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2.2 Considerations, Other Requirements, and Flexibilities

NIST PIV and digital identity SP 800-63-3
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Title

Considerations, Other Requirements, and Flexibilities

Control

Agencies may employ other risk mitigation measures and compensating controls not specified herein. Agencies need to ensure that any mitigations and compensating controls do not degrade the selected assurance level’s intended security and privacy protections. Agencies may consider partitioning the functionality of a digital service to allow less sensitive functions to be available at a lower level of authentication and identity assurance.

Agencies may determine based on their risk analysis that additional measures are appropriate in certain contexts. In particular, privacy requirements and legal risks may lead agencies to determine that additional authentication measures or other process safeguards are appropriate. When developing digital authentication processes and systems, agencies should consult OMB Guidance for Implementing the Privacy Provisions of the E-Government Act of 2002 [ M-03-22 ] . See the Use of Electronic Signatures in Federal Organization Transactions [ ESIG ] for additional information on legal risks, especially those related to the need to 1) satisfy legal standards of proof and 2) prevent repudiation.

Additionally, federal agencies implementing these guidelines should adhere to their statutory responsibilities under the Federal Information Security Modernization Act (FISMA) of 2014, 44 U.S.C. § 3551 et seq., Public Law (P.L.) 113-283 [ FISMA ], and related NIST standards and guidelines. FISMA directs federal agencies to develop, document, and implement agency-wide programs to provide security for the information and systems that support the agency’s operations and assets. This includes the security authorization and accreditation (SA&A) of IT systems that support digital authentication. NIST recommends that non-federal entities implementing these guidelines follow equivalent standards to ensure the secure operations of their digital systems.