|Type of consultation||Green paper|
|Deadline for comments||31/08/2022|
About the consultation
consultation seeks to identify the perceived barriers to financial services businesses adopting Digital ID Systems to assist in meeting customer due diligence requirements.
Digital ID Systems are defined by the Financial Action Task Force (FATF) as systems that use "electronic means to assert and prove a person's official identity online (digital) and/or in person environments at various assurance levels".
The consultation, which is being run jointly with the Jersey Financial Services Commission, also seeks to identify potential options to remove the perceived barriers and facilitate adoption of digital ID systems by financial services businesses.
To determine the future direction of travel, we are seeking industry views on three options, which are further described in the consultation document:
- Option 1: Further clarity around the existing regime
- Option 2: Establishment of a digital ID accreditation framework for Digital ID Systems/System providers
- Option 3: Creation of a new class of business/activity within Jersey's legislative regime whereby Digital ID System Providers become Supervised Persons and subject to supervision by the JFSC or another regulatory body
A further option, which will not be explored in detail in this consultation, is exploring the development of a shared know your customer utility - a centralised platform where customer identification and verification can be performed once for a customer, rather than several times by different Supervised Persons. In 2020, a JFSC report determined that, although there was scope for such a tool, there was insufficient willingness at the time on the part of branch and subsidiary structures in Jersey to invest in a Jersey-specific process which might be at variance from a globally emerging group approach.
We consider it unlikely that this position has yet changed and note the growing market of Digital ID System providers with proven products in the private sector. We are inviting comments on this view within this consultation.
Consultation Paper: The adoption of Digital ID Systems
How to submit comments to the consultation
To respond, review the consultation paper, which contains further information and a list of the questions to which we are seeking responses.
Then respond by email to email@example.com with a subject line of "Digital ID", including whether you give permission for your comments to be quoted and, if so, whether they should be attributed or anonymous.
How we will use your information
The information you provide will be processed in accordance with the Data Protection (Jersey) Law 2018 for the purposes of this consultation. Both the Government of Jersey and the Jersey Financial
Services Commission will, for the purposes of this consultation, be data
controllers, as defined under the DP(J)L. For more information, please read our privacy notice,
which is Annex C on p19 of the consultation document.
The Government of Jersey may quote or publish responses to this consultation, but will not publish the name and addresses of individuals without consent. Types of publishing may include, for example, sending to other interested parties on request, sending to the Scrutiny Office, quoting in a published report, reporting in the media, publishing on the Government website, and listing on a consultation summary. Confidential responses will still be included in any summary of statistical information received and views expressed.
Under the Freedom of Information (Jersey) Law 2011, information submitted to this consultation may be released if a Freedom of Information request requires it, but no personal data may be released.
Jersey Finance Limited is coordinating an industry response that will incorporate any matters raised by local businesses.
Comments should be submitted to JFL by 31 August 2022. Jersey Finance will upon request anonymise the response they provide to Government and the JFSC.
To contribute to the industry response, contact Nathalie Andersson, Strategy and Research Manager at JFL:
- email: firstname.lastname@example.org
- telephone: +44 (0) 1534 836019
- write to:
Nathalie Andersson, Strategy and Research Manager
Jersey Finance Limited
4th Floor, Sir Walter Raleigh House