We provided a submission to the Digital Transformation Agency's (DTA) Digital Identity Legislation Position Paper on 16 July 2021.
In our submission we welcomed the release of the new Position Paper and thanked the DTA for taking the time to directly consult with DSPANZ on how Digital Identity will be used by Digital Service Providers (DSPs) in the lead up to its release. We also covered the following:
- The charging framework should be in line with the fee structures of existing providers to make costs affordable
- Recognising or adopting the Security Standard for Add-on Marketplaces (SSAM) for relying parties would help reduce regulatory burden for DSPs looking to participate in the system
- We support the interoperability principle but note that DSPs may have additional user verification requirements when acting as a relying party that are not covered by the TDIF specifications
- There is an opportunity to align the Trusted Digital Identity Framework (TDIF) with New Zealand's Digital Identity Trust Framework
- Users should be made aware that they need to create accounts with each identity provider as well as verifying all of their identity documents to prevent their identity from being compromised.
A full copy of this submission can be accessed here.