Defining the Problem – Identity Proofing Challenges
Russ Reopell, Sandy Christopher, and Lorrayne Auld
© 2023 IDPro, Russ Reopell, Sandy Christopher, and Lorrayne Auld
Identity proofing, process by which a credential service provider collects, validates, and verifies information about a person, is a critical step for many identity systems. This article explores identity proofing in general and why current practices are challenging. While the article is largely informed by the identity proofing examples within the United States, the concepts are globally applicable.
Whether you’re purchasing merchandise online or requesting financial or medical services from the federal government or health care providers, being able to prove you are who you claim to be and are indeed entitled to the goods and services you are attempting to access has become a crucial and required fact of everyday life. This article helps readers understand the difficulties and challenges they may face in registering for online goods and services.
Applicant : A subject undergoing the processes of enrollment and identity proofing.
Binding : Associating an authenticator with an identity.
Claimant : A subject whose identity is to be verified by using one or more authentication protocols.
Claimed Identity : An applicant’s declaration of unvalidated and unverified personal attributes.
Credential : An object or data structure that authoritatively binds an identity—via an identifier or identifiers—and (optionally) additional attributes to at least one authenticator possessed and controlled by a subscriber.
Credential Service Provider (CSP) : A trusted entity that issues or registers subscriber authenticators and issues electronic credentials to subscribers. A CSP may be an independent third party or may issue credentials for its own use.
Enrollment : Also known as Registration. Enrollment is concerned with the proofing and lifecycle aspects of the principal (or subject). The entity that performs enrollment has sometimes been known as a Registration Authority, but we (following NIST SP.800-63-3) will use the term Credential Service Provider.
Identity : An attribute or set of attributes that uniquely describes a subject within a given context.
Identity Evidence : Information or documentation the applicant provides to support the claimed identity. Identity evidence may be physical (e.g., a driver’s license) or digital (e.g., an assertion generated and issued by a CSP based on the applicant successfully authenticating to the CSP).
Identity Proofing : The process by which a CSP collects, validates, and verifies information about a person.
Identity Provider (IdP) : The party that manages the subscriber’s primary authentication credentials and issues assertions derived from those credentials. This is commonly the CSP as discussed within this article.
Knowledge-Based Authentication (KBA) : Identity-verification method based on knowledge of private information associated with the claimed identity. This is often referred to as knowledge-based verification (KBV) or knowledge-based proofing (KBP).
Registration : See Enrollment.
Remote : In the context of remote authentication or remote transaction , an information exchange between network-connected devices where the information cannot be reliably protected end to end by a single organization’s security controls.
Subscriber : A party enrolled in the CSP identity service.
Why do we need identity proofing?
Today, many companies and government agencies rely heavily on accurately identifying, credentialing, monitoring, and managing user access to information and information systems across their enterprise to ensure they know who is accessing their data. One of the challenges of digital identity is associating a set of online activities with a specific entity. There are numerous situations where it is important to reliably establish an association of a digital identity with a real-life subject. Examples include obtaining health care and executing financial transactions. There are also situations where the association is required for regulatory reasons (e.g., the financial industry’s Know Your Customer (KYC) requirements, established in the implementation of the USA PATRIOT Act of 2001) 1 or to establish accountability for high-risk actions (e.g., changing the release rate of water from a dam).
Identity proofing establishes that a person is who they say they are based on the validity of one or more pieces of identity evidence. The more due diligence incorporated into the identity-proofing process, the higher the confidence that the applicant is who they claim to be. For example, one would place little confidence in self-asserted identity (“I say I am Santa Claus, therefore I am Santa Claus”). However, suppose I claim to be Mother Nature and can provide written and corroborated identity evidence proving I am Mother Nature. In that case, there is a much higher level of confidence placed in that identity. If I provide all that documentation to the CSP in person, you can be sure I am who I claim to be.
What is identity proofing?
Identity proofing is the process used by a credential service provider (CSP) to collect, validate, and verify the identity evidence provided by an applicant to establish a subscriber’s digital identity. The identity provider (IdP) manages the subscriber’s primary authenticators and, in federation agreements, issues assertions derived from the subscriber’s account. When an applicant is identity proofed, the expected outcomes are:
The claimed identity (a set of unvalidated and unverified personal attributes) is resolved to a single, unique identity within the context of the population of users the IdP/CSP serves and has been validated to exist in the real world.
