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Purpose
1.
This briefing:
1.1
seeks your formal direction to progress the modernisation of RealMe services of
Identity Check and to work to develop a Verifiable Identity Credential (VIC)
within baseline funding provided in Budget 2022; and
1.2
provides a high-level plan for the Department of Internal Affairs’ (the
Department) proposed approach to RealMe modernisation.
Background
Cabinet mandate: modernising digital identity services
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2.
In December 2021, Cabinet [GOV-21-MIN-0061 refers] endorsed modernising the
Department’s contribution to the digital identity system by:
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2.1
the implementation and running of a digital identity regulatory regime (the
Digital Identity Services Trust Framework);
2.2
modernising the Department’s digital identity services, including RealMe
services;
2.3
continuing the operation of the Department’s key digital identity services,
including RealMe login and the Identity Verification Service; and
2.4
driving uptake of modernised digital identity services through support to
Information
agencies and engagement with market providers.
The Digital Identity Services Trust Framework Bill
3.
Following Budget 2022 decisions, the Minister for Digital Economy and
Official
Communications (DEC Minister) has previously directed officials to:
3.1
progress the Digital Identity Services Trust Framework Bill (the Bill);
the
3.2
9(2)(g)(i)
3.3
continue development of the rules which will be required for the Bill; and
under
3.4
continue stakeholder engagement for the above.
Modernisation of digital identity services: proposed initiatives
4.
In line with your direction, the Department will progress work to develop two key
services designed to support the new digital identity approach underpinned by the
Digital Identity Services Trust Framework: Identity Check and Verifiable Identity
Credentials.
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Identity Check
Overview
5.
Identity Check is a Department-operated service that provides organisations with a
common approach to verifying user identity information submitted through online
services. The key purpose of the service is to provide these organisations with
confidence that the user providing the information is the owner of the identity. The
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Identity Check service would verify a submitted photo of the identity, taken in real
time, and core identifying information against the authoritative records, such as the
New Zealand Passports database.
6.
Client demand for Identity Check comes from both the public and private sectors. The
ability for customers to prove their identity in a fully digital channel in real-time has
mass appeal.
Distinction from RealMe
7.
Identity Check differs from the RealMe verified identity in that Identity Check is
completely digital and in real-time for both the application and back-office approval
processes. Identity Check is a one-use transactional identity verification process. It
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does not create a reusable identity credential. By contrast, once the RealMe verified
identity has been approved, it is able to be re-used again and again. The RealMe
verified identity does have a higher confidence rating than Identity Check as it has a
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more extensive validation process, which is governed by the Electronic Identity
Verification Act.
Controlled pilot implementation
8.
To manage performance and client expectations, the Identity Check service will be
implemented initially as a controlled pilot study. Baseline funding will enable the
production of the initial version of Identity Check and some customisation to meet the
needs of partners. Partner feedback will help inform future work to develop the
Information
service and provide insights for the product roadmap and 9(2)(f)(iv)
Current interest/potential uptake
9.
Identity Check has been tested with some public and private agencies and demand is
strong. There is active interest from the following:
Official
9.1
9(2)(b)(ii)
the
9.2
Telecommunications companies and banks;
9.3
9(2)(b)(ii)
9.4
Public sector agencies, such as the New Zealand Transport Authority, Ministry
of Business Innovation and Employment and the Ministry of Social
under
Development; and
9.5
the University of Auckland.
Costs/funding for full implementation
10.
The Department can generate revenue by charging for the transactions facilitated by
intermediaries each time someone utilises Identity Check. There are a number of
Released
questions to be worked through including, for example, whether the Department
should charge government agencies for this type of service and, if so, how much. In
addition, there are also some outstanding questions around equity of access to
services for New Zealanders and how to make any identity proofing services low or no
cost. This is the work the Department would do this year to understand how Identity
Check will be put fully into production.
11.
The Department considers that, given the wide ranging commercial interest in Identity
Check, productionising it with different client types could enable the Department to
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continue iterating the product and evolving it for the customers’ benefit.
9(2)(f)(iv) and 9(2)(g)(i)
Verifiable Identity Credentials (VIC)
12.
A VIC can be stored by individuals on their personal device via an app or in an online
account and can be shared directly with organisations or agencies to prove their
identity. The VIC concept differs from the RealMe verified identity in that the VIC will
be interoperable with other digital wallet or web-based service providers, not just via
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RealMe.
