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The author of this blog, David T.S. Fraser, is a Canadian privacy lawyer who practices with the firm of McInnes Cooper. He is the author of the Physicians' Privacy Manual. He has a national and international practice advising corporations and individuals on matters related to Canadian privacy laws.

For full contact information and a brief bio, please see David's profile.

Please note that I am only able to provide legal advice to clients. I am not able to provide free legal advice. Any unsolicited information sent to David Fraser cannot be considered to be solicitor-client privileged.

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The views expressed herein are solely the author's and should not be attributed to his employer or clients. Any postings on legal issues are provided as a public service, and do not constitute solicitation or provision of legal advice. The author makes no claims, promises or guarantees about the accuracy, completeness, or adequacy of the information contained herein or linked to. Nothing herein should be used as a substitute for the advice of competent counsel.

This web site is presented for informational purposes only. These materials do not constitute legal advice and do not create a solicitor-client relationship between you and David T.S. Fraser. If you are seeking specific advice related to Canadian privacy law or PIPEDA, contact the author, David T.S. Fraser.

Sunday, December 05, 2004

US Government developing standard for positive identification 

According to Privacy Digest, the National Institute for Science and Technology is developing a national standard for positive indentification of government employees and contractors. The following is a general introduction to the project, from a working paper released on the NIST site:
The “Personal Identity Verification for Federal Employees and Contractors” briefing was developed in response to the Homeland Security Presidential Directive (HSPD-12). The directive sets a policy for a common identification standard for Federal employees and contractors. It also establishes the high level requirements to be satisfied in the Personal Identity Verification standard.

The following information is intended to convey current thinking regarding the NIST response to the HSPD. The concept and design decisions contained herein are tentative and subject to change in the course of consultations with affected Federal government departments and agencies.

A general threat facing government agencies is the unauthorized access to physical facilities or logical assets under the protection umbrella of the PIV system and in which a PIV card is employed in access control processes. Specific examples of threats to government resources include the following:

  • Cardholder makes improper use of a valid card
  • Counterfeit cards are used to intercept or gain access to stored information
  • Stolen or borrowed cards are used to gain unauthorized access
  • PIN information is captured / intercepted through passive surveillance
  • Lower sensitivity rated cards are used to gain access to more sensitive and critical assets.

HSPD-12 mandates a government-wide standard for secure and reliable forms of identification. The policy further defines the following criteria for a secure and reliable form of identification. The identification standard (PIV FIPS 201) will be:

  • Based on sound criteria to verify an individual employee’s identity
  • Strongly resistant to fraud, tampering, counterfeiting, and terrorist exploitation
  • Rapidly verifiable electronically
  • Issued by providers whose reliability has been established by an official accreditation process
  • Applicable to all government organizations and contractors
  • Used to grant access to Federally controlled facilities and information systems
  • Flexible enough for agencies to select the appropriate security level for each application by providing graduated criteria from least secure to most secure
  • Not applicable to identification associated with national security systems
  • Implemented in a manner that protects citizens’ privacy

The program working paper is available at and a slideshow from the project briefing is available at

Thanks to Privacy Digest for the pointer.

This is a complete aside, but I found it very interesting that the word document above is loaded with metadata, showing the last minute revisions that were made to it before the briefing. The tone of the narrative was shifted slightly. To see the changes, open the document, right-click on the toolbar above the document, select "Reviewing" and, on the toolbar that appears, select "Final, showing changes" in the drop-down box. Voila, you can see the revisions made.

Lucily for NIST, the document it is not full of "notes to draft" or anything significantly embarrasing. It is a bit surprising in any event that the organization responsible for IT security standards is posting metadata-laden documents on its website!

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