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Introduction

Background

The aim of this work is to design an open Extended Customer Attribute (ECA) Standard to support the sharing additional customer data, which is not required under PSD2 nor the CMA Order, and which can be surfaced by ASPSPs and provided to relying parties on a commercial basis. This data can be used for a number of identity verification use cases and is of particular relevance to the UK government’s work (in particular the proposed trust framework for digital identity) as well as the OpenID Foundation’s eKYC & Identity Assurance work.

It has been agreed that a common, open ECA Standard such as that already developed by OBIE would be beneficial to support a number of use cases, providing clarity around the data elements, presentation of consent to the customer, and provision of this data to relying parties. The ECA Standard is modelled on the principles used the within the PSD2 customer journeys for TPPs, for example, gathering of consent and authentication at the ASPSP. The prototype journeys provided within this standard are designed to reflect ECA example journeys, some of which may sit outside the PSD2 framework. Certain journeys may demonstrate a combination of PSD2 and ECA data sharing in which case certain PSD2 principles will directly apply. Design of the standard needs to be inclusive and OBIE will ensure a wide range of participation in developing the ECA Standard so that it reflects views of both providing (ASPSPs) and relying parties (other entities and/or TPPs).

This ECA Standard is being developed on behalf of seven contributing members (the 6 largest UK ASPSPs plus TSB Bank). The scope will be limited to producing a standard based on extending the latest OBIE Standard (https://standards.openbanking.org.uk/) to meet the set of use cases as defined below.

This work is not covered by the activity defined by the CMA’s Revised Roadmap but is an area of interest to many participants and it is hoped that extending the OBIE Standard to cover such data will allow the ecosystem to continue to innovate and flourish.

Key design principles

A number of key design principles were agreed for the development of the ECA Standard, namely:

1. Developed as an initial draft to enable any participating firms to launch MVP or pilot activity.

2. Aligned to the emerging UK Government Trust Framework model, albeit not necessarily initially constrained by this (as it still being drafted).

3. Published under the MIT Open Licence to ensure it is free from IPR claims so that it can be submitted to other standard bodies without issue.

4. Will be submitted to OBIE for inclusion (as an optional/premium API) into the OBIE Standard.

5. Out of scope of the CMA Order, thus OBIE will not mandate implementation for the CMA9 (or any other firms).

6. Must be aligned to (i.e. not conflict nor contradict) PSD2/RTS, CMA Order, GDPR or any other relevant regulation.

7. Should not re-invent the wheel, so should re-use rather than replicate other relevant standards wherever possible.

8. Will generate value for people and small businesses and be designed to avoid harm.

The initial ECA Standard will thus focus on a set of (relatively) simple extensions to the current OBIE Standard and Trust Framework as follows:

1. Be based on the current OBIE API interaction flows and FAPI security profile.

2. Make use of the existing OBIE Directory, so that the APIs can be accessed by existing authorised TPPs, without the need for OBIE (or any other body) to create nor validate additional roles or scopes (e.g. Digital Identity Service Providers). Albeit this should not necessarily restrict access by other firms under contract with an ASPSP.

3. Initially focus on the provision (not consumption) of additional data (beyond CMA Order/PSD2 data) by ASPSPs.

4. However, this should be extensible (e.g. in a future version) to enable:

   1. data consumption by ASPSPs and potentially both provision and consumption by other data holders; and

   2. use cases which require access to data from multiple sources (e.g. bank accounts and government services).

5. Cover both personal and business accounts, in particular considering data attributes which relate to both:

   1. the authenticating user; and

   2. the owner(s) of the account.

   3. but perhaps leaving more complex multi-user accounts out of scope for now.

Use cases

The initial use cases have been prioritised based on the following considerations:

1. Do-ability: should be (relatively) easy for ASPSPs to build.

2. Market readiness: should meet one or more high priority, high value and/or high volume market needs.

3. Commercial value: should thus provide ASPSPs a strong commercial benefit (either directly or indirectly) which aligns to their commercial strategy/objectives.

4. Value for end users: use cases which help drive better outcomes and/or generate value for end (personal and business) users and/or bring broader societal benefits.

