NCBF Implementation Details (Larry)

The National Marine Fisheries Service Policy Directive 32-110, "Use and Implementation of Electronic Signatures" outlines the following requirements for an approved electronic signature system:

Technical non-repudiation services
Legally binding the electronic transaction to an entity
Providing chain of custody audit trails
Providing an electronic receipt or acknowledgment of a successful submission
Collecting only necessary information in the electronic signature authentication process
Create a long-term retention and access policy
Periodic review and re-evaluation of the electronic signature process

This sections documents design details that address these requirements.

Binding the Transaction to an Entity and Non-repudiation

Requirements 1 and 2 above are addressed in the design of three component parts of the system:

identity assertion, person proofing, and registration
terms and conditions and signing ceremony
document binding and document integrity

The Hawaii Non-Commercial Bottomfish e-signature evaluation has concluded that OMB Assurance Level 1 (little or no confidence in the asserted identity) was appropriate for the Hawaii Longline Logbook. This was a considered decision justified by low likelyhood of occurrence, low impact of harm, emphasis on usability and public acceptance, and mitigating controls, including matching of the asserted identity with a specific fishing permit and the email address of record for that fishing permit. Note that the identity is established from association with a fishing permit holder, and not solely through the registration to submit logbooks electronically.

The proposed identity assertion, person proofing, and registration starts with a permit holder initiating an online registration process to establish username and password credentials for e-signature. The registration web application will guide the permit holder through choosing a username and password, entering their fishing permit number and email address, and entering a //en.wikipedia.org/wiki/Captcha string. The registration program will verify the CAPTCHA string (as a defense against automated attacks) and then confirm that the email address supplied matches the email address-of-record for the specified fishing permit. If these tests are passed, the program will generate an email message to this address-of-record. The email message will contain a URL link unique for this particular registration transaction. When the email message has been sent to the address-of-record, the registration program will explain to the permit holder that they must now follow further instructions which will be supplied via email to complete their registration. The permit holder should now access their email, read the registration message, and click on the unique link enclosed. When they click on the enclosed link, the registration program will recognize the unique key in the URL and will accept that unique key as confirmation that the permit holder does have control of the email address-of-record.
(See Identity Assertion, Person Proofing and Registration for a broader discussion of these issues and alternatives.)

Terms and conditions presented during registration and the signing ceremony contribute to binding the transaction to the entity and non-repudiation. (See terms and conditions and signing ceremony for a broader discussion of these issues and alternatives.) Terms and conditions specified during the registration process include the following statement on the paper form just above the required signature block:

Registration Terms and Conditions

Terms and conditions presented during the signing ceremony (when the vessel operator is submitting logbook data to NMFS) includes the following statement just above the required signature block:

Signing Ceremony Terms and Conditions

By typing my name in the indicated fields, I hereby certify that all of the information submitted in, and in support of, this application is true, accurate and complete. I am also agreeing to conduct business electronically with the National Oceanic and Atmospheric Administration in accordance with the Government Paperwork Elimination Act (GPEA) (P.L. 105-277, 44 U.S.C. 3504 note). I understand that transactions and/or signatures in records may not be denied legal effect solely because they are conducted, executed, or prepared in electronic form, and that if a law requires a record or signature to be in writing, an electronic record or signature satisfies that requirement. I further understand that false statements made knowingly and willfully on this application, including any documents submitted with or in support of this application, are punishable by fine and/or imprisonment under the provisions of 16 U.S.C. §1857 and 18 U.S.C. §1001.

The signer must make a willful act to demonstrate that they have read and agreed with the statement above. They must place a check mark in a check box that is labeled "I have read and understand the statement above." In addition to placing a check mark in the check box, the applicant must also type their password to complete the electronic signing ceremony. Attempting to proceed to the next step of the electronic transaction without completing the above steps will cause the system to display a message instructing the applicant that they must read the terms and conditions statement, and enter their password before their information will be accepted.

Technically the transaction data is bound to entity identity data by a shared identifier (permit number) in the registration data (electronic logbook agreement), the permit database, and in e-logbook submissions. (See document binding and integrity for a broader discussion of these issues and alternatives.)

The authentication tokens are username and password, and they are protected by Secure Socket Layer (SSL) transmission protocol. Technical controls for document integrity and audit trails contribute to binding the transaction to the entity and non-repudiation, but those controls are more appropriately discussed in the next section.

