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From: Kennedy Luvai <kluvai@gmail.com>

Sent: Thursday, October 24, 2019 12:51 PM

To: privacyframework <privacyframework@nist.gov>

Subject: NIST Privacy Framework: Preliminary Draft Comments

NIST Team,

The Global Policy Working Group of the Sovrin Foundation appreciates the opportunity to offer a 

general comment with regard to the NIST Privacy Framework Preliminary Draft. The general 

comment is attached. 

Kennedy Luvai

208.863.0508
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

               

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

THE SOVRIN FOUNDATION GLOBAL POLICY WORKING GROUP’S RESPONSE TO

REQUEST FOR COMMENT TO THE DRAFT NIST PRIVACY FRAMEWORK

ABOUT THE SOVRIN FOUNDATION AND ITS GLOBAL POLICY WORKING GROUP

The Sovrin Foundation (the “Foundation”) is a private-sector, international nonprofit that

was established to govern the world’s first self-sovereign identity (SSI) network. The

purpose of the Foundation’s Global Policy Working Group (GPWG) is to research, formulate,

and recommend policies affecting the Sovrin infrastructure as a whole, in particular the

intersection between the unique capabilities of SSI, regulatory policies and civil laws

worldwide. This comment has been prepared and is being submitted by the GPWG.

Digital identity is one of the oldest and hardest problems on the internet. There is still no

way to use digital credentials to prove our online identity the same way we do in the offline

world. This is finally changing. First, the World Wide Web Consortium is standardizing the

format of digitally-signed credentials. Secondly, public blockchains can provide decentralized

registration and discovery of the public keys needed to verify digital signatures. These two

steps pave the way to establish a global public utility for self-sovereign identity

(SSI)—lifetime portable digital identity that uses multiple sources of formal and informal 

identification under the control and permission of the individual .

The Sovrin Network has been designed exclusively for this purpose, including governance

(the Sovrin Foundation and the Sovrin Governance Framework), scalability (validator and

observer nodes and state proofs), and accessibility (minimal cost and maximum

availability). Most importantly, Sovrin implements Privacy by Design on a global scale,

including pairwise pseudonymous identifiers, peer-to-peer private agents, and selective

disclosure of personal data using zero-knowledge proof cryptography.

GENERAL COMMENT REGARDING APPENDIX B: GLOSSARY

The GPWG appreciates the significant efforts and work undertaken by NIST and the various

stakeholders in developing the preliminary draft of the NIST Privacy Framework: A Tool for

Improving Privacy through Enterprise Risk Management (Privacy Framework). As an

international nonprofit organization that is governing a privacy-enhancing SSI network, the

Foundation has itself engaged in a cross-functional and cross-industry effort to develop

governance frameworks that have led to the development of a comprehensive glossary of

terms and their definitions: the Sovrin Glossary. The glossary is an official document of the

Sovrin Governance Framework, is approved by the Foundation’s Board of Trustees and

reflects ongoing efforts by the Foundation to provide clarity as to the terminology needed

across all dimensions of the Sovrin Governance Framework, including the business, legal,

and technical (“BLT”) layers. Accordingly, as NIST embarks on developing version 1.0 of the

Privacy Framework, the Foundation invites NIST to review and, as needed, rely on any

privacy-related definitions and concepts in the Sovrin Glossary as a resource with regard to

any further development of Appendix B: Glossary. It is hoped that in doing so, the risk of

inconsistent definitions in these widely-accepted glossaries will be minimized or even

eliminated.
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

CONCLUSION

The Foundation and the GPWG look forward to being a resource to help develop and provide

input to future NIST privacy-related initiatives.

MEMBERSHIP OF THE GPWG

Kennedy Luvai, Co-Chair

Jack Najarian, Co-Chair

Amos Doornbos, Co-Chair

Christopher Hempel

Dan Gisolfi

Joyce Searls

M Karamat

Drummond Reed

Joseph Cutler

Alan Davies

Aamir Abdullah

Drummond Reed

Nathan George

Bob Craig

George Simons

Neal Cohen

Robert Musiala

Mawaki Chango

Ramon Bernabeu

Diana Stern

Eric Welton

Heather Dahl

Karin Miller

Riley Hughes

Laura Jehl

Tammy Horn

GPWG CONTACT

Kennedy Luvai

kluvai@gmail.com

801-923-7308