The following high level use cases have been identified as in scope for the initial ECA Standard:

Data model overview

To facilitate these use cases, the following data should be covered by the ECA Standard. This is further developed in the Attributes section below

For each of these data objects, we will also consider:

1. The date/time the field was last updated.

2. The level of assurance at the time of update (e.g. the method by which it was checked), however, this should be aligned to emerging standards in this regard (e.g. GPG 45).

3. Whether the data relates to:

   1. the authenticating user; or

   2. the owner(s) of the account.

4. Not all providers will have all of these fields.

5. The above list of fields is not exhaustive and may change as the project progresses.

Intellectual Property Rights (IPR)

As per key design principle #3, any work produced as a result of this activity will be published under an open licence and may be shared with and submitted to other standards bodies. Therefore any contributions to this work must be made with the understanding that there are no IPR associated with any such contributions and the contributor warrants that their contributions are free from any IPR claims.

All contributions are made in accordance with the IPR Policy set out below in Appendix 1.

Regulatory considerations (PSD2/GRPR)

The ECA standard and ECA customer journeys have been developed to replicate the design principles of the OBIE Standard. OBIE has used a design approach which leverages on the current PSD2 principles and overlays them to support the ECA use cases. It is important to note that while the principles of consent and authentication will feature in each of the use cases, they may not necessarily be underpinned by a relevant regulatory requirement under PSD2 as they may not be linked to a payment activity within the regulation. It is the sole responsibility of participants to consider applicable regulatory obligations and ensure that they have been appropriate met for any of the use cases they are engaging in. This is especially important in use cases which combine payment services under PSD2 and data sharing under ECA. Participants must also ensure that they meet any applicable regulatory obligations under GDPR in relation to processing personal data.

API Specification

The ECA Standard will use the specification that is under active development by the OpenID foundation eKYC & IDA Working Group, namely, the “OpenID for Identity Assurance” specification. There is an associated specification that will add support for legal entity use cases called “OpenID for authority”.

Advantages of this specification include:

• Developed under the OpenID Foundation

• Builds directly on OpenID and FAPI so is sufficiently secure for data sharing.

• A fairly simple technical extension to OpenID and FAPI

• FAPI provides for Relying Party identification and signing mechanisms

• Privacy preserving through requests for specific claims in any combination

• Provides access to attributes directly from the OpenID provider via OpenID ID Token or UserInfo endpoint

• OpenID with eKYC & IDA Supports most use cases

• Age verification is in roadmap for Q1 2021 as part of eKYC & IDA Implementers Draft 3

• Will support use cases for both personal and business use cases

• eKYC & IDA base spec is already in production for similar use cases elsewhere in the world

• Can support use cases that require data from multiple sources

• Verified claims are presented in a JWT so a plethora of libraries are available

The OpenID for Identity Assurance specification already supports a majority of the use cases defined in the ECA scope and will support the remaining in scope use cases in the future. The specification has also been developed in a way that means it is highly flexible with regard to use cases and can be readily extended with new attributes. It also allows requesting parties to be very specific about which attributes are required thus addressing data leakage and privacy concerns at a protocol level.

The specification (OpenID for Identity Assurance)

The work of the eKYC & IDA Working group is still underway and currently has an approved Implementers Draft 2 specification.

Implementers Draft 2 supports the following use cases that the ECA Standard is intended to support:

1. Onboarding

2. Ongoing validation or data sharing

3. Ecommerce

4. Authentication as a service

The roadmap for the eKYC & IDA specification includes an Implementers Draft 3 which is scheduled for Q1 2021 and currently includes the addition of age verification features and could also include registration of additional attributes required for the ECA Standard. Roadmap items for the eKYC & IDA spec that are of interest to the ECA Standard are:

• Attribute verification

• Support for legal entity use cases

• Conformance testing facilities

Data Model

In the context of the OpenID for Identity Assurance specification attributes can be used in a flexible fashion but there are a set of attributes in the specification that are going to be registered into the IANA JSON Web Token Registry to ensure consistent use internationally. It is appropriate for globally relevant attributes identified as part of the ECA Standard to be added to that set.

There is discussion on-going within and between various bodies about how interoperability can be achieved with respect to more localised attribute requirements. The OIDF, IANA, OIX and other stakeholders are considering this matter. One suggestion is registration of a UK specific profile that contains attributes that are only relevant in a UK context (such as national insurance number).

