
Age-verification - a matter of informed choice
Filed under: Opinion, Second Life, Legal
As the fur continues to fly over Second Life's beta age-verification system, one of the aspects that has only really been lightly touched on is informed choice.
Before offering your identity documents and personal data to any third-party, there are things you need to know, otherwise you cannot be said to be capable of making an informed choice in the matter. So far, that information hasn't been comprehensively provided to you.
The provider for the verification service, we already know, is Aristotle/Integrity. According to their website the Integrity Direct verification service has verification data for 152 countries (out of a total of 194).
There doesn't seem to be information on which countries they don't have information for, but those missing 42 countries apparently account for 48.8% of the Earth's population, using Aristotle/Integrity's own figures.
You might reasonably point out that they say over 3.4 billion citizens. We reasonably point out that almost nobody says "over 3.4" if the number is 3.5 or more. Aristotle/Integrity repeatedly use "over 150 countries" when they mean 152. We feel it is reasonably to assume the true number of citizens in their database to be between 3.4 and 3.5 billion as, if they exceeded 3.5, they'd be saying "over 3.5 billion". You might also point out that many of those missing citizens are actually within the 152 countries - which then begs the question - why are some citizens included and others not?
Aristotle/Integrity claims to have some "government issued ID data" as a part of their database. Government authorities who have been contacted in the UK and Australia flatly denied that their passport and drivers license data was available to third parties, and seemed offended by the notion. We were cautioned against sending our identity data for verification - more on that in a minute.
It could well be that some of this data comes from public court records.
"Available data sets may include (1) full name, (2) full address, (3) year of birth, (4) phone number (when available) and (5) cell phone number (when available)."
The word "may" is fully reversible. You can also read this as "Available data sets may not include (1) full name, (2) full address, (3) year of birth, (4) phone number and (5) cell phone number" with equal validity. It doesn't sound half as good that way, though, does it?
Assuming they 'may not' have a full name, and a year of birth, then the rest of the claimed data is available by digesting phone directories, electronic listings of which are available from most countries for a reasonable fee.
So - they've got some data on some citizens in some countries. Maybe it's gleaned from the phone book. Maybe it's supplemented from public court records. Maybe they've bought some direct mail lists.
Citizens outside the USA have verified (in only small numbers to date) with a variety of correct and incorrect data. It appears that if your information at Aristotle/Integrity is incomplete, their system more or less takes a guess.
What do they do with the data you send them for verification? Well, they have a privacy policy.
"Personally identifiable information provided for purposes of age and identity verification to Aristotle and its Integrity unit is used only for that purpose, and is not transferred or retained, except as required by law." (our emphasis)
We've been told that they are sent for matching is archived in case USA law requires access to the data or for auditing purposes in the event of some dispute between Linden Lab and Aristotle/Integrity. Of course, your data is only one of (over) 3.4 billion database records. Probably nobody is interested in your data.
If you're in the European Union, your data is subject to the European Commission's Directive on Data Protection (1998). Your personal data cannot lawfully be transmitted to a non-European Union nation unless they comply with certain "adequacy" standards for privacy. In the USA that is implemented by the Safe Harbor framework.
Linden Lab isn't a participant, and even though they state quite firmly that they don't retain your personal data when performing a manual verification, it is quite likely unlawful to send it to them. You should check with your relevant local authorities if you are in any doubt.
Aristotle/Integrity, however, is a participant in the Safe Harbor framework, and even though the data for online verification is routed almost directly to them, it is possible for Linden lab to transparently record or intercept that data between their web-service and Aristotle/Integrity's.
We don't think for a moment that that is likely - but our opinion doesn't change what is or isn't. This is all about trust, and law, and you have to form your own opinion on the former, and find out about the latter.
Just as a side note, Aristotle/Integrity failed to answer the final question on their Safe Harbor information submission. When asked, "Do you agree to cooperate and comply with the European Data Protection Authorities?" Aristotle/Integrity failed to provide an answer.
Conveniently, though, there is a list of EU/EEA countries from which Aristotle/Integrity receives personal information: Cyprus, Finland, Hungary, Latvia, Malta, Portugal, Spain, Austria, Czech Republic, France, Iceland, Liechtenstein, Netherlands, Romania, Sweden, Belgium, Denmark, Germany, Ireland, Lithuania, Norway, Slovakia, United Kingdom, Bulgaria, Estonia, Greece, Italy, Luxembourg, Poland, and Slovenia.
The last thing you may need to consider is that - what, with the War on Terror running on overtime, and no end in sight - that it may be unlawful for citizens of other countries to send identification data such as passport numbers, drivers license numbers, national ID numbers, social-security numbers and so forth to foreign countries with or without the accompaniment of other identifying information.
Massively reader, Ryan Schultz has has contacted the Canadian authorities. Canadian Citizens are encouraged by the authorities to lodge complaints about any company (within Canada or without) who requests or requires these numbers.
Canadian readers can call:
SIN: 1-800-206-7218 (Option 3 for SIN)
Passport Canada: 1-800-567-6868
Whatever you do, you should make an informed choice, aware of your options, of what you are doing and whether your actions are lawful or unlawful. We at Massively aren't here to make decisions for you (sorry, but that service costs extra) - you have to do that yourself, but as we said at the beginning, you can only make an informed decision if you are properly informed. Regretfully, we believe that a user that is marked as successfully verified is no more necessarily linked to their true identity than an unverified user at this time. What you think, is up to you.
We have additional queries pending with Linden Lab about this matter. We will pass on further information as and when it becomes available to us.






Reader Comments (Page 1 of 1)
12-08-2007 @ 11:25AM
dandellion Kimban said...
That 152 countries versus 3.4 billion people puzzle can be solved... just suppose that china is not in their databases (quite reasonable presumption) and maybe they keep only data of over 18-years-old.
But it would be really interesting to know how did they got all those data from 152 countries. At least half of them wouldn't give citizen databases to some dubious company abroad.
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12-08-2007 @ 12:01PM
MikeG1 Schumann said...
Keep up the excellent research. Linden Lab needs to have their feet and other miscellaneous appendages held to the fire on this.
Meanwhile, we have declared (via covenant) all of the sims we own to be age-verification-free zones, and encourage other private estate owners to do the same.
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12-08-2007 @ 12:07PM
Daman Tenk said...
Let's hope more follow your example, MikeG1.
LL needs to realise the monstrosity they created here.
I STILL am a very big proponent of Verifying, but the way it is done is wrong.
"Hail for the New Second Life Order! Americans Only Beyond This Point!"
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12-08-2007 @ 1:09PM
dandellion Kimban said...
MikeG1, can you give us that part of the covenant or which estate is that so I can steal it :)
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12-09-2007 @ 8:59AM
Jamie Davis said...
Well the age verification system has a huge hole in it. Using google images and searching for Drivers License gives any 12 year old the path in.
It verifies the Dead and those dumb enough to give out personal data. Please see Mohamad Atta the terrorist and the image of his drivers lisence provided kindly by the Department of Homeland Security. Number, DOB and address. Yes Aristotle verifies him.
As to Canada the big issue is how did Aristotle get the populations Identities?
Jamie
"Do not give out personal information over the internet."
US States Attorney Generals number one gudeline.
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12-09-2007 @ 9:33AM
Jamie Davis said...
For listing of countries and what infor they require from them please see. http://www.aristotle.com/index.php?option=com_content&task=view&id=113&Itemid=145
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12-09-2007 @ 11:40AM
Ryan Schultz said...
I want to make it clear that I am *NOT* encourage Canadians to file official complaints until the system moves OUT of beta. At least on person that I know of already has, but there's no need to jump the gun here. But we need to make Linden Labs aware that their age-verification system is a total clusterfuck for Canadians.
It is not illegal for a third party to ask for a SIN, but I am quite concerned that those Canadians, who are not aware of Canada's privacy laws, will thoughtlessly supply numbers like the SIN, and thereby open themselves to identity theft.
I am not a lawyer, but according to Canada's Personal Information Protection and Electronic Documents Act at
http://www.privcom.gc.ca/information/02_05_d_08_e.asp
(Note the second point below, about how LL cannot refuse age-verification services if Canadians refuse to provide these sorts of ID):
-----
"The law [Canada's Personal Information Protection and Electronic
Documents Act] requires organizations to:
- obtain your consent when they collect, use or disclose your personal information [which, btw, INCLUDES YOUR AGE]
- supply you with a product or a service even if you refuse consent
for the collection, use or disclosure of your personal information
unless that information is essential to the transaction;
- collect information by fair and lawful means; and
- have personal information policies that are clear, understandable
and readily available. "
I am NOT against age verification, but I have very serious concerns about HOW Linden Labs is implementing this policy.
I now understand from the Age Verification FAQ that Linden Labs will now accept a scanned copy of a utility bill with my name and home address. That's the first reasonable request from them I've had, and I can certainly do that.
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12-10-2007 @ 5:29AM
Jamie David said...
My feeling is that we need to start asking questions now. Not about SecondLife but Aristotle and how they are claiming to have all our data as Canadian citizens. Something fundamentally wrong here. Aristotle claim to be able to verify Canadians and have on file out License numbers, Passport Numbers, SIN numbers as well as address, DOB and Name.
I find it very hard to believe that the government has handed this over. I do plan to call first thing Monday morning and follow it up with a good old snail mail. I want to know did the Government hand over this data? If so why? If not how can they allow a company to falsely claim so.
Many people are not as careful as they should be and are handing over their personal data. Trusting folk they are. This is going on right now as they are concerned that they will be kept out of something.
As a human in the modern world one has to be very careful. Canada is a trusting and safe environment and the citizens are not so aware of how identity theft and profiling are becoming common place. We have strict rules for privacy for a good reason to protect us.
So DO NOT VERYIFY as a canadian until this is all settled I doubt very much that it will remain now that a terrorist can Verify. To many holes to make it worthwile.
Do call and let our government and ask if Aristotle has the right to have out personal information on file and who provided it? Let them know that there is a company claiming to have all of our personal data. www.aristotle.com. We can not afford to sit back and let this just happen.
Re the sending in of a utility bill as proof of identity that is the most ridiculous thing I have heard of. Bad enough that one can use anothers identity now we can make it up. Photoshop and bingo we have a Utility bill in what ever name we want further invalidating the need to hand over real identity information.
Protect your identity as no one else will.
For those who want the verification. Search images.google.com for "Drivers License" and there is all that you need. Verify with out worry as LindenLab has no idea what ID was used and Aristotle doesn't care. They just want records that they can sell.
Please remember that this is all about protecting kids and giving users trust in their fellow residents. As it currently is it does neither.
12-09-2007 @ 10:41PM
Mike said...
dandellion, our sim covenants state, among other things:
"(2) No 'global' ban lines are permitted; you may ban individuals but you may not set an area to limit only specific people or group(s). The reason is that the ban lines are Ugly. You may not ban the Estate Owners or other residents of this sim or other sims managed by the Estate Owners."
Given that neither of the estate owners, nor the bulk of our residents, have submitted to being probed by Aristotle, we've made it clear that this forbids setting up AV bans. I'm happy to say that our residents are 100% behind us in this. We've got good residents.
(You can read our whole covenant by dropping by Second Mirage if you like).
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