13.
The Department’s VIC solution, their role in New Zealand’s digital identity system, and
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how they may be used by private and public-sector entities, will need to be assessed
against existing legislative frameworks. These include the privacy principles and
standards yet to be implemented through the Digital Identity Services Trust
Framework Bill.
14.
9(2)(f)(iv)
effort will be put into detailed solution design including
market engagement with vendors. This will test the VIC’s interoperability and identify
any issues with product design in this area, with a view to completing proof of concept
Information
implementations where possible, and completing operational analysis and planning.
9(2)(f)(iv) and 9(2)(g)(i)
Quarterly reporting
15.
Going forward, the Department will report to you both on the progress made with the
Official
Identity Check and VIC initiatives. This will provide you with up-to-date information to
allow you to continue to engage with your Cabinet colleagues to reinforce the value
and importance of this work for their own portfolios. Reporting will be on a quarterly
the
basis.
Governance
16.
The Digital Government Leadership Group1 will be the cross-agency governance body
under
for Identity Check and VIC, as the membership is already across the Department’s
initiatives and other digital strategies across the public-sector.
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1 The Digital Government Leadership Group (DGLG) is a group of 13 public service system leaders and chief
executives from across the public-sector. The DGLG oversees government’s digital transformation, working
with ministers, the Public Service Leadership team, and public service agencies to support New Zealanders to
have seamless access to the government services they want and need.
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Te Kaupapa | Purpose
1.
The pilot for Identity Check is due to commence on 19 September 2022. The purpose
of this briefing is to provide you an update on recent progress, next steps and talking
points should these be required.
2.
You were previously briefed about the Department’s intent to move forward with this
service offering [DEC202200130] and in June 2022 you directed officials to continue to
progress the development of Identity Check within existing baselines and report back
quarterly on progress.
He Whakarāpopototanga | Executive summary
3.
Identity Check (previously known as One Time Identity) is a new identity verification
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service operated by the Department of Internal Affairs (the Department) that provides
a person a secure, trusted, and real-time way of proving who they are online so they
can access the services they need.
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4.
Identity Check is an example of the products and services that will operate under the
Digital Identity Trust Framework which can be bundled and integrated by both
agencies and also private identity services providers.
5.
Identity Check compliments the Departments existing RealMe Verified Identity service
by providing a convenient single use verified identity credential for people who don’t
have time to complete the more robust RealMe identity verification process.
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6.
There is strong demand for Identity Check from both the public and private sectors.
The ability for customers to prove their identity in a fully digital channel, in real-time,
with a high degree of integrity has mass appeal as it enables organisations to create
more innovative and transformative digital experiences for their customers.
7.
The Department has completed robust legal, privacy, and security, reviews of the
Official
Identity Check service, including consultation with the Office of the Privacy
Commissioner, detailed legal analysis, and security certification and accreditation. The
the
pilot service is now ready to be used.
8.
The next phase of product development is a pilot study which will provide a safe way
for the Department to; test how the service functions in the real-world environment,
tune service performance, identify areas for further product development, and
under
increase partner buy-in.
9.
In August, the Department entered into a pilot agreement with Hospitality New
Zealand (HNZ), which will see Kiwi Access card applicants (or their identity referee) use
Identity Check to prove who they are in a new, fully online, Kiwi Access Card
application process. The pilot is planned to begin on 19 September 2022 and will run
for 12 months.
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10.
In recent months, there has been media interest in Identity Check focused on its
development, how it works, and concerns around the sharing of personal information
including selfie photos. Therefore, it is likely you will be approached for comment
when the pilot becomes public knowledge.
11.
The Chief Executive of HNZ, Ms Julie White, intends to brief the Minister for the Digital
Economy and Communications on this from HNZ’s perspective.
12.
Talking points are included in Appendix A.
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He whakamārama | Background
What Identity check is and how it works
13.
Identity Check (previously known as One Time Identity) is a new identity verification
service operated by the Department of Internal Affairs (the Department) that provides
a person a secure, trusted, and real-time way of proving who they are online so they
can access the services they need.
14.
