in070337, Late Comment#1 received from John Eul on the 2nd Public Review of INCITS 420, Information technology - Biometric Profile - Interoperability and Data Interchange - Point-of-Sale Biometrics Based Verification and Identification. Public Review Period is from 1/12/2007 to 2/26/2007.

M1/07-0173

Mr. Eul’s Public Review Comment on Project 1575 INCITS 420 Biometric Profile Interoperability and Data Exchange Point- of-Sale

in070337

From: John Eul [mailto:jeul@att.net]
Sent: Tuesday, February 27, 2007 3:14 PM
To: Bennett, Barbara
Cc: psa@ansi.org
Subject: Public Comment on Project 1575 INCITS 420 Biometric Profile Interoperability and Data Exchange Point- of-Sale

Gentlemen:

I am John Eul the former Project Editor of Project 1575-D and as the former Project Editor I must take exception to the proposed change M1/06-1090 dated December 14, 2006. I do agree with the current Project Editor Mr. Douglas Buettner’s public comment of January 27, 2007and concur with him in his assessment of the proposed changes. The use of ANSI/X9 X9.84-2003 IS key to the use of this standard. The financial community will not support any standard for a financial transaction that does not subscribe to the use of ANSI/X9 X9.84-2003. Therefore this proposed change will render Project 1575-D Application Profile for Point-of-Sale Biometric Verification/Identification unworkable in the financial and retail communities it purports to address.

Therefore, again I concur with Mr. Buettner’s proposed change of January 27, 2007 as it follows:

POS use of biometrics shall follow the biometric data protection techniques provided in ANSI/X9 X9.84-2003 – “Biometric Information Management and Security for the Financial Services Industry” to safeguard the biometric data defined herein for the confidentiality, integrity and availability, in accordance with local, regional or national policy considerations.

Reinstate the normative reference to ANSI/X9 X9.84-2003 in clause 3.

Respectful,

John Eul

Former Project Editor

Project 1575-D