For many industries, companies often have to establish trust in digital identity verification solutions that can guarantee “the person claiming a particular identity is in fact the person to whom the identity was assigned.” But, this imposes strict requirements on the vendor that is managing personal information, including images of government-issued IDs, biometric and other personal information.
“Personal data shall be processed in a manner that ensures appropriate security of the personal data, including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organisational measures (‘integrity and confidentiality’).”
Beyond the secure handling of PII data, there are additional considerations when the outcome of that verification results in an “automatic refusal of an online credit application or e-recruiting practices.” Fully automated verification solutions that fail to give the data subject the right “to obtain human intervention on the part of the (data) controller, to express his or her point of view and to contest the decision” (Article 22(3) GDPR) are not allowed under GDPR.
1. Human Review
GDPR gives data subjects (i.e., your online customers) the right not to be subject to decisions solely based on automated processing that produce ‘legal effects’ or other significant effects. As increasingly more online verifications are carried out by algorithms, concerns have been raised about the lack of transparency behind the technology, which leaves individuals with little understanding of how decisions are made about them.
Since Jumio takes a hybrid approach to online identity verification, combining machine learning, AI, computer vision and biometrics, coupled with human review, we’re able to provide much greater transparency about the rationale for acceptance or rejection for any given identity verification transaction.
2. Machine Learning
With GDPR, vendors should deploy and train their AI models in a way that would prevent bias and potential discriminatory effects on the data subjects.
Jumio’s machine learning approach builds in prevention of bias and discrimination in the decision making process by continuous testing against those factors. Furthermore, Jumio incorporates data privacy and security at every stage of the machine learning workflow including initial data capture, ID preprocessing, data tagging, algorithm training and model deployment.
3. Data Retention
GDPR requires that personal data should be ‘limited to what is necessary for the purposes for which they are processed,’ and requires personal data storage being ‘limited to a strict minimum.’
Because Jumio is PCI-DSS compliant, we are already mandated to adhere to strict data retention procedures ensuring that personal data that is no longer needed is discarded appropriately and in a timely fashion. Our enterprise customers can customize data retention policies based on their unique business needs.
4. Breach Notification
GDPR requires data processors to notify the controller ‘without undue delay’ once aware of a data breach. Most identity verification vendors don’t have established or tested processes in place for data breach notifications.
Because Jumio is already PCI-DSS compliant, we regularly test our notification processes and procedures for dealing with data breaches. This ability helps our business customers manage their own breach notification and mitigation processes.
5. Data Encryption
GDPR requires data processors to have ‘appropriate’ measures to ensure security of personal data, including encryption, ensuring confidentiality, restoring data access and regular auditing/testing.
Because Jumio is PCI DSS Level 1 compliant, we regularly subject our security practices to stringent regulatory security audits, vulnerability scans and penetration tests to ensure compliance of the product. All personal data, including ID documents and selfies is encrypted twice: all data is encrypted in transit via TLS encryption using strong cipher suites and at rest with military-grade 256 bit AES encryption.
Jumio is not only fully GDPR compliant as a data processor, with a robust and transparent program for maintaining all standards laid out in GDPR, but also our identity verification solution is a key GDPR enabler, offering customers the ability to maintain data protection and contribute to their compliance with GDPR requirements.
GDPR categorizes data holders into two groups: processors and controllers.
There are additional required measures, processes and documentation requirements for controllers. Jumio is considered a data processor.
Moreover, Jumio is also PCI-DSS compliant. This means that we’ve adopted a strict set of security standards designed to ensure that identity and PII-related information are encrypted, stored and maintained in a secure and vetted environment.
Statement of Compliance
Jumio uses the European data privacy directives as the baseline for its data privacy compliance globally. Effective February 1, 2018 all necessary steps to achieve GDPR compliance have been completed. Jumio’s data privacy compliance program is applicable to all categories of personal data, including biometric data.