Rules of Use
The Equity Study on Remote Identity Proofing is administered by the U.S. General Services Administration (GSA) and the participating identity-proofing vendors. The study will test how one-to-one (1:1) remote identity-proofing methods like facial-verification technology perform across various demographics to determine if vendor identity verification capabilities meet equity standards across various demographics. This study will enable GSA to make a data-driven decision on whether to pursue facial verification capabilities, to determine baseline performance metrics, and to provide real-world identity verification pass rate data to the broader Federal community.
GSA will collect Personally Identifying Information (PII) during this study to verify your identity. This will include comparing a photo of your identity document with a live photograph of your face (a “selfie”). GSA will also collect demographic information from you.
These Rules of Use provide:
- Information on the Equity Study process and what you can expect from it,
- The terms under which you participate in the Equity Study,
- How GSA and its partners will use your information and your rights to that information, and
- The conditions that you agree to when you participate in the Equity Study.
Prior to participating in the Equity Study, you are required to agree to these Rules of Use.
By accepting these Rules of Use, you agree to participate in a study that will test the software of multiple Identity Proofing vendors. Specifically, this Equity Study will test the performance of document authentication, biometric comparison (comparing your selfie to the picture in your identity document), and liveness detection of the participating vendors. In addition, the study will assess vendor performance on the non-biometric aspects of the National Institute of Standards and Technology (NIST) SP 800-63-3 guidelines for remote identity proofing. This will allow for a more informed comparison of drop-off rates, i.e., to what extent a successful or unsuccessful identity verification is caused by either biometric or non-biometric aspects of the process.
You agree that:
- You are not a person under 18 years of age,
- Any information you provide to us is complete and accurate,
- The identity you claim when participating in the study is your own, and
- You will comply with applicable local, state, and federal laws during the study.
You further agree that you will NOT misrepresent your identity or any information you present in the Equity Study, including through participant support channels.
GSA will post any changes to these Rules of Use to [URL]. If the changes affect GSA’s handling of your personal information or are otherwise deemed significant, GSA will notify you by email. If GSA cannot reach you by email, GSA reserves the right to contact you by other means, including postal mail. If at any time prior to the completion of the study should you no longer agree to these Rules of Use, Privacy Act Statement, Consent Forms, Privacy Impact Assessment, or SORN, you may contact us at email@example.com or (202) 969-0772.
How will GSA use your information?
Table 1: Data collected by GSA and its uses
|Data Collected||Data Use|
|Demographic Information (self-reported race, ethnicity, gender, age, income, education, and skin tone)||Used to look for trends in identity proofing results.|
|Email Address||Used to share compensation details at the end of study and needed by the survey platform. If participants agree, GSA may also contact them via email for future studies.|
|Participant Name||Used to share compensation details at end of study|
|Images of Identity Document (front/back)||Used for the “document authentication” identity-proofing step and check that the identity document is legitimate.|
|Identity Document Machine Readable Zone information (barcode)||Used to verify that the identity document is legitimate.|
|Identity Document Number||Used to verify that the identity document is legitimate.|
|Identity Document Issue Date and Expiration Date||Used to verify that the identity document is valid.|
|Face reference (picture from Identity Document)||Used to verify that the identity document is legitimate, as well as the “biometric comparison” identity proofing step to compare the participant’s Face reference to their selfie.|
|First, Middle, and Last Name (from Document)||Used to verify the participants’ identity matches the identity document.|
|Date of Birth (from Document)||Used to verify the participants’ identity matches the identity document.|
|Sex/Gender (from document)||Used to verify the participants’ identity matches the identity document.|
|Address Street, City, State, Zip Code (from Document)||Used to verify the participants’ identity matches the identity document.|
|Live image of your face (or “Selfie”)||Used to verify that the Identification document belongs to the participant.|
|Participant-Asserted Address: Street, City, State, Zip Code||Used to verify that the participant is who they claim they are.|
|Participant-Asserted Social Security Number||Used to verify that the participant is who they claim they are.|
|Participant-Asserted Date of Birth||Used to verify that the participant is who they claim they are.|
|Participant-Asserted Phone Number||Used to verify that the participant is who they claim they are.|
|Phone Number matching the User identity||Used to verify that the participant is who they claim they are.|
|Unique Mobile Device Identifiers||Used to compute a risk assessment of the mobile device used by the participant to access the study.|
|IP Address||Used to compute a risk assessment of the mobile device used by the participant to access the study.|
|Device Geolocation (IP based)||Used to compute a risk assessment of the mobile device used by the participant to access the study.|
|Device-behavioral Information (how the device and its applications are used)||Used to compute a risk assessment of the mobile device used by the participant to access the study.|
|Identity Proofing Results||Used for determine demographic bias in data|
GSA will share a de-identified dataset containing aggregated demographic and identity-verification results with Clarkson University’s Center for Identification Technology Research (CITeR who will analyze the results and assist GSA in producing a peer-reviewed publication. To explain proofing failures, this publication (with your consent) may include images of the selfies and profile pictures from your identity document (any other PII in your identity document will be redacted).
As stated above, this publication will assist GSA in making more informed decisions regarding identity-verification capabilities. The outcome will also enable GSA to provide more equitable access to diverse populations that need to prove their identity to obtain government services.
GSA will be working with Rekrewt, a recruitment partner, to engage up to 4,000 participants residing in the US and US territories to participate in the study. Rekrewt will post advertisements in social media and assist GSA with building different outreach materials. Rekrewt will also manage participants’ compensation. To track compensation and ensure GSA meets the study’s demographic needs, Rekrewt will receive your name and email address along with an aggregated and de-identified demographic quota status.