Identity Check differs from the RealMe verified identity in that Identity Check is
completely digital and in real-time for both the application and back-office approval
processes. Identity Check is a one-use transactional process and does not create a
reusable identity credential. By contrast, once the RealMe verified identity has been
approved, it is able to be re-used again and again. The RealMe verified identity has a
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higher confidence rating than Identity Check as it has a more extensive validation
process, which is governed by the Electronic Identity Verification Act.
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15.
Identity Check has been designed to integrate seamlessly into the digital onboarding
process of a partner organisation.
16.
Identity Check works by leveraging identity verification technology (already used by
thousands of New Zealanders when applying for Passports, Citizenship, and RealMe) to
verify a presenting individual’s information against identity information held in the NZ
Passport database or NZ Driver Licence register. Over time it is hoped that Identity
Check can be expanded to verify the identity of people who don’t have a NZ Passports
Information
or NZ Driver Licences
17.
Customers will experience Identity Check as an option to prove their identity online
when applying for services from a partner organisation.
18.
If a person is wanting to transact online and decides to verify their identity using
Official
Identity Check (from the option or options provided by the partner organisation) they
will be redirected to a DIA website to complete the Identity Check process.
19.
Identity Check will always be optional. One of the conditions the Department will
the
require of any organisation using Identity Check is that they must provide an
alternative way for customers to prove who they are.
20.
If a person chooses Identity Check, they will be asked to enter their identity
under
information and look at the screen of the device they are using. A digital video will be
captured and a frame from the video compared to the image held in the passports or
Driver’s Licence database. This is like what happens at an airport smartgate. Once
verified the person will receive immediate notification and be returned to the partner
website with confirmation of their identity, removing the need for them to present
identity documents in person.
21.
The Identity Check service does not allow third parties access to the NZ passports
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database or NZ Driver Licence register. The only personal information provided to the
partner organisation is what the customer provides themselves along with a statement
of fact for the Department verifying whether the information submitted matches the
relevant passport or Driver Licence record held by the Department or Waka Kotahi NZ
Transport Agency (NZTA).
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Why Identity Check is necessary
22.
In recent years, identity verification services, like Identity Check, have become
ubiquitous in New Zealand. These services are used by the public millions of times each
year helping a wide range of organisations create innovative and transformative digital
experiences while reducing their exposure to identity fraud and helping them meet
their evidence of identity obligations under Anti-Money Laundering and Countering
Financing of Terrorism (AML/CFT) regulations.
23.
As the sophistication of identity fraud in New Zealand has grown, vulnerabilities in the
current generation of data confirmation-based identity verification services have
begun to be exploited. Today, 9(2)(k)
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This is possible because current settings
do not allow identity verification services to compare a customer photo against
authoritative government records.
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24.
Identity Check leverages the Department's unique authorisation to access NZ Driver
Licence records and NZ Passport records for identity verification to eliminate this
vulnerability, offering organisations a better way to protect themselves and their
customers from identity fraud.
How Identity Check is authorised
25.
At pilot launch, Identity Check will operate without a specific legislative mandate
Information
authorising its entire operation, however, as Minister of Internal Affairs you may
authorise the Department to operate Identity Checks as long as it complies with the
law.
26.
The Department has comprehensively reviewed the design of Identity Check against
applicable legislation (the Identity Information Confirmation Act (2012), the Passports
Official
Act (1992), the Land Transport Act (1998), and the Privacy Act (2020)) and holds the
position that the service is lawful. However, there may be merit in pursuing an explicit
the
legislative mandate to foster greater public trust and confidence in the service.
Identity Check is open to everyone and lever for more equitable access to services
27.
Identity Check is a digital tool which, if expanded, has the potential to support greater
under
access to services and greater equity of access in New Zealand.
28.
Identity Check is currently limited to use by organisations who engage directly with the
Department to serve their customers, however, over time it is hoped that the service
can be expanded to support an intermediary model which will facilitate greater
partner organisation adoption and enable the bundling of Identity Check with other
services that are important to customers. An example of this could be SmartStart
acting as an intermediary for the Ministry of Education, Ministry of Social
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Development, and Inland Revenue to both verify a customer’s identity for all of these
agencies but also bundle other sharing, such an income or citizenship into a single
interaction. Alternatively, a private sector AML-CFT agency could bundle Identity Check
with other checks to digitally transform the provision of a variety of services from
switching home-loans, to purchasing high value items online, to property
conveyancing.