The data model for ECA is being developed with four attribute types:

1. Natural person attributes

2. Session attributes

3. Legal entity attributes

4. Verification attributes: attributes about the verification of the "verified attributes"

Attributes

Natural Person attributes

Session attributes

Legal entity attributes

Verification attributes

Note: there are a few time/date formats in use in this list of attributes

The first type are defined in OpenID Core 1.0 Section 2 as a JSON number representing the number of seconds from 1970-01-01T0:0:0Z as measured in UTC until the date/time.

The second is defined as in ISO 8601:2004 YYYY-MM-DDThh:mm[:ss]TZD format and if birthdate were presenet it would follow suit.

"time":"2021-01-02T18:25Z",

Use Case technical examples

Relying Party is any entity that is permitted to interact with a provider so could be an intermediary or end consumer of data attributes.

OpenID Provider is the entity that has data about the end user and will send it to the Relying Party when authorised to do so.

It is anticipated there will be a contractual arrangement between the relying party and the OpenID provider

The end User has an established relationship with the OpenID Provider but not necessarily with the Relying Party

Onboarding Use Case sequence diagram

Onboarding use case requires delivery of specific verified claims and specific verification metadata including some details of evidence used for verification of the end user and requests those claims to be delivered via the ID Token.

Open

Age Verification Use Case sequence diagram

Open

Note: Precise syntax for age verification request and response is actively being worked on by the OIDF eKYC & IDA Working Group and is unstable at the point of writing

Payment, Name and Address Use Case sequence diagram

Bank as attribute provider with multiple events

This example is as per the “Onboarding Use Case“ above from a sequence perspective but is intended to reflect a more current reality of the information that a bank may have available today and how the events that a customer may have been through could be reflected using the JSON schema defined within OpenID for IDA.

Customer Experience Guidelines (CEGs)

The following wireframes and prototypes, unlike other examples in the OBIE CEGs, are not not intended to be prescriptive but rather to: 

1. Act as a catalyst to help implementers (ASPSPs and Relying Parties) identify actual use cases

2. Help ensure the specification contains standardised data elements/claims which supports these use cases

3. Provide guidance for implementers in delivering consistent messaging and the right level of friction (e.g. not introducing unnecessary steps in the authentication flow)

No elements of these CEGs are mandatory and implementers are free to innovate.

Example 1: Age verification

In our first demo of innovative use cases for bank verified ID, the customer shares the minimum information which is necessary to verify their age via their ASPSP. A venue or merchant that requires age verification presents a QR code. The user scans the code to link to their mobile banking app, via search / menu of available providers. In this scenario the venue does not need the actual age or data of birth, the need only a binary response from the ASPSP that the customer is indeed over 21, for example.

View prototype

Example 2: Onboarding for a service

Onboarding journeys present the primary friction for users of online services and mobile apps. With the need for good anti-fraud measures onboarding can even become asynchronous while a human verifies uploaded documentation. Here the bank provides information to optimise sign-up, and good assurance of identity via their own login protocols, eg. biometric.

View prototype

Example 3: Secure login via QR code

In a non-cookied state, the ID provider uses registered bank account to offer a secure login journey. Embedded QR code instructions trigger an app-to-app redirect to the PSU’s mobile banking app.

View prototype

Example 4: Persistent login

Similar to Google suite, our third party ID provider is maintaining a persistent logged-in state, so access is frictionless.

View prototype

Example 5: Account sign-up with AIS

In this example, the merchant streamlines account onboarding and identity verification via a third party facility, including an AIS service for checking affordability. This reduces the need for manual user input and asynchronous verifications, including email and identification documents.

View prototype

Example 6: eCommerce checkout with PIS

Here the third party assurance provider streamlines a standard checkout, to reduce user friction and fraud, using a PISP to make the payment.

View prototype

Implementation considerations/risks

This ECA Standard does not include any Operational Guidelines, such as those included with the OBIE Standard.

In developing this ECA Standard, the authors have identified a number of risks which implementers should take into account, together with mitigating actions which can or should be considered.