GSA will use a licensed survey software, Qualtrics, to send you a survey asking for your demographic information (race, ethnicity, gender, age, income, and educational level). This information will help GSA understand if and how demographics impact the identity-proofing results of various remote identity-proofing solutions.
Survey responses are stored in the Qualtrics system for the purposes of managing quota requirements. GSA will also store the survey responses in a GSA-licensed Google Drive to correlate the demographic data with the identity-proofing results.
To track completion status, this system generates a unique ID for each participant. Upon completion of all study requirements, GSA will provide your name and email address to Rekrewt to complete the compensation process.
If you decide to terminate your participation after completing the demographics survey, GSA will retain the de-identified demographic information to study drop-off rates and the recruitment process.
Device Risk Information Collection
While you are using the study’s web-based platform, GSA will collect hardware and software data as well as device-behavioral information (how you use the device and its applications) for device risk detection from the personal mobile device you use to complete the study.
Vendor Performance of Identity Proofing Document Authentication and PII Validation
If eligible, you will also help GSA test multiple vendors’ document authentication software. You will go through an identity-proofing workflow that includes document authentication and PII validation.
The identity-proofing workflow collects the following personally identifiable information (PII):
- a picture of your identity document and attributes printed on the document,
- a picture of your face, and
- your Full Name, Social Security Number, Date of Birth, Phone Number, and Physical Address
GSA will direct all identity-proofing vendors to delete your data from their systems within 24 hours of collection. GSA will retain records of this study in accordance with GSA’s retention schedule for Customer Research and Reporting Records and any other applicable federal records schedules.
During document validation, you will provide information to GSA’s vendors so they may provide identity-verification services to GSA. Specifically, GSA will present unbranded capture screens for the identity-proofing vendors. Each vendor will collect information from you during the presentation of their designated screens, including a selfie, and validate the provided data. Vendors will transmit their results to GSA, and GSA will store those results on the GSA Google Drive.
During PII validation, you will provide information directly to GSA. GSA then shares that information with the applicable vendors for verification.
The final step is a security code check that ensures the device you used in the workflow is in your possession and owned by you.
All data collected by the identity-proofing vendors shall be deleted within 24 hours of the transaction with each vendor. PII deletion from vendors’ systems is achieved by different mechanisms, and ensured through a contractual requirement.
After the last step in the Equity Study, you will be redirected to a GSA-administered Qualtrics exit survey. The purpose of the exit survey is to gather usability feedback with the study. A copy of the exit survey results will be stored in the GSA Google Drive and Qualtrics.
Participation in the Equity Study is voluntary. If you do not consent to the Equity Study, you may not participate and no identifying information will be collected. Once your information is submitted at the conclusion of the exit survey, you may no longer terminate your participation. In any event, GSA will still protect your personal information consistent with GSA’s Privacy Act Statement and System of Record Notice.
Information collected through the Equity Study will be retained subject to GSA’s System of Records Notice, as amended. GSA will retain records of this study in accordance with GSA’s retention schedule for Customer Research and Reporting Records [PDF, 8 Pages] and any other applicable federal records schedules.
Service Operation and Customer Support
The Equity Study operates with a high standard of service, both in service delivery and customer support.
Availability and Uptime
Participant support is available through firstname.lastname@example.org or via voicemail at (202) 969-0772. When you request participant support, GSA will use any information you provide to address your question or comment, and may use your feedback to improve this or future studies or for other purposes as GSA sees fit. In doing so, GSA will never reveal your personal information outside of the Equity Study except as required by applicable law or as stated elsewhere in these Rules of Use.
Responsibilities of GSA’s Partners
Identity proofing vendors will collect data during the workflow and share results with GSA, and GSA will prohibit further access to data upon receipt. The identity-proofing vendors will delete this data within 24 hours of your identity proofing transaction. GSA will provide the Recruitment partner your email address and name for compensation purposes via Google products. All vendors are required to protect your information in compliance with federal law and policy.
In designing this study, GSA assessed each vendor, the type of data and level of access they require to render services, and all potential risks of both GSA and the vendor’s processes and applications. Based on these assessments, GSA entered agreements that minimize the data vendors receive while still accomplishing the goals of the study. For further information about GSA’s partners’ responsibilities see the Equity Study’s Privacy Act Statement.
You will not be charged any fees for your participation.
Representations, Warranties and Liabilities
Participation in the Equity Study does not create a contractual relationship between participants and GSA, nor between participants and GSA’s vendors. The Equity Study is provided “as is” and on an “as-available” basis. GSA and its vendors make no warranty that the study will be error free or that access thereto will be continuous or uninterrupted.
In no event will GSA or its vendors, provided they are acting within the scope of this agreement and in accordance with applicable Federal, State and local law, be liable with respect to any subject matter of this Agreement under any contract, negligence, strict liability or other legal or equitable theory for: (1) any special, incidental, or consequential damages; (2) the cost of procurement of substitute products or services; or (3) for interruption of use or loss or corruption of data.
You hereby warrant that (1) your participation in the Equity Study will be in strict accordance with these Rules of Use and all applicable laws and regulations, and (2) your participation in the Equity Study will not infringe or misappropriate the intellectual property rights of any third party.
These Rules of Use constitute the entire Agreement between GSA and you concerning the participation in the Equity Study, and may only be modified by the posting of a revised version on this page by GSA.
Any disputes arising out of this Agreement and access to or use of the services shall be governed by federal law.
No Waiver of Rights
GSA’s failure to exercise or enforce any right or provision of this Agreement shall not constitute waiver of such right or provision.
If you have questions about these Rules of Use or any other aspect of the Equity Study, you can contact us at email@example.com.