8.2 Notice and Consent
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Title
Notice and Consent
Control
Section 4.2 requirement 3 requires the CSP provide explicit notice to the applicant at the time of collection regarding the purpose for collecting and maintaining a record of the attributes necessary for identity proofing, including whether such attributes are voluntary or mandatory in order to complete the identity proofing transactions, and the consequences for not providing the attributes.
An effective notice will take into account user experience design standards and research, and an assessment of privacy risks that may arise from the collection. Various factors should be considered, including incorrectly inferring that applicants understand why attributes are collected, that collected information may be combined with other data sources, etc. An effective notice is never only a pointer leading to a complex, legalistic privacy policy or general terms and conditions that applicants are unlikely to read or understand.