These are documented here: https://openbanking.atlassian.net/wiki/pages/createpage.action?spaceKey=DZ&title=ECA%20Risk%20Log&linkCreation=true&fromPageId=2013888689

The ECA standard does not constitute legal advice. While certain aspects have been designed to relevant regulatory provisions and best practice, they are not a complete list of the regulatory or legal obligations that apply to ASPPSs and/or relying parties. Although intended to be consistent with regulations and laws, in the event of any conflict with such regulations and laws, those regulations and laws will take priority. ASPSPs and relying parties solely responsible for their own compliance with all regulations and laws that apply to them, including without limitation, PSRs, PSD2, GDPR and consumer protection laws. ASPSPs and Relying Parties that choose to implement the ECA Standard will need to assess for themselves their own risks and regulatory obligations prior to doing so.

Appendix 1: ECA Intellectual Property Rights Policy

This Extended Customer Attributes (“ECA”) Intellectual Property Rights Policy (“IPR Policy”) defines the intellectual property rights and obligations of Contributors (as defined below) in relation to Contributions (as defined below) proposed to Open Banking Limited (“OBL”) for the creation of Specifications. 

1. Definitions 

   1. “Contributions” mean any of the following, to the extent provided by a Contributor in connection with a Specification: (a) communications to or through a particular mailing list; (b) other communications provided at a face-to-face or video call working group meeting (without subsequent and timely objection by the putative Contributor); or (c) any other communications offered in any online collaboration tools selected by the applicable working group (e.g., Atlassian and other web-based collaboration platforms). 

   2. “Contributor” means, with regard to a particular working group, any person (individual, entity, or otherwise) who has joined such working group by requesting access or otherwise provided Contributions to OBL in connection with a Specification.  

   3. “Specification” means the draft and final versions and contents of API specifications including associated documentation and guidelines that have been deemed as such by the relevant working group. 

   4. “Implementation” means a product (e.g., but without limitation, hardware, software, or firmware) or service that consists of (or makes use of) a Specification or any Contributions.  

   5. “Implementer” means a person or other entity that creates, distributes, or offers a product or service that contains or makes use of a Specification. 

   6. “Intellectual Property Rights”  means patents, rights to inventions, copyright and related rights, moral rights, trade marks, business names and domain names, rights in get-up, goodwill and the right to sue for passing off, rights in designs, database rights, rights to use, and protect the confidentiality of, confidential information (including know-how) and all other intellectual property rights, in each case whether registered or unregistered and including all applications and rights to apply for and be granted, renewals or extensions of, and rights to claim priority from, such rights and all similar or equivalent rights or forms of protection which subsist or will subsist now or in the future in any part of the world. 

2. General 

   1. By making any Contribution to a Specification, Contributors agree to be bound by this IPR Policy. A Contributor may withdraw from a working group at any time and agrees to be bound by the terms of this IPR Policy in relation to any Contributions made prior to withdrawal. 

   2. No Contributor will incorporate any third party materials into any Contribution, unless it has all the rights and licenses necessary from such third party to submit such Contribution in accordance with the terms and conditions of this IPR Policy. 

3. Confidentiality 

   1. All Contributions, and other materials shared with OBL in connection with Specifications will be considered non-confidential information, regardless of any markings to the contrary included thereon or related thereto.

4. Intellectual Property Rights 

   1. To the extent that a Contribution is or may be subject to Intellectual Property Rights, the Contributor hereby grants a perpetual, irrevocable (except in case of breach of this license), non-exclusive, royalty-free, worldwide license in such Intellectual Property Rights to OBL, to other Contributors, and to Implementers, to reproduce, prepare derivative works from, distribute, perform, and display the Contribution and derivative works thereof for the of development and Implementation of Specifications. 

   2. Contributor represents that Contributions comprised of written submissions submitted by such a Contributor to OBL comply with any attribution requirements relating to third party content. 

   3. Subject to each Contributor’s rights in individual Contributions, the Intellectual Property Rights in any Specifications will be the property of OBL and published open source under the Open Licence defined at https://www.openbanking.org.uk/open-licence/.  Each Contributor will execute and deliver such instruments and take such other actions as and when OBL may reasonably request to perfect or protect its Intellectual Property Rights in the Specifications to enable it to publish them open source. 

   4. Each Contributor hereby irrevocably promises not to assert any claim against any other entity (whether OBL, a Contributor, an Implementer or otherwise) for making, using, selling, offering for sale, importing, or distributing any Implementation or offering any product or service to the extent it contains or uses a Specification and/or any Contributions.