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Design Age Assurance for Accessibility and Inclusivity

February 13, 2023

Mark Roberts, our California-based Chief Technical Strategist, considers concerns about how to ensure age assurance is accessible and inclusive.

One of the concerns raised frequently in the debate about age assurance is that it could lead to the exclusion of some people, particularly those from minority populations, those with protected characteristics under equality laws, and poorer groups of the population.

Examples of potentially affected individuals or challenging situations include:

  1. Lacking Documentation: Refugees and asylum seekers without official IDs
  2. Digital Divide: Those without access to the latest tech devices may find themselves unable to scan their ID easily or properly
  3. Poor Connectivity: People residing in areas without a strong and consistent enough signal to complete age checks
  4. Discrimination: Artificial intelligence age estimation tools that are less accurate for some skin tones than others
  5. Visual Impairments: Selfie taking and AV technologies that rely on visual cues, such as captchas or images, to estimate age
  6. Cognitive Impairments: Some AV technologies may require a certain level of cognitive ability to complete
  7. Language Barriers: Some AV technologies may only be available in certain languages
  8. Cost: Some AV technologies may require payment which can create a financial barrier for some individuals

Listed below are some general responses to these concerns, followed by more specific answers to the particular concerns.

General responses

The most effective overall solution to address many of these concerns is interoperability.  Interoperability would allow a single age check to be re-used across multiple sites and services, without the need to unnecessarily repeat the checking process.  At present, if you happen to access a second website that shares an AV provider with an initial site where you already proved your age, you wouldn’t need to prove it again.  An interoperable solution extends this concept of verification re-use across competing AV tech providers and thus effectively across ALL of the websites with age assurance requirements.

The European Union has recently completed a successful project to prove the concept of interoperability. euCONSENT created dummy sites across 5 countries, accessed by 2000 adults and children, where they were able to re-use one check on the other sites.

With interoperability, the alternative technology variations and methods of age verification provided by competing AV providers become openly available to the various end users rather than just a smaller subset of verification methods coming from a single AV provider. The benefits this creates for accessibility and inclusivity is that a user need only find a single verification method that works for them to be able to have access to age-restricted areas of the internet.  If they need assistance in completing an age-check, it’s a one-off need, not an ongoing requirement.  Example #1: if someone was lucky enough to look much younger than their age, they need only find a teacher to vouch for them once to establish it without relying on estimation software.  Example #2: If access to wifi or a mobile data signal is a regular issue, they need only, as President Biden highlighted, park at McDonalds once to go through the AV process.

 

Specific answers

1. Lacking Documentation: Refugees and asylum seekers without official IDs

Age Estimation does not require any documentation at all.

Vouching allows for trusted professionals such as teachers or doctors to provide a reference for someone who can then be granted an age check.

2. Digital Divide: Those without access to the latest tech devices may find themselves unable to scan their ID easily or properly

Interoperability means that (1) a user need only manage to scan their ID once, so could potentially borrow a more sophisticated phone/tablet, and (2) that they can prove their age by a number of different means and then re-use that check method instead of one which requires the ID to be scanned.

Levels of age assurance – the rigor of the age check – tend to be somewhat lower for age assurance than digital identity checks, because the associated risks are lower.  So for most purposes, you would not need the very high level of age assurance that scanning a chip in a government issued document would provide.

3. Poor Connectivity: People residing in areas without a strong and consistent enough signal to complete age checks

Interoperability again means that once you’ve managed to do a check once, you can re-use it over and over, so you need not find a strong signal each time you need to access age restricted services.  You may need that for the initial check, but it would be unlikely the signal required is any more than is required to access the service you are trying to use itself.  So if the signal isn’t good enough to complete the age check, you’re unlikely to be able to use the website you’re trying to access.

4. Discrimination: Artificial intelligence age estimation tools that are less accurate for some skin tones than others

Ever-improving technology is eradicating any differences across skin tones.  Early experiments with artificial intelligence used very homogenous data – basically lots of white faces – and was then unsurprisingly only accurate when estimating age from similar faces.  The AV sector has learnt this lesson and now seeks diverse training data that reflects the population that will be relying on it.  International standards now place limits on the degree of difference that is permitted – it will never be zero without training the algorithms on every person in the world.

Most providers use a ‘waterfall’ of methods so if a user is not passed using estimation, they can easily try alternative ways to verify their age.  Where there are hard legal age requirements, estimation software has to allow for a ‘buffer’ of a few years to ensure that those who look old for their age do not pass as false positives – so many people around that legal age will need to find a different way to prove their age anyway, regardless of skin tone.

5. Visual Impairments: Selfie taking and AV technologies that rely on visual cues, such as captchas or images, to estimate age.

Alternative methods that do not rely on visual cues facilitated through interoperability, mean that people who cannot easily use one method should be able to find an alternative.  If they do need to use a method where they need assistance, the reusability of the check means that is not something they will need each time.

6. Cognitive Impairments: Some AV technologies may require a certain level of cognitive ability to complete.

The alternative methods of age assurance made available through interoperability should provide a number of clear-instruction/plain-language methods to complete a verification process. Alternative methods using the assistance of others would also be available for one-off needs.

7. Language barriers: Some AV technologies may only be available in certain languages.

AV technologies are already available in multiple languages to ensure that individuals with limited English proficiency can access online content. The coverage of language availability is continuing to expand rapidly and will also be aided by readily available AI translator services. All of the fallback one-off methods discussed above would also be available as needed.

8. Cost: Some AV technologies may require payment which can create a financial barrier for some individuals.

Some forms of age assurance are more expensive than others.  Online content providers joining an interoperable network may agree to contribute to a provider of last resort using a small share of revenues from the simple, cheaper forms of check.  Or the market may still offer these checks but at a premium which services may still be willing to pay in order to increase their customer base and audience.

Summary

Maintaining internet accessibility and inclusiveness is rightfully a top necessity for any new online technology, especially when the technologies are created to address legal requirements. As we advance toward the legal requirements of age assurance/verification in more and more territories, it is crucial that the technologies developed for the protections for our youth also incorporate AV interoperability such that 1) the general ease-of-use of the internet is maintained and 2) the present levels of accessibility and inclusiveness are not negatively affected.

 

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