There are also requirements for information collected for identity verification/proofing, for credential issuance and management, and for records retention in Part B. I did not see any provisions that deal with the re-use of data derived from proofing or from logs of credential use (i.e., something that corresponds to the “no tracking” requirement under FICAM). I do not know of any review by the P3WG of the requirements or the language of IAF—and building in privacy protections here would seem to be fundamentally important. Should we not be integrating PAC into the existing framework in some way?
451 4.2.2 Notices and User Information/Agreements
452 These criteria apply to the publication of information describing the service and the
453 manner of and any limitations upon its provision, and how users are required to accept
454 those terms.
455 An enterprise and its specified service must:
456 AL2_CO_NUI#010 General Service Definition
457 Make available to the intended user community a Service Definition that includes all
458 applicable Terms, Conditions, and Fees, including any limitations of its usage, and
459 definitions of any terms having specific intention or interpretation. Specific
460 provisions are stated in further criteria in this section.
461 and actual Subscribers,
462 Subjects, and relying parties.
463 AL2_CO_NUI#020 Service Definition inclusions
464 Make available a Service Definition for the specified service containing clauses that
465 provide the following information:
466 a) Privacy, Identity Proofing & Verification, and Revocation and Termination
468 b) the country in or legal jurisdiction under which the service is operated;
469 c) if different from the above, the legal jurisdiction under which Subscriber and
470 any relying party agreements are entered into;
471 d) applicable legislation with which the service complies;
472 e) obligations incumbent upon the CSP;
473 f) obligations incumbent upon the Subscriber/Subject;
474 g) notifications and guidance for relying parties, especially in respect of actions
475 they are expected to take should they choose to rely upon the service;
476 h) statement of warranties;
477 i) statement of liabilities toward Subscribers, Subjects and Relying Parties;
478 j) procedures for notification of changes to terms and conditions;
479 k) steps the CSP will take in the event that it chooses or is obliged to terminate
480 the service;
481 l) availability of the specified service per se and of its help desk facility.
482 AL2_CO_NUI#030 Due notification
483 Have in place and follow appropriate policy and procedures to ensure that it notifies
484 Subscribers and Subjects in a timely and reliable fashion of any changes to the Service
486 specified service, and provide a clear means by which Subscribers and Subjects must
487 indicate that they wish to accept the new terms or terminate their subscription.
488 AL2_CO_NUI#040 User Acceptance
489 Require Subscribers and Subjects to:
490 a) indicate, prior to receiving service, that they have read and accept the terms of
491 service as defined in the Service Definition;
492 b) at periodic intervals, determined by significant service provision events (e.g.
493 issuance, re-issuance, renewal) and otherwise at least once every five years, re494
affirm their understanding and observance of the terms of service;
495 c) always provide full and correct responses to requests for information.
496 of User Acceptance
497 Obtain a record (hard-copy or electronic) of the Subscriber's and Subject’s acceptance of
498 the terms and conditions of service, prior to initiating the service and thereafter at
499 periodic intervals, determined by significant service provision events (e.g. re-issuance,
500 renewal) and otherwise at least once every five years.
501 AL2_CO_NUI#060 Withdrawn
503 AL2_CO_NUI#070 Change of Subscriber Information
504 Require and provide the mechanisms for Subscribers and Subjects to provide in a
505 timely manner full and correct amendments should any of their recorded
506 information change, as required under the terms of their use of the service, and only
507 after the Subscriber's and/or Subject’s identity has been authenticated.