A Public Comment on NCCoE's White Paper on Privacy-Enhancing Identity Brokers

The National Cybersecurity Center of Excellence (NCCoE) (in the United States) has published on October 19, 2015, a white paper on "privacy-enhanced identity brokers." We present here a reply to their request for public comments. We enumerate concerns whose consideration we find paramount for the design of a privacy-enhancing identity brokering solution, for identification and authentication of citizens into myriad online services, and we recommend how to incorporate them into a revised white paper. Our observations, focused on privacy, security, auditability and forensics, are mostly based on a recently published research paper (PETS 2015) about two nation-scale brokered identification systems.