Category Archives: Legal issues

Security-related legislation, government initiatives, court cases

Extending the requirements for traceability

A large chunk of my 2005 PhD thesis explained how “traceability” works; how we can attempt to establish “who did that?” on the Internet.

The basics are that you record an IP address and a timestamp; use the Regional Internet Registry records (RIPE, ARIN etc) to determine which ISP has been allocated the IP address; and then ask the ISP to use their internal records to determine which customer account was allocated the IP address at the relevant instant. All very simple in concept, but hung about — as the thesis explained — by considerable caveats as to whether the simple assumptions involved are actually true in a particular case.

One of the caveats concerned the use of Network Address Translation (NAT), whereby the IP addresses used by internal machines are mapped back and forth to external IP addresses that are visible on the global Internet. The most familiar NAT arrangement is that used by a great many home broadband users, who have one externally facing IP address, yet run multiple machines within the household.

Companies also use NAT. If they own sufficient IP addresses they may map one-to-one between internal and external addresses (usually for security reasons), or they may only have 4 or 8 external IP addresses, and will use some or all of them in parallel for dozens of internal machines.

Where NAT is in use, as my thesis explained, traceability becomes problematic because it is rare for the NAT equipment to generate logs to record the internal/external mapping, and even rarer for those logs to be preserved for any length of time. Without these logs, it is impossible to work out which internal user was responsible for the event being traced. However, in practice, all is not lost because law enforcement is usually able to use other clues to tell them which member of the household, or which employee, they wish to interview first.

Treating NAT with this degree of equanimity is no longer possible, and that’s because of the way in which the mobile telephone companies are providing Internet access.

The shortage of IPv4 addresses has meant that the mobile telcos have not been able to obtain huge blocks of address space to dish out one IP address per connected customer — the way in which ISPs have always worked. Instead, they are using relatively small address blocks and a NAT system, so that the same IP address is being simultaneously used by a large number of customers; often hundreds at a time.

This means that the only way in which they can offer a traceability service is if they are provided with an IP address and a timestamp AND ALSO with the TCP (or UDP) source port number. Without that source port value, the mobile firm can only narrow down the account being used to the extent that it must be one out of several hundred — and since those several hundred will have nothing in common, apart from their choice of phone company, law enforcement (or anyone else who cares) will be unable to go much further.

So, the lesson here is clear — if you are creating logs of activity for security purposes — because you might want to use the information to track someone down — then you must record not only the IP address, but also the source port number.

This will soon be a necessity not just for connections from mobile companies, but for many other Internet access providers as well — because of the expected rise of “Carrier Grade NAT” (or “Large Scale NAT“), as one way of staving off the advent of the different sort of world we will enter when we “run out” of IPv4 addresses — sometime in the next two or three years.

There is currently an “Internet Draft” (a document that might become an RFC one day) that sets out a number of other issues which arise when addresses are routinely shared … though the authors appear unaware that this isn’t something to worry about in 2011, but something that has already been happening for some time, and at considerable “scale”.

In my next article, I’ll discuss what this massive use of NAT means in practice when traceability leads you to a mobile phone user.

What does Detica detect?

There has been considerable interest in a recent announcement by Detica of “CView” which their press release claims is “a powerful tool to measure copyright infringement on the internet”. The press release continues by saying that it will provide “a measure of the total volume of unauthorised file sharing”.

Commentators have divided as to whether these claims are nonsense, or whether the system must be deeply intrusive. The main reason for this is that when peer-to-peer file sharing flows are encrypted, it is impossible for a passive observer to know what is being transferred.

I met with Detica last Friday, at their suggestion, to discuss what their system actually did (they’ve read some of my work on Phorm’s system, so meeting me was probably not entirely random). With their permission, I can now explain the basics of what they are actually doing. A more detailed account should appear at some later date.
Continue reading What does Detica detect?

apComms backs ISP cleanup activity

The All Party Parliamentary Communications Group (apComms) recently published their report into an inquiry entitled “Can we keep our hands off the net?”

They looked at a number of issues, from “network neutrality” to how best to deal with child sexual abuse images. Read the report for the all the details; in this post I’m just going to draw attention to one of the most interesting, and timely, recommendations:

51. We recommend that UK ISPs, through Ofcom, ISPA or another appropriate
organisation, immediately start the process of agreeing a voluntary code for
detection of, and effective dealing with, malware infected machines in the UK.
52. If this voluntary approach fails to yield results in a timely manner, then we further recommend that Ofcom unilaterally create such a code, and impose it upon the UK ISP industry on a statutory basis.

The problem is that although ISPs are pretty good these days at dealing with incoming badness (spam, DDoS attacks etc) they can be rather reluctant to deal with customers who are malware infected, and sending spam, DDoS attacks etc to other parts of the world.

From a “security economics” point of view this isn’t too surprising (as I and colleagues pointed out in a report to ENISA). Customers demand effective anti-spam, or they leave for another ISP. But talking to customers and holding their hand through a malware infection is expensive for the ISP, and customers may just leave if hassled, so the ISPs have limited incentives to take any action.

When markets fail to solve problems, then you regulate… and what apComms is recommending is that a self-regulatory solution be given a chance to work. We shall have to see whether the ISPs seize this chance, or if compulsion will be required.

This UK-focussed recommendation is not taking place in isolation, there’s been activity all over the world in the past few weeks — in Australia the ISPs are consulting on a Voluntary Code of Practice for Industry Self-regulation in the Area of e-Security, in the Netherlands the main ISPs have signed an “Anti-Botnet Treaty“, and in the US the main cable provider, Comcast, has announced that its “Constant Guard” programme will in future detect if their customer machines become members of a botnet.

ObDeclaration: I assisted apComms as a specialist adviser, but the decision on what they wished to recommend was theirs alone.

Static Consent and the Dynamic Web

Last week Facebook announced the end of regional networks for access control. The move makes sense: regional networks had no authentication so information available to them was easy to get with a fake account. Still, silently making millions of weakly-restricted profiles globally viewable raises some disturbing questions. If Terms of Service promise to only share data consistent with users’ privacy settings, but the available privacy settings change as features are added, what use are the terms as a legal contract? This is just one instance of a major problem for rapidly evolving web pages which rely on a static model of informed consent for data collection. Even “privacy fundamentalists” who are careful to read privacy policies and configure their privacy settings can’t be confident of their data’s future for three main reasons:

  • Functionality Changes: Web 2.0 sites add features constantly, usually with little warning or announcement. Users are almost always opted-in for fear that features won’t get noticed otherwise. Personal data is shared before users have any chance to opt out. Facebook has done this repeatedly, opting users in to NewsFeed, Beacon, Social Ads, and Public Search Listings. This has generated a few sizeable backlashes, but Facebook maintains that users must try new features in action before they can reasonably opt out.
  • Contractual Changes: Terms of Service documents can often be changed without notice, and users automatically agree to the new terms by continuing to use the service. In a study we’ll be publishing at WEIS next month evaluating 45 social networking sites, almost half don’t guarantee to announce changes to their privacy policies. Less than 10% of the sites commit to a mandatory notice period before implementing changes (typically a week or less). Realistically, at least 30 days are needed for fundamentalists to read the changes and cancel their accounts if they wish.
  • Ownership Changes: As reported in the excellent survey of web privacy practices by the KnowPrivacy project at UC Berkeley, the vast majority (over 90%) of sites explicitly reserve the right to share data with ‘affiliates’ subject only to the affiliate’s privacy policy. Affiliate is an ambiguous term but it includes at least  parent companies and their subsidiaries. If your favourite web site gets bought out by an international conglomerate, your data is transferred to the new owners who can instantly start using it under their own privacy policy. This isn’t an edge case, it’s a major loophole: websites are bought and sold all the time and for many startups acquisition is the business model.

For any of these reasons, the terms under which consent was given can be changed without warning. Safely disclosing personal data on the web thus requires continuously monitoring sites for new functionality, updated terms of service, or mergers, and instantaneously opting out if you are no longer comfortable. This is impossible even for privacy fundamentalists with an infinite amount of patience and legal knowledge, rendering the old paradigm of informed consent for data collection unworkable for Web 2.0.

How Privacy Fails: The Facebook Applications Debacle

I’ve been writing a lot about privacy in social networks, and sometimes the immediacy gets lost during the more theoretical debates. Recently though I’ve been investigating a massive privacy breach on Facebook’s application platform which serves as a sobering case study. Even to me, the extent of unauthorised data flow I found and the cold economic motivations keeping it going were surprising. Facebook’s application platform remains a disaster from a privacy standpoint, dampening one of the more compelling features of the network.

Continue reading How Privacy Fails: The Facebook Applications Debacle

Attack of the Zombie Photos

One of the defining features of Web 2.0 is user-uploaded content, specifically photos. I believe that photo-sharing has quietly been the killer application which has driven the mass adoption of social networks. Facebook alone hosts over 40 billion photos, over 200 per user, and receives over 25 million new photos each day. Hosting such a huge number of photos is an interesting engineering challenge. The dominant paradigm which has emerged is to host the main website from one server which handles user log-in and navigation, and host the images on separate special-purpose photo servers, usually on an external content-delivery network. The advantage is that the photo server is freed from maintaining any state. It simply serves its photos to any requester who knows the photo’s URL.

This setup combines the two classic forms of enforcing file permissions, access control lists and capabilities. The main website checks each request for a photo against an ACL, it then grants a capability to view a photo in the form of an obfuscated URL which can be sent to the photo-server. We wrote earlier about how it was possible to forge Facebook’s capability-URLs and gain unauthorised access to photos. Fortunately, this has been fixed and it appears that most sites use capability-URLs with enough randomness to be unforgeable. There’s another traditional problem with capability systems though: revocation. My colleagues Jonathan Anderson, Andrew Lewis, Frank Stajano and I ran a small experiment on 16 social-networking, blogging, and photo-sharing web sites and found that most failed to remove image files from their photo servers after they were deleted from the main web site. It’s often feared that once data is uploaded into “the cloud,” it’s impossible to tell how many backup copies may exist and where, and this provides clear proof that content delivery networks are a major problem for data remanence. Continue reading Attack of the Zombie Photos

The Curtain Opens on Facebook's Democracy Theatre

Last month we penned a highly-critical report of Facebook’s proposed terms of service and much-hyped “public review” process. We categorised them as “democracy theatre”, a publicity stunt intended to provide the appearance of community input without committing to real change. We included our report in Facebook’s official forum, and it was backed by the Open Rights Group as their official expert response as requested by Facebook. Last night, Facebook published their revised terms of service and unveiled their voting process, and our scepticism about the process has been confirmed. We’ve issued a press release summarising our opposition to the new terms.

Taking a look at the diff output from the revised terms, it’s clear that as we anticipated, no meaningful changes were made. All of the changes are superficial, in fact Section 2 is now slightly less clear and a few more shady definitions have been pushed to the back of the document. Facebook received hundreds of comments in addition to our report during the public review process, but their main response was a patronising FAQ document which dismissed user’s concerns as being merely misunderstandings of Facebook’s goodwill. Yet, Facebook still described their new terms as “reflecting comments from users and experts received during the 30-day comment period. ” We would challenge Facebook to point to a single revision which reflected a specific comment received.

The voting process is also problematic, as we predicted it would be. The new terms were announced and instantly put to a 7-day vote, hardly enough time to have a serious debate on the revised terms. Depending on your profile settings it can be quite hard to even find the voting interface. For some profiles it is prominently shown on one’s home page, for others it is hidden and can’t even be found through search. The voting interface was outsourced to a third-party developer called Wildfire Promotion Builder and has been frequently crashing in the first 12 hours of voting, despite a relatively low turnout (50,000 votes so far). This is particularly damning since the required quorum is 60 million votes over 7 days, meaning Facebook was unprepared technically to handle 1% of the required voting traffic.

The poorly done voting interface summarises the situation well. This process was never about democracy or openness, but about damage control from a major PR disaster. Truly opening the site up to user control is an interesting option and might be in Facebook’s long-term interest. They are also certainly within their rights as well to run their site as a dictatorship using the older, corporate-drafted terms of service. But it’s tough to swallow Facebook’s arrogant insistence that it’s engaging users, when it’s really doing no such thing.

Update, 24/04/2009: The vote ended yesterday. About 600,000 users voted, 0.3% of all users on the site and less than 1% of the required 30%. Over 25% of voters opposed the new terms of service, many of which can be interpreted as voting in protest. For Facebook, it was still a win, as they experienced mostly good press and have now had their new terms ratified.

Chip and PIN on Trial

The trial of Job v Halifax plc has been set down for April 30th at 1030 in the Nottingham County Court, 60 Canal Street, Nottingham NG1 7EJ. Alain Job is an immigrant from the Cameroon who has had the courage to sue his bank over phantom withdrawals from his account. The bank refused to refund the money, making the usual claim that its systems were secure. There’s a blog post on the cavalier way in which the Ombudsman dealt with his case. Alain’s case was covered briefly in Guardian in the run-up to a previous hearing; see also reports in Finextra here, here and (especially) here.

The trial should be interesting and I hope it’s widely reported. Whatever the outcome, it may have a significant effect on consumer protection in the UK. For years, financial regulators have been just as credulous about the banks’ claims to be in control of their information-security risk management as they were about the similar claims made in respect of their credit risk management (see our blog post on the ombudsman for more). It’s not clear how regulatory capture will (or can) be fixed in respect of credit risk, but it is just possible that a court could fix the consumer side of things. (This happened in the USA with the Judd case, as described in our submission to the review of the ombudsman service — see p 13.)

For further background reading, see blog posts on the technical failures of chip and PIN, