License 1: Attestation Officer Professional License

The one professional license that will be required before all others is the Attestation Officer Professional License

Attestation Officers are responsible for what in traditional PKI terms would be called “registration authority” functions, the process of receiving evidence of a subject's (individual's) claim of identity, judging its reliability, and, when warranted, submitting a Certificate Signing Request to the City of Osmio Vital Records Department. The CSR may or may not include the evidence, depending upon the type of enrollment.

An Attestation Officer must be able to apply not just the public authority of the City of Osmio to certification processes, but also the public authority of the physical jurisdiction where they practice. That means they must be a duly commissioned notary public, a consular official, a notary signing agent, or a justice of the peace. By Osmio's standards all Attestation Officers are holders of a notarial office or other public office that empowers them to administer oaths.

However, not all enrollments are notarial. Self-service online enrollments that do not carry the “Digital Birth Certificate” designation do not involve an oath and affidavit. Instead, the registration authority is the automated routine that uses SMS and email validation checks for a lower Enrollment Quality (Metric #2) score.

Within self-service enrollments and Digital Birth Certificate enrollments, procedures calling for differing levels of rigor and different technology are available, depending upon the needs of both subject and subject's relying parties. And so Attestation Officers must be able to perform a number of different procedures.

The City of Osmio Professional Licensing Board qualifies individuals who have held public office (such as notaries or justices of the peace) for a requisite amount of time and who meet other standards, and commission them as Attestation Officers for the Vital Records Department.

The Professional Licensing Board is also responsible for qualifying and commissioning other professionals, including architects, contractors, building inspectors, highway officials, and city planners.

What Do We Need in an Attestation Officer?

A candidate for Attestation Officer must exhibit 10 distinct attributes. (The first two are those noted above, easily obtained in the U.S. and many other common law countries by being commissioned as a notary public.) The 10 are:

  • 1. Criminal liability for malfeasance as a public official.

    Authority to administer an oath that places the affiant under penalty of perjury in such a manner that the act cannot be subsequently repudiated.

    • Established background of service with integrity in an attestation profession.
    • Ability to visually verify identity credentials (driver’s license or passport).
    • Ability to operate authentication and enrollment equipment.
    • Ability to perform the corroboration interview.
    • Ability to say “no” when required.
    • Ability to use the Certificate Signing Request system.
    • Willingness and sufficient insurability to assume liability.
    • Sufficient management sense to run an independent professional practice.

Let’s look at the additional qualifications one by one.

Established background of service with integrity in an attestation profession

In the Latin law countries we find an ideal benchmark for this qualification. The benchmark is an office called the Latin or civil notary.

To begin with, Latin or civil notaries are lawyers. But they are extensively trained in a kind of practice of law that is unfamiliar to most Americans — a practice where it is assumed that the public interest is served by ensuring that contracts are made in such a way that the likelihood of subsequent dispute and litigation between the parties is reduced.

Notaries in the non-Latin law jurisdictions are typically not lawyers. So in most of the United States, and the rest of the non-Latin-law world for that matter, we must build a whole new designation, inspired by the standards of the UINL and of its member organizations, particularly in common law jurisdictions.

The Source of Standards for Attestation Professionals

The principles of the Latin or civil notary profession constitute the starting point for our Public Authority Component. The standards for the new profession which we are instigating are based upon those of the Latin notary profession, which has been in the business of verifying identities not just for centuries but for millennia.

Since there are no Latin or civil notaries in most of the common law world, however, we must use the standards of that office as inspiration for the standards to be applied in the common law world.

Note that this is only the standards-setting part of the job. The actual qualification, training, commissioning, and supervision of the practitioners needs to be separate from the setting of standards. The latter is a matter of invoking public and NGO authority, while the former is a set of operating concerns.

The Osmio Professional Licensing Board concerns itself with most of the items on the list of qualifications of an attestation professional. In doing so, it goes country by country to evaluate the various attestation professions to see which designation in which jurisdiction can serve as a starting point.

A candidate does not have to be a notary (or hold another public office enabling them to administer oaths) in order to apply; however, such qualification must be obtained before the candidate is certified. Some specialized training also will be required. For example, while any notary ought to be able to do a fairly good job of checking ID documents, our enrollment professionals must be trained to perform that work at the highest level.

The third qualification will require the most work, because the attestation professions vary widely from country to country. What is the difference, for example, between a “certified paralegal” in the U.S. and a “clerk” in the U.K.? Every such designation in every jurisdiction must be evaluated.

Following is an outline of suggested Osmio Professional Licensing Board standards for Enrollment Officers in North America. The candidate for an Attestation Officer license must have:

Prior Professional Certification

  • Certification for Canada & US except Louisiana and Québec
    • Current Notary Public commission
  • In a jurisdiction with clear definition of legal consequences and penalties of malfeasance in office, or
  • In other jurisdictions, personal assets put into escrow to supplement bond
    • OR Current appointment as diplomatic officer authorized to administer oaths
    • PLUS one of the following additional credentials:
  • PACE Certified Paralegal with RP designation, two years’ continuous service in one law firm, no board actions
  • Signing Agent with two years’ experience AND 200 actions (e.g., mortgage closings) with no registered complaints or other contested acts
  • Attorney in good standing with no bar association actions or regulatory agency disciplinary actions
  • Registered Court Reporter with Registered Merit Reporter (RMR) or Registered Diplomate Reporter (RDR) certification
  • CPA in good standing with no CPA board actions or regulatory agency disciplinary actions
  • Current or retired diplomatic official (consul or above)
  • Five continuous years’ satisfactory service as INS employee; magistrate or clerk-magistrate; police office; administrator in Motor Vehicle Department, Birth/Death Records Department, Registry of Deeds PLUS passage of background check and Identity Verification Competency Examination
    • Current Notary Public commission with at least two years’ active practice and no board or regulatory agency actions, or attorney in good standing with no bar association actions or regulatory agency disciplinary actions, plus sponsorship by an authentication services organization

The last item, sponsorship by an authentication services organization, means that the candidate must be presented as a candidate for certification by an organization that actually provides authentication services, either directly or through licensees. It is anticipated that the candidate will be a prospective employee or licensee of that organization.

The rest of this material about Attestation Officers was copied and pasted from the Public Authority component specs, which appeared to be more complete.

Before they are sponsored, the authentication services organization will want to ensure that the candidate has all of the other qualities mentioned in our list, starting with one of those listed above and including

  1. Ability to perform a visual check of identification credentials (driver’s license or passport). They must not only have good eyesight, but also the kind of visual discernment that for instance an immigration officer must have.
  2. Ability to perform the corroboration interview. Questions about details of the candidate’s neighborhood, previous residences, previous employment, etc. will be presented on the screen along with multiple choice answers, both from a PII corroboration service such as IDology. This will trip up an impostor with the best of fake ID – unless he or she has thoroughly studied the background of the victim. The ability to discern when someone is acting is difficult to measure objectively, but an informal assessment of that ability is part of the process.
  3. For the higher enrollment quality procedures, the ability to operate authentication and enrollment equipment will be required. The equipment is basically a secure laptop computer with iris and fingerprint capture devices and a webcam with microphone.
  4. Ability to say “no” when required. This is a classic weakness of the notarial system. If a frail, elderly woman requests notarization of a document granting her son-in-law a blanket power of attorney, and this occurs in the presence of a large young man with a menacing aura who is glaring at her, the notary should ask questions before proceeding. More to the point, the notary must be prepared to decline to notarize if the answers are not satisfactory. Too often, however, the notary is too embarrassed or perhaps even intimidated by the situation to follow procedure. Our authentication professionals need to be able to look the candidate in the eye and tell her or him that they are not convinced of her or his identity and therefore cannot proceed.
  5. Ability to manage a portion of the CA system. With the system we are instigating, the registration authority is truly an integral part of the certification authority. A portion of a very important online database will be under their control.
  6. Willingness and sufficient insurability to assume liability. Insurance companies are a wonderful resource when these sorts of qualifications are to be evaluated. The meaningful part of a bond or E&O insurance policy is not so much the claims provisions of the policy as the fact that an insurance company has sufficient confidence in the situation to risk its money.
  7. Sufficient management sense to run an independent professional practice. The authentication professional will have plenty of support from the licensing organization. But he or she must still get to appointments on time, with equipment in good working order, and with the right type and quantity of blank smart cards, USB tokens, disks, etc.

In the language of PKI, the Attestation Officer is registration authority, and registration authority operator. While there is a reliable backup system to take over in the case of incapacity of an Attestation Officer, the process of managing the records on a day to day basis must be strictly by the book.

The Council of Attestation Officers

The existence of standards for those who issue credentials does not get the issuance done. After the standards are set, someone must qualify, recruit, train, equip, and supervise those who actually engage in the practice of enrollment. That is the job of the Council of Attestation Officers.

The charter of the Council of Attestation Officers is to manage enrollment assignments in such a manner that they can make a good living in this very important new profession. Only individuals who are recommended after passing qualifying examinations may be so licensed.

The Council of Attestation Officers will help the City of Osmio Vital Records Department select, train, equip, and license qualified individuals to examine evidence supporting a claim of identity either in a face-to-face notarial setting (they are all notaries with the Signing Officer designation or its equivalent) or via a remote out-of-band procedure; supervise the generation of key pairs; and issue certificate signing requests to the City of Osmio Vital Records Department. In addition, they may be asked by subjects to serve as trusted escrow agents for foundational keys and biometric data, and they may supervise the generation of chained certificates.