29.
While a digital service that requires a device with a camera to work, Identity Check is
not limited to online use and can be implemented in multiple ways, including via in
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person kiosks (operating in a similar way to airport smartgates) or via assisted service.
Kiosks could be implemented in convenient locations and enable access to a variety of
services and assisted service models could support people to overcome technology
barriers.
30.
Identity Check is available anywhere with internet access and many places where
physical stores are no longer viable. The Department is investigating the inclusion of a
zero-rated data scheme into the service to improve access for people who rely on
mobile data plans to access services.
31.
At pilot launch, Identity Check will be used to enable people to get a Kiwi Access card
online. The Department is working with HNZ to help make the Kiwi Access card to be
easier to obtain and, by supporting a more robust identity verification process, enable
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the card to be trusted in more places.
32.
Over time it is hoped that Identity Check can be expanded to include people who may
not hold a NZ Passports or NZ Driver Licences such as temporary or permanent
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residents, the elderly, or people with disabilities.
33.
Where Identity Check is not right for people, the Department will offer more flexible
options via its RealMe Verified Identity service.
Budget 22 decisions and direction from Ministers.
34.
In Budget 22 the Department sought funding to modernise New Zealand’s digital
identity system. 9(2)(f)(iv)
Information
35.
Following the announcement of Budget 22 the Department briefed you on the
Department’s intentions to move forward with modernisation initiatives as funding
allowed.
Official
36.
You directed officials to progress the modernisation of RealMe services, Identity Check
and to work to develop a Verifiable Identity Credential (VIC) within baseline funding
the
provided in Budget 22 and report back quarterly on progress made.
Development update
37.
The Department has now completed its first phase of development; including work to
under
ensure Identity Check meets all data protection and security requirements and is now
ready to pilot the service with partners.
37.1
A thorough Privacy Impact Assessment (PIA) has been completed and reviewed
by the Office of the Privacy Commissioner, showing how the Department
responsibly manages privacy risks and complies with applicable legislation. The
full PIA will be published publicly at the commencement of the pilot.
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37.2
Security certification and accreditation for the service has been completed
including an audit against the New Zealand Information Security Manual and
the development of a risk management plan. All inherent risks have been
mitigated to an acceptable level.
37.3
An Identity Check confirmation agreement has been developed that sets out
appropriate terms to ensure partner expectations are clear and all information
sharing is appropriately authorised.
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38.
The next phase of product development is a pilot study which will provide a safe way
for the Department to; test how the service functions in the real-world environment,
tune service performance, identify areas for further product development, and
increase partner buy-in.
Business development and engagement
39.
The Department continues to work closely with several organisations who have shown
active interest in using Identity Check including:
39.1 9(2)(b)(ii) and 9(2)(j)
39.2
the Ministry of Social Development
39.3 9(2)(j)
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40.
In August, the Department entered into a confirmation agreement with HNZ who will
be the first partner to pilot the service. This will see Kiwi Access card applicants (or
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their identity referee) use Identity Check to prove who they are in a new completely
digital Kiwi Access Card application process. HNZ believe their newer, more robust,
online process will increase the accessibility and utility of the Kiwi Access cards and
expect as many as 15,000 people to apply online in the first year. Go live for the pilot is
planned for 19 September 2022 and will run as a 12-month pilot.
41.
From September, the Department will look to re-engage other public and private
organisations which have shown interest in using the service in the past to gauge
interest in their participation in the pilot and keep them abreast of service
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development.
42.
Over the course of the pilot the Department intends to work with partners to engage
with Iwi and the Māori Data Sovereignty group to demonstrate how the service works
and might be used and incorporate Māori views into its future design and/or usage
Official
principles.
Media interest in Identity Check the
43.
Following the proactive release of Cabinet material about
investing in infrastructure for
the digital identity system, the Department received several media enquiries and
Official Information Act requests from Radio New Zealand (RNZ) related to Identity
Check. RNZ subsequently published several radio segments and website articles which
under
discussed:
43.1
the development of the Identity Check service,
43.2
the Departments access to information (including images) from the New
Zealand Driver Licence register for Identity Check,
43.3
the potential usage of Identity Check by the private and public sector,
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43.4
the digital identity trust framework, and
43.5
government investment in digital identity,
44.
