ID Proofing - Assessment and Management of Privacy and Security Risks, v1.0

Credential Service Providers must conduct a risk management process that covers the privacy and security risks related to the retention of PII data recorded during the identity proofing process.

Assessment Step

1
CSP Risk Management (CSPRiskManagement)
Has the CSP conducted a risk management process that covers the privacy and security risks associated with their identity proofing processes, specifically covering issues of PII retention and any other requirements that apply?
Artifact
A1
Provide evidence (e.g. organizational policies, compliance/assessment reports, sample risk management report) that make it clear what risk management processes are being used by the CSP.

Conformance Criteria (1)

C1
The CSP SHALL conduct a risk management process, including assessments of privacy and security risks to determine:
  • Any steps that it will take to verify the identity of the applicant beyond any mandatory requirements specified herein;
  • The PII, including any biometrics, images, scans, or other copies of the identity evidence that the CSP will maintain as a record of identity proofing (Note: Specific federal requirements may apply.); and
  • The schedule of retention for these records (Note: CSPs may be subject to specific retention policies in accordance with applicable laws, regulations, or policies, including any National Archives and Records Administration (NARA) records retention schedules that may apply).
Citation
NIST SP 800-63A
Section 4.2 (7)