7.2 RON Identity Verification, Recording, and Security

RON Identity Verification, Recording, and Security

In traditional notarization you confirm identity by personally knowing the signer or by inspecting an unexpired photo ID across the table. RON cannot rely on that physical inspection, so A.R.S. § 41-376 builds a layered identity-proofing process. Understanding the exact thresholds is heavily tested because the numbers are specific and easy to write wrong-answer options around.

Two Ways to Verify a Remote Signer

Under A.R.S. § 41-376(B), the notary may verify a remotely located individual's identity in one of two ways:

1. Personal knowledge — the notary already knows the signer well enough to be assured of their identity (same standard as in-person). If you truly have personal knowledge, the credential-analysis and KBA steps are not required.
2. The full identity-proofing stack — used for everyone else, and it has THREE parts that all must succeed:
   • Remote presentation of an unexpired government ID that constitutes satisfactory evidence of identity under A.R.S. § 41-311.
   • Credential analysis — an automated process run by a reputable third party that confirms the ID is genuine, checking security features, formatting, and signs of tampering, then extracting the data.
   • Identity proofing by dynamic knowledge-based authentication (KBA) — a quiz built from public and private data sources.

The Arizona KBA Rules (Memorize the Numbers)

Arizona's RON rules (Ariz. Admin. Code R2-12-1305) set precise KBA thresholds:

The figure students most often confuse is the passing score. With five questions, 80% means four of five correct. A wrong-answer option of "60%" or "three of five" is a classic distractor.

The Notary's Own Visual Comparison

Technology does not replace your judgment. Even after credential analysis and KBA pass, you must visually compare, in real time, the photograph and information on the credential against the person you see on camera (R2-12-1305). If the face does not match, or the signer seems coerced, confused, or unwilling, you refuse — exactly as you would in person. The 12-step screening (signer present, comprehends, proceeding willingly, identified) still governs RON; the camera simply replaces the table.

Recording the Session and What Goes in the Electronic Journal

Every RON act produces TWO permanent records:

• A tamper-evident electronic journal entry (A.R.S. § 41-374(A)) containing the date and time, a description and type of act, the full name and address of each person, the identity-verification method and results (but NOT the ID's serial number), and any fee charged. A RON act may never be logged in your paper journal.
• An audio-visual recording of the entire performance of the act (A.R.S. § 41-374(B)). The notary (or a person acting for the notary, typically the platform) creates it, and the notary must maintain a protected backup.

Retention: Five Years, Not Ten

This is the single most important correction to learn. Under A.R.S. § 41-374(D), the electronic journal AND the audio-visual recording must be retained for at least FIVE years after the date of the remote online notarial act. Some study materials and older summaries say ten years — that is incorrect for Arizona. The five-year RON retention mirrors the five-year retention for traditional paper journals, and both are public records under A.R.S. § 41-319. Expect a question that pairs the right concept (RON recording) with a wrong number (10 years) to test whether you actually know the statute.

Security and Fraud Considerations

A.R.S. § 41-374(C) and § 41-375 require the notary to take reasonable steps to protect the integrity, security, and authenticity of every RON act: keep the communication technology secure from unauthorized interception, protect the electronic seal from unauthorized use (you may never let another person use it), and back up both the journal and the recording. If the electronic seal or electronic journal is stolen, vandalized, lost, or used by another person, the notary must immediately notify the Secretary of State — and, for theft or vandalism, an appropriate law-enforcement agency as well.

Example: A signer in another state presents a driver's license over the RON platform. Credential analysis flags the ID as authentic, but on the KBA quiz the signer answers only 2 of 5 questions correctly within the 2-minute window — below the 80% threshold. Arizona rules allow one retake within 24 hours with at least 40% of the questions replaced; the signer scores 2 of 5 again. The signer has now failed twice and may not retry for 24 hours, so the notary cannot proceed and ends the session. Refusing here is correct: identity was never established to the statutory standard.