written notice to the InCommon office in accordance with the Participation Agreement or Assurance Addendum.

Termination by InCommon or Participant is governed by the terms and conditions of the Participation Agreement or Assurance Addendum.

In all cases of Withdrawal or Termination, the Participant will be removed from the metadata.

10.3    Suspension of Participants' Services

10.3.1   Suspension for reasons of security

A Participant may request the suspension of any Federation services in the case of Administrator credential compromise, participant key compromise, or other security compromise within the Participant's systems. This request may be made via e-mail or telephone from the Executive or Administrator and will be verified by InCommon using trusted communication channels. Suspension may include processes such as revoking credentials, or removing or modifying metadata.

If InCommon suspects any compromise or negligence on the part of a Participant, it will make reasonable efforts to contact Participant to verify Participant's status. For example, a non-responsive Administrator's account may be suspended for the security and safety of Participant's metadata if InCommon suspects an Administrator is no longer active and its repeated attempts at contact go unanswered.

10.3.2   Suspension of Assurance Certification

Suspension of certification is done when a Participant's certification is deemed temporarily unwarranted as defined in Assurance Program documentation and the Assurance Addendum. In the case of Suspension of Participant's Assurance certification, InCommon will only remove the declaration of certification status from Participant's IdP metadata and only for the duration of the Suspension.