All supplied identity evidence is validated to be correct and genuine (e.g., not counterfeit or misappropriated).
The CSP/IdP verifies that the claimed identity is associated with the real person who supplied the identity evidence.
When conducting an online transaction, a digital identity represents the person trying to access the digital service.
How is a Digital Identity created?
A digital identity is created based on a positive verification of an applicant from the identity proofing process. Identity proofing starts during the initial enrollment/registration process and may be updated at various stages of the digital identity lifecycle where life events warrant it. Figure 1 shows the Digital Identity Lifecycle and the events that take place during the creation, ongoing maintenance, and the suspension or expiration of a digital identity. 2 Identity proofing can be performed remotely via the Internet or in person at a physical building with individuals hired and trained to perform proper proofing.
Figure - Identity Proofing in the Digital Identity Life Cycle
Identity proofing is thought to be done once, at the time of enrollment/registration. But that may not be the only case and may be required at various stages of the digital identity lifecycle where life events warrant it. As illustrated in Figure 1, the following are the digital identity lifecycle processes:
Sponsorship: The onboarding process to obtain a digital identity. This process may require the applicant to either have or create an account with the CSP prior to sponsorship. This is the first step in the digital identity lifecycle.
Enrollment and Registration: The process through which an applicant applies to become a subscriber of the CSP and the CSP validates the applicant’s identity. This is generally done via an in-person or remote identity-proofing process.
Creation: After a successful Identity Proofing event, the CSP provisions a credential by binding the credential to the subscriber’s digital identity.
Updates: The act or process by which a requirement to be identity proofed after the initial digital identity is established. Examples of identity-proofing updates include:
Per policy, an organization may require identity proofing of their users every three years, such as a government employee who needs to renew the certificates on their smart card.
Change in name or gender may require the subscriber to be identity proofed again.
The subscriber may initially have been identity proofed at a lower assurance level but, based on required access to higher-risk transactions, the subscriber may be asked to be identity proofed at a higher level of assurance.
There are several scenarios, including times of emergency or transactions between strangers, when one may need to be identity proofed to ensure that that digital identity still belongs to that real-life person who was identity proofed at enrollment.
Suspension/Revocation: Revocation is the process of permanently changing the status of a credential to invalid (e.g., the credential has been compromised or the status of the sponsor has changed). There may also be an expiration of the credential bound to the subscriber, which may either trigger another identity-proofing event to renew the credential or surrender the credential housed on a smart card to the CSP. Reasons for suspending or revoking a credential include:
Death of the subscriber.
What is the difference Between In-Person Proofing and Remote Proofing?
In-person identity proofing is when individuals are required to present themselves and their documentation directly to a person. Remote identity proofing is used when individuals are not expected to present themselves or their documents in person and, instead, provide it online. In either case, this traditionally involves validating and verifying presented data against one or more corroborating authoritative sources of data.
Why is remote identity proofing hard and what are the challenges?
Historically, IdPs/CSPs who offered remote identity proofing services typically relied on knowledge-based authentication (KBA), where applicants were asked static questions about themselves and expected to be the only ones to know the answers to such questions, such as job history, credit report data or credit history, their mother’s maiden name, their date of birth, etc. IDPs/CSPs used data collection companies, such as the credit bureaus, Lexis/Nexis, SEON Technologies, Silent Eight, and others, as authoritative sources of identity information to verify the applicant’s responses. If applicants responded correctly to these questions, the credit bureaus would provide a scoring to indicate the assurance of that identity based upon the answers provided. The CSPs, in turn, used those scores in determining the acceptable level of assurance that the identity was verified. However, due to recent data breaches, massive amounts of personally identifiable information (PII) have been stolen and made available from multiple sources, including those on the dark web. Reports of fraud activity clearly show that significant amounts of PII have fallen into the hands of criminals and are being used for identity-related crimes, such as stealing services, assets, or benefits. The recent Twitter, LastPass, and AT&T data breaches, as reported by the Identity Theft Resource Center, are good examples of these types of compromised identity data. 3 As a result, solely relying on the use of KBA is insufficient for corroborating an individual’s claimed identity.
