By Chuck Wilson, Content Proposal Manager – Identity Solutions, USA Region
While the debate about necessity and validity of municipal identity credentials is becoming a polarizing political issue, there is an unmet civil need for access to services offered by local municipalities. Regardless with which side of the political divide one may associate, there is no denying that a non- secure or vulnerable credential solution exposes the community it is supposed to serve and protect to fraud and abuse. However, this is a self-inflicted risk that can be easily mitigated by following some of the credentialing best practices developed and already adopted by larger state and federal government agencies to protect its citizens/residents.
Most cities have a portion of their population that is undocumented or under-documented, including immigrants, homeless, foster youth, ex-inmates, and the non-driving elderly. Without a government-issued ID, many people face severe barriers in seeking healthcare, opening a bank account, applying for public benefits, or even collecting a package from the U.S. Post Office, etc. Many people without IDs are wary about interacting with police to seek help or to report a crime. Some cities have addressed these issues with a municipal card that helps break down these barriers and readily provides access to the city services. There are four key tenets that drive and sustain the impact of these card programs:
1) Inclusiveness – This means providing the municipal services cards to everyone in the city who wants one, as well as giving everyone reasons to want one. While providing municipal services cards are a strong symbol of welcome to those marginalized in the community, their value increases significantly when they are carried by mainstream residents. Appealing to a broad cross-section of the municipality improves the value of the cards and lessens the risk of creating a negative perception of the cardholders.
2) Confidentiality – This means protection of the Personal Identifiable Information (PII) of the cardholders. This is done in two ways: first, by reviewing, but not retaining any application (breeder) documents and applicant data; and second, by protecting the facial image and other identity data. Maintaining photo images for facial recognition analysis is a key mechanism to combat fraud and abuse; but that data must remain protected and confidential to the extent permitted by law.
3) Sustainability – Successful, long-term municipal card programs must be low-cost and securely issued to remove fraud and abuse. The central issuance solution accomplishes these goals, by producing credentials in a secure card facility with the most technologically advanced equipment. On-site, over-the-counter (OTC) equipment is more prone to obsolescence, and requires onsite card inventories with their security challenges and potential for abuse. OTC solutions cannot match the heightened level and variety of security features available in a centrally-issued card. The latter enables cards to be mailed to individuals, to the city, or to an alternative address, such as a shelter. An added advantage in cases of potential fraud is removing the decision to issue a card from the city clerks.
4) Networkability – The card utility increases as additional services are tied to it, such as use as a library card, transit, or access to community cultural venues and events, such as festivals, fairs, expos and other city-sponsored functions.
1. Develop the program as one’s official municipal card. This can be accomplished legislatively, or via an executive order giving the card a statutory framework and establishing the legitimacy of the credential. There are four key steps in developing the program:
a. Get community input before establishing the purpose and uses of the card, and in striving to improve it. Community involvement improves constituency buy-in, and it increases enrollment. Partnering with local retailers is an example of providing additional value to drive enrollment, including those citizens who do have access to other government-issued IDs.
b. Ensure that all municipal agencies accept the card as proof of identity and city residency; the card should bear the city seal or other clear municipal identifier.
c. Involve law enforcement early in the process, especially in the training to authenticate the card.
d. Produce a Policies and Procedures Document, vetted by legal counsel, that governs the application for and the issuance of the municipal services card. This provides an accountability mechanism and helps ensure no conflict with state and federal laws.
2. Enable a broad and flexible list of breeder documents to be used to prove identity and residency
a. The list of approved documents is a city-centric decision, since every municipality is different. A comprehensive list depends on the community it is serving and the individuals’ access to records.
b. Not all breeder documents are equal. Some cities use a menu method where the applicant provides a document from Group A and one from Group B. Others, such as New York City, use a point system similar to some DMV jurisdictions.
3. Ensure strong anti-fraud card security. There are two considerations here: (a) Card Design and (b) Card Authentication.
a. Card Design – There are an array of available security features that can be designed into a card, especially with central issuance, rendering the municipal card virtually impossible to counterfeit. Reputable card companies are fully in alignment with the security guidance of the American Association of Motor Vehicle Administrators (AAMVA) which has become the pseudo standard for securing identity credentials in the United States.
b. Card Authentication – As important as is a highly secure card, it is crucial for law enforcement to be able to quickly ascertain the legitimacy of a municipal card via a combination of tactile features, security marks, and / or the use of an infrared or ultraviolet filtered flashlight.
4. Keep the cardholder’s data private. This is accomplished in several ways:
a. Prohibit the retention of breeder application documents, reinforced with emphasis during the staff training. The cost of retention of these documents exceeds any derived value.
b. Limit the retention of PII to only essential items such as a photo image; and retained only as long as the cardholder is enrolled in the system.
c. Enable each cardholder to self-attest to his or her gender.
d. Enable cardholders to provide alternative addresses to prove residency and to receive their cards. This is especially true for the homeless or survivors of a domestic violence.
e. Delete any data at the card personalization factory which is used to produce and deliver the card credentials, including the cardholder’s address.
5. Enable the municipal card with multi-purpose uses in mind. Single-purpose cards are rarely successful over time. However, expanding the benefits of a municipal services card significantly by adding various benefits and incentives broadens its appeal, and makes it more attractive for everyone. Some examples include:
a. Using the municipal ID as a local library card.
b. Providing access to bus or train services, in partnership with local transit.
c. Using the card to provide access to cultural venues such as municipal parks, festivals, museums or recreation centers.
d. As a key for prescription drug discounts at participating drug stores.
e. Offering local business discounts, including restaurants, grocers, clothing stores, department stores, etc.
f. Developing partnerships with financial institutions to broaden services for cardholders, including opening accounts.
g. Identifying allergies or medical conditions on the card.
h. Providing proof of intent as an organ donor.
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