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Organization Name (N/A, if individual): State of New York Organization Type (see below for codes): 5
Document (63-3, 63A, 63B, or 63C): 63-3
Reference (Include section and paragraph number): Appendix A.1 Definitions
Comment (Include rationale for comment): Current definition of "identity" needs improvement.
Suggested Change: “For these guidelines, digital identity is the unique representation of a subject engaged in an online transaction. A digital identity is always unique in the context of a digital service, but does not necessarily need to uniquely identify the subject in all contexts. In other words, accessing a digital service may not mean that the subject’s real-life identity is known.”
Suggested amendment, "a subject that engages in online transactions" rather than "a subject engaged in an online transaction" to convey the idea that the identity persists beyond the duration of each transaction.
Organization Name (N/A, if individual): State of New York
Organization Type (see below for codes): 5
Document (63-3, 63A, 63B, or 63C): 63-3
Reference (Include section and paragraph number): Appendix A.1 Definitions
Comment (Include rationale for comment): Current definition of "identity" needs improvement.
Suggested Change: “For these guidelines, digital identity is the unique representation of a subject engaged in an online transaction. A digital identity is always unique in the context of a digital service, but does not necessarily need to uniquely identify the subject in all contexts. In other words, accessing a digital service may not mean that the subject’s real-life identity is known.”
Organization Type: 1 = Federal, 2 = Industry, 3 = Academia, 4 = Self, 5 = Other
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