Successful remote identity proofing is contingent on the user having technical knowledge of the process and what is needed to accomplish it successfully (e.g., the user has a smartphone and the ability to use it to capture images/pictures and has valid identification that can be verified with the issuing authority). Online remote identity proofing is difficult because the validation and verification process can be cumbersome and challenging. Identity documentation may not be available, or the documentation provided by the applicant may be insufficient. Further difficulties arise when not all applicants have a smartphone or government-issued identification card that can be remotely validated. Some may find the identity validation and verification process can be too time-consuming or difficult. This increased user friction causes applicants to get frustrated and abandon the service.
The U.S. Government Accountability Office (GAO) released a remote identity proofing report that identified four out of six federal agencies that are still relying on PII-related KBA. 4 The GAO report cites high costs and implementation challenges for certain segments of the public as reasons why some agencies have not adopted alternative identity-proofing methods to KBA. For example, the lack of a mobile phone for some applicant populations was given as a key implementation challenge. Organizations still using KBA should evaluate the value of their KBA solutions and, where possible, replace them with a more dynamic KBA. Additionally, the European Union Agency for Cybersecurity, ENISA, which is dedicated to achieving a common level-high of cybersecurity across Europe, also published a remote I.D. proofing report in March 2021. 5 In their report, they’ve identified similar gaps with a lack of awareness and understanding of the remote proofing process, the variation in quality and completeness of identity evidence across the many European countries, and the desire to use physical presence as the benchmark, which, while tempting, cannot be reasonable when considering the variables introduced in remote proofing.
Over the last few years, there have been multiple government efforts to offer the public secure and private online access to participating government programs both here in the U.S. and abroad. The goal was to make managing government-provided benefits, services, and applications easier and more secure for the populations they were designed to serve. Whether agency applications and services would need to integrate with a single government authentication service is still in question. A single authentication entity for government services would require users to first be redirected to this central authentication service via secure protocols to register, be identity proofed, and assigned an authenticator (either remotely or in-person). Once the user has been identity proofed and acquired an authenticator, the authenticator could be presented to any Government online application or service that accepts them, provided they meet the required identity assurance level of that application or service. Gaining consensus across multiple agencies of the one government to use a common authentication service has proven to be much more difficult than anticipated.
Another remote proofing challenge is that there are too many misperceptions about why personal information, especially biometrics, is being requested and used. Many citizens do not trust the government to protect their personal information and question how it is being used. As a result, many people are reluctant to share their personal information for fear that the information will be used for more than the specified purposes. By not carefully explaining why data is being collected, how it is being used, and whether or not the data is stored or destroyed after remote identity proofing is complete, individuals may not provide the required information and will therefore fail remote identity proofing.
According to concerns expressed by the GAO report, additional work is needed to ensure that a fraudulent image, such as a photo of a mask, is not being provided in lieu of a live image — a threat known as a “presentation attack.” Keeping up with ever-evolving threats to remote identity proofing and implementing the proper security controls to mitigate those threats is an ongoing challenge.
Challenges with remote identity proofing extend to other countries as well. The United Kingdom (U.K.) was among the first to try remote identity proofing, but it has been plagued with performance issues. One of their key problems was centered around the datasets used by the identity providers when trying to confirm a user’s identity. Applicant data used for verification did not match what was on the government’s systems, resulting in the U.K. government not being able to create and manage the system. Due to these problems, private industry is taking over the effort with the first task addressing the issue of the mismatched datasets used by the identity providers.
Today, many organizations and government agencies rely heavily on being able to accurately identify, credential, monitor, and manage user access to information and information systems across their enterprise to ensure they know who is accessing their data. There are numerous situations where it is important to reliably establish an association of a digital identity with a real-life subject. Identity proofing establishes that a person is who they say they are based on the validity of one or more pieces of identity evidence. The more due diligence incorporated into the identity-proofing process, the higher the confidence that the applicant is who they claim to be.
Historically, those who offered remote identity proofing services typically relied on knowledge-based authentication (KBA), where applicants were asked static questions about themselves (such as their mother’s maiden name, the street they grew up on, or their father’s date of birth) and expected to be the only one to know the answers to such questions. However, vast amounts of data about an individual have been stolen in data breaches and are readily available to purchase online. This stolen data can be used by fraudsters to then obtain access to your bank account, receive your stimulus check, or your tax returns. It is due to this high increase in stolen identities that organizations are finding that they no longer trust that digital identity and must improve their remote identity-proofing efforts to more effectively thwart fraudsters.
