{"action":"opened","issue":{"url":"https://api.github.com/repos/usnistgov/800-63-3/issues/24","repository_url":"https://api.github.com/repos/usnistgov/800-63-3","labels_url":"https://api.github.com/repos/usnistgov/800-63-3/issues/24/labels{/name}","comments_url":"https://api.github.com/repos/usnistgov/800-63-3/issues/24/comments","events_url":"https://api.github.com/repos/usnistgov/800-63-3/issues/24/events","html_url":"https://github.com/usnistgov/800-63-3/issues/24","id":155787407,"number":24,"title":"IAL2 requires Trained Personnel and cannot be automated","user":{"login":"TerryMcBride","id":19349600,"avatar_url":"https://avatars.githubusercontent.com/u/19349600?v=3","gravatar_id":"","url":"https://api.github.com/users/TerryMcBride","html_url":"https://github.com/TerryMcBride","followers_url":"https://api.github.com/users/TerryMcBride/followers","following_url":"https://api.github.com/users/TerryMcBride/following{/other_user}","gists_url":"https://api.github.com/users/TerryMcBride/gists{/gist_id}","starred_url":"https://api.github.com/users/TerryMcBride/starred{/owner}{/repo}","subscriptions_url":"https://api.github.com/users/TerryMcBride/subscriptions","organizations_url":"https://api.github.com/users/TerryMcBride/orgs","repos_url":"https://api.github.com/users/TerryMcBride/repos","events_url":"https://api.github.com/users/TerryMcBride/events{/privacy}","received_events_url":"https://api.github.com/users/TerryMcBride/received_events","type":"User","site_admin":false},"labels":[],"state":"open","locked":false,"assignee":null,"milestone":null,"comments":0,"created_at":"2016-05-19T17:05:23Z","updated_at":"2016-05-19T17:05:23Z","closed_at":null,"body":"**Organization**: 1\r\n \r\n**Type**:\r\n \r\n**Reference (Include section and paragraph number)**: 800-63A, Section 5.2.2.1. Methods to Perform Identity Evidence Validation\r\n\"Strong\" row in the table\r\n \r\n**Comment (Include rationale for comment)**:\r\nIAL 2 requires at least on piece of Strong evidence.  The requirements for validating Strong evidence state:\r\n\r\n- The evidence has been confirmed as genuine by **trained personnel** and appropriate equipment, confirming the integrity of the physical security features OR The evidence has been confirmed as genuine by confirmation of the integrity of cryptographic security features.\r\nAND\r\n - All personal details and evidence details have been confirmed as valid by comparison with information held/published by the issuing source OR evidence details have been confirmed as valid by comparison with information held/published by the issuing source.\r\n\r\nAssuming the transaction is remote and the evidence doesn't include cryptographic security feature (which I think is safe to assume is the vast majority of cases), you are requiring a \"person\" to look at an image/video (video is a series of images).  \r\n\r\n**Suggested Change**:  Allow IAL 2 to be automated (no trained personnel required to look at each piece of Strong evidence).  \r\nAlso, I suggest that requiring agencies to receive and analyze images of identity documents is relatively prescriptive. It makes me wonder what evidence NIST has to drive all agencies to these technologies. \r\n \r\n---\r\n \r\nOrganization: 1 = Federal, 2 = Industry, 3 = Other \r\n\r\n"}}