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Draft Recommendation on the Governance of Digital Identity

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updated at 21 Mar 2023
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III. 2. Take steps to ensure that access to essential services, including those in the public and private sector is not restricted or denied to natural persons who, for whatever reason, cannot access or use a digital identity solution;

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  • Ellis Shamah

    " is not restricted or denied to......", is just not strong enough. There needs to be reference to alternate non-digital channels, and also most importantly, the use of proxies (Power of Attorney), especially in countries with low literacy rates. Without specific reference, and as an after-thought only, technical crypto issues may be very complex to solve.

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    • Henk Marsman
      Henk Marsman  •  Author  •  2023-03-22 14:35:05

      Perform at least three impact assessments:
      - risk impact assessment
      - data privacy impact assessment
      - human right impact assessment

      - background:
      risk assessment is typical for security
      DPIA is required under GDPR but should be a common assessment done (in order also to get the legal framework in place, or test it being in place, to protect residents/citizens privacy). Case of Kenya 2021, high court ruling stating the rollout of a country-wide biometric ID scheme was illegal.
      human right assessment is related to the outcome of digital identity solutions and addresses the risk for exclusion, amplification of existing inequalities.

      • Eduardo Chongkan

        https://www.bbc.com/news/world-africa-51324954

        ^ One problem of using local Registries ( by country, is that internally, at least in my, these systems are not compliant with a lot of basic requirements.

        Examples:

        A) Equifax Data. My Data in Equifax is partially true, outdated, and reflects I never know when the data is being read or updated. It uses asimilar model to that of SWIFT. It aggregates data from Financial Institutions and monetizes that data, without the user consent
        B) SICAC ( our national KYC DB ). Currently, the data is being gathered by all participants, by email, and then being centralized from each bank to the central back DB. The process for onboarding is usually to print a PDF and sign it, then scan it, and send it back along with scanned IDs and proof of address. The UX of this process is a major friction point. It is not properly digitalized.
        C) A user with a Data Agent credential, can access anyones data

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        • Eduardo Chongkan

          C .. anyones data, without a record of access or proper ACL levels. They access the RAW data and can share it and they do sell this data to other private companies and criminal organizations. The recommendation for this should be to use ACL based data access and a Zero-Trust approach to data challenging and verification, rather than simply storing raw data and having humans performing data checks by accessing the raw data.

          e.g. The ideal solution is something like https://www.skyflow.com/ ( the best solution in my opinion ) -- You can see examples and use cases of the Zero-Trust approach.

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