Providing Chain of Custody Audit Trails

NMFS policy directive 32-110 specifies "...audit trails that ensure the chain of custody for the transaction. These audit trails should identify the sending location, sending individual or entity, date and time stamp of receipt, and other measures that will ensure the integrity of the document. These audit trails must validate the integrity of the transaction and prove: (1) that the connection between the submitter and NMFS has not been tampered with; and (2) how the document was controlled upon receipt by NMFS."

The proposed design implements the following audit trail controls for submission of e-logbooks via the web:

Audit trail entries will be written for each registration submission, recording a timestamp, origin and destination IP addresses, username, permit number, email address-of-record... and generated email message.
Audit trail entries will be written upon request of the uniquely coded URL that indicates confirmation of control of the email address-of-record, recording a timestamp, origin and destination IP addresses, username, and the unique URL requested.
Audit trail entries will be written upon each e-signature transaction, recording a timestamp, origin and destination IP addresses, username, an e-signature transaction id, and the data submitted in the e-logbook entry which is being signed.
A receipt page will be displayed to the permit holder after each e-signature transaction, and a copy of the receipt will also be sent via email to the permit holder's email address-of-record. (See more detail in the Receipt section below.)
Audit trail entries will be written to log the processing of the e-logbook entry and generation of the e-signature transaction id and display and emailing of the receipt.

These audit trail data items should be written to audit trail tables by the web application using a database account which has insert privileges to the database but does not have update or delete privileges. (And update and delete privileges on the audit trail tables should be carefully controlled by the database administrator.)

Providing an Electronic Receipt or Acknowledgment of a Successful Submission

Subsequent to each e-signature transaction, a receipt page will be displayed to the permit holder, and a copy of the receipt will also be sent via email to the permit holder's email address-of-record. The receipt will document the timestamp and the e-signature transaction id.

After the data import program has interpreted (or attempted to interpret) the submitted e-logbook data, the data import program writes a receipt file. The proposed receipt will consist of an exact recapitulation of the submitted data with the following additions:
1. a "messages" element will be added to the XML as a child element of the top level "LogbookReport" element
  1. the messages element will contain one or more messages documenting success or failure(s) in the interpretation of the e-logbook submission; for example:
    - in the case of a successful data import one message would be returned which might look like:
      <messages>
      <message msgid="1000" severity_code="I" severity_desc="INFO">Ok</message>
      </messages>
    - in the case of a failed data import one or more messages would be returned to explain the failure which might look like:
      <messages>
      <message msgid="1179" severity_code="E" severity_desc="ERROR">Line 1 49 is not a recognized gear code</message>
      </messages>
2. for each element in the returned XML which consists of a code, for example, gear code, the XML schema will provide an optional attribute for a name; when the XML is submitted from the vessel these optional attributes will not be present (and if they are present they will be ignored); when the XML is returned from the agency as a receipt, these optional attributes will be populated by the agency to indicate that the code was recognized and to confirm what the code represents; for example:
  - incoming XML markup for gear may look like <gear>91</gear>
  - outgoing (receipt) XML markup for gear may look like <gear name="Pot">91</gear>
The receipt file will be written back onto the portable media if that media is to be returned to the vessel operator
Assuming that the data import was successful, or at least successful enough that the e-logbook's permit could be ascertained, the receipt file will also be emailed directly by the data import program to the address of record for the permit holder
1. The XML file will be an attachment to the receipt email message; the body of the receipt message will contain a synopsis of any "messages" elements contained in the receipt.
If the receipt file cannot be emailed directly to the address of record for the permit holder the operator executing the data import program is notified so that they can take steps to inform the submitter

Collecting Only Necessary Information in the Electronic Signature Authentication Process

Since the proposed system relies heavily on mitigating controls, no additional information is collected specifically for the e-signature process.

Create a Long-Term Retention and Access Policy

Retention and access policies already exist for logbook data. Electronic data submission does add audit trail data to the mix. The existing retention and access policies will be revised to accommodate electronic submission audit trail data and protect that data from delete or update access.

Periodic Review and Re-Evaluation of the Electronic Signature Process

The proposed e-signature system should be reviewed annually for several years, as this technology is unfamiliar to the agency and our customers and we expect to learn from experience.