The use of online remote identity proofing services is difficult because the validation and verification process can be cumbersome and challenging. Identity documentation may not be available, or the documentation provided by the applicant may be insufficient. Further difficulties arise when not all applicants have a smartphone or government-issued identity card that can be remotely validated. Some may find the identity validation and verification process can be too time-consuming or difficult. This increased user friction causes applicants to get frustrated and abandon the service.
Principal Cybersecurity Engineer, MITRE Corporation
Lorrayne has over 25 years of experience in the area of identity and access management, secure web, portal, and Public Key Infrastructure (PKI) technologies supporting the Federal Government. She has worked both as a hands-on integrator and as a cybersecurity engineer providing guidance to the government. She has helped multiple agencies with their Identity, Credential, and Access Management (ICAM) strategies, implementation guidance, and best practices.
Lorrayne serves as the focal point for researching, understanding, and applying ICAM emerging technologies while ensuring ongoing growth within this area. She also serves as the senior advisor to the ICAM capability area as well as a mentor to junior staff. She has spoken at conferences on higher assurance identity proofing and next-generation authentication technologies. Lorrayne is a member of Kantara, IDPro, Women in Identity, and the FIDO Alliance.
Senior Communications Advisor, MITRE Corporation
Building on 20+ years of leading communication and change, Sandy delivers holistic communication programs that measurably engage stakeholders and achieve business goals. Throughout her career, Sandy has worked with executive leadership to create strategic communication plans that align employees with the priorities of the organization. She is an innovative problem solver with extensive domestic and international communication experience on a wide range of issues, including organizational change, crisis communications, healthcare, information technology, ethics, operational risk, quality, deregulation of the utility industry, human resources, environmental, and financial services.
Principal Cybersecurity Engineer, MITRE Corporation
With over 25 years of experience in identity and access management, Public Key Infrastructure (PKI) technologies, and web services focused on identity, authentication, and authorization, Mr. Reopell has supported the Federal Government, Department of Defense, and Telecommunication companies. He began his career as a programmer and quickly became involved in the design, development, integration, and testing of various Air Force and Naval support systems. In the early 80s, he began working on information security systems and helped deploy security solutions in federal and commercial spaces until finally focusing on Identity, Credential, and Access Management (ICAM) strategies, implementation guidance, and best practices.
Russ worked closely with other MITRE staff and served as MITRE’s ICAM Capability Area Lead for many years. Russ was the go-to person across MITRE to assist with or guide staff in the design and integration of ICAM capabilities to the many sponsors MITRE supports. He is responsible for researching, understanding, and applying ICAM emerging technologies and helped to grow work in this ever-evolving area. Russ is a member of IDPro and enjoys mentoring junior staff to increase their knowledge as well as pique their curiosity about the many exciting innovations in the ICAM space.
Dow Jones, “Understanding the Steps of a “Know Your Customer” Process,” Risk and Compliance Glossary, n.d., https://www.dowjones.com/professional/risk/glossary/know-your-customer/ (accessed 27 March 2023). ↩
For more on the digital identity lifecycle, see Cameron, A. & Grewe, O., (2022) “An Overview of the Digital Identity Lifecycle (v2)”, IDPro Body of Knowledge 1(7). doi: https://doi.org/10.55621/idpro.31 ↩
Identity Theft Resource Center, 2022 Data Breach Report , January 2023. https://www.idtheftcenter.org/wp-content/uploads/2023/01/ITRC_2022-Data-Breach-Report_Final-1.pdf (accessed 24 March 2023). ↩
U.S. Government Accountability Office (U.S. GAO), DATA PROTECTION Federal Agencies Need to Strengthen Online Identity Verification Processes , May 2019. https://www.gao.gov/assets/gao-19-288-highlights.pdf (accessed24 March 2023). ↩
European Union Agency for Cybersecurity, REMOTE ID PROOFING Analysis of methods to carry out identity proofing remotely, March 2021. https://www.enisa.europa.eu/publications/enisa-report-remote-id-proofing (accessed 24 March 2023). ↩