To date there has been little interest from the wider news media, but we anticipate
greater coverage following go live and it is likely you will be approached for comment
when the pilot becomes public knowledge.
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45.
You recently received several written parliamentary questions related to Identity
Check. The talking points in Appendix A are based on previous responses to these
written parliamentary questions and anticipated questions from media.
Next steps
46.
Following go live, the Department will; monitor service performance, look to open the
pilot to more organisations, and progress a series of enhancements as funding allows.
47.
In September 2022 the Department intends to present the service, amongst other
initiatives, to the Data Ethics Advisory Group (convened by the Government Chief Data
Steward and Chief Executive of Statistics NZ) for advice on how the service might
develop following the pilot.
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48.
9(2)(g)(i)
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Ngā tūtohutanga | Recommendations
•
Note Identity Check will go live ~19 September and media interest is
Yes/No
expected
•
Note the attached talking points in Appendix A
Yes/No
Information
•
Advise officials if you would like a practical demonstration of the service
Yes/No
•
Note the Department will provide a further update in December 2022
Yes/No
Official
the
Tim Waldron
Acting General Manager Te Pou Manawa
Kāwai ki te Iwi | Service Delivery and Operations
under
Hon Jan Tinetti
Minister of Internal Affairs
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/
/
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Appendix A
What Identity Check is and how does it work?
• Identity Check is a new service being piloted by the Department of Internal Affairs
(the Department).
• For many years the Department has used biometric technology to help make it easier
for New Zealanders to apply for passports, citizenship, and RealMe.
• Identity Check reuses the existing identity verification technology that New
Zealanders access when applying for, or renewing, passports, RealMe, or NZ
Citizenship.
•
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Identity Check is fully consent-based and optional.
• Identity Check will make it easier for New Zealanders to securely access services.
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• Identity Check works by allowing third parties to confirm people are who they say
they are, by having the Department compare their information against NZ passport
or NZ Driver Licence records
• The only information provided from the NZ passports or NZ Driver Licence databases
is a confirmation that the applicant matches their relevant passport or Driver Licence
record.
• The technology is proven, secure and designed to keep New Zealander’s information
Information
safe as well as complying with all data protection requirements.
How will the Department be ensuring New Zealanders’ data is securely, safely, and
appropriately managed?
• A lot of work has gone into making sure Identity Check meets all data protection and
Official
security requirements.
• This included getting the proposed service model reviewed by the Office of the
the
Privacy Commissioner.
• It also included security checks by independent third parties.
• Data held by the Department will never be shared with third parties.
under
• The service will always be consent based – no one will be obliged to use it.
• One of the conditions the Department will make of any organisation using the service
is that there must be an alternative way to access the organisation’s services if that is
what the customer chooses to do.
Why do New Zealanders need Identity Check?
Released
• Enabling New Zealanders to transact online saves them the cost of document
reproduction, avoids the costs of travel to physically go to an organisation to prove
their identity, and transacting online reduces the time they’re away from their
productive work or family time.
• The aim is to make access to services more convenient and faster by using online
channels. It also helps to prevent fraudulent behaviour and protect people from
identity theft.
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• Identity Check doesn’t rely on physical documents which can be forged or copied – a
tactic used by those seeking to steal people’s identity.
• In the 21st century New Zealanders rightly expect to be able to easily, and securely,
access services.
• It will enable people to access services online, 24/7 and without having to visit offices
or make appointments.
• New Zealanders expect government to play its part in ensuring identity verification
works as they need it to.
What is the technology the Department uses and how does it work?
• The Department uses facial recognition technology to support four of the services it
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provides to New Zealanders:
•
Applying for a passport for the first time
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•
Renewing a passport
•
Applying for citizenship
•
Applying for a RealMe account
• The technology is only used to help verify someone is who they claim to be.
Information
Official
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Appendix B
Email 2 - Attachment
Talking Points on Digital Identity
• The Department of Internal of Affairs (DIA) is the lead agency on two initiatives in relation to
Digital Identity.
• The first is the implementation and running of a digital identity regulatory regime (the Digital
Identity Services Trust Framework).
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• The proposed legislation for this regime is currently before the house (The Digital Identity
Trust Framework Bil ).
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• The bill proposes a governance and compliance regime to ensure that those who are
providing digital identity services consistently meet standards for using, storing and sharing
personal and organisational information.
• This wil provide people with assurance that they can trust New Zealand’s digital identity
ecosystem if they ask for, or consent to, their identity information being provided to firms or
agencies they are interacting with, where they need to prove who they are. It will establish
rules to protect the privacy and security of people’s information when it is shar
Information ed within the
trusted environment.
• The Bill creates a framework, which government agencies and private business will be able to
opt into, if they choose.
Official
• DIA have worked closely with Māori and iwi leader groups in developing policies which
informed the development of a busi
the ness case and the Digital Identity Services Trust
Framework.
• The implementation of the Trust Framework has been paused due to other competing
priorities. As such, work on t
under he implementation plan and further consultation with Māori and
iwi leader groups has also been paused. However, broader consultation on the Trust
Framework with Māori and other key stakeholders is ongoing.
• The second initiative led by DIA is called One Time Identity Check.
• This proposed new service under development is intended to provide a convenient way for
Released
people to prove who they are online.
• The project is in the Pilot phase. It works by enabling people to request that DIA confirm
their identity (against NZ Passport or NZ Driver Licence information) and share their
confirmed information with a service provider they are trying to access.
• Facial recognition wil be used by One Time Identity Check to undertake a one-to-one
comparison against existing databases to confirm the customer’s identity, with informed
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consent from the customer. DIA is not proposing to share photo images or facial recognition
algorithm with any other agency.
• Unlike the current RealMe service, customers wil not need to create an account to use this
service, but this will mean they will need to repeat the identity confirmation process each
time they need to prove who they are.
• As this initiative is in its early design and development engagement with Māori and other key
stakeholders is ongoing. No final decisions on design or implementation have been made at
this stage.
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Appendix B
Emails 5 to 7
From: Sarah Dickson‐Johansen <Sarah.Dickson‐[email address]>
Sent: Tuesday, 9 August 2022 1:32 pm
To: PlanningPerformanceandSupport <[email address]>
Subject: FW: DC‐182‐2022 NEC New Zealand event
Kia ora Team,
Is this something we could provide advice on?
Ngā mihi,
Sarah
From: PlanningPerformanceandSupport <[email address]>
Sent: Tuesday, 9 August 2022 1:37 pm
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To: Colin Holden <[email address]>
Subject: FW: DC‐182‐2022 NEC New Zealand event
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Kia ora Colin
Am I correct in thinking Digital Identity is under SSI now?
The Office require some advice on the Minister speaking at the beginning of the NEC New Zealand event that will
showcase innovation including work on Digital Identity which was spoken about at the recent Digital Trust Hui
Taumata.
Information
This is due to the Office by COP tomorrow.
Ngā mihi
Dylan Leney | Programme Coordinator, Digital Public Service Official
45 Pipitea Street, Wellington
Department of Internal Affairs Te Tari Taiwhenua
Mobile: 9(2)(a)
| www.dia.govt.nz
the
under
From: Colin Holden <[email address]>
Sent: Tuesday, 9 August 2022 4:51 pm
To: Cecily Lin <[email address]>
Subject: FW: DC‐182‐2022 NEC New Zealand event
Hi Cecily
Can you provide some advice on this? Note short timeframes!
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Ngā mihi
Colin
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Emails 9 & 10
From: Colin Holden <[email address]>
Sent: Wednesday, 10 August 2022 3:33 pm
To: Cecily Lin <[email address]>; PlanningPerformanceandSupport
<[email address]>
Cc: Mary‐Beth Kedzlie <Mary‐[email address]>; Prashil Reddy <[email address]>
Subject: RE: DC‐182‐2022 NEC New Zealand event
Thanks Cecily and Prashil
Dylan, I’m happy to provide this advice to the Minister’s Office.
Ngā mihi
Colin
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From:
PlanningPerformanceandSupport
Sent:
Wednesday, 10 August 2022 3:41 pm
To:
Sarah Dickson-Johansen
Act
Subject:
FW: DC-182-2022 NEC New Zealand event
Hi Sarah
Please see advice below.
Ngā mihi
Information
Dylan Leney | Programme Coordinator, Digital Public Service
45 Pipitea Street, Wellington
Department of Internal Affairs Te Tari Taiwhenua
Mobile: 9(2)(a)
| www.dia.govt.nz
Official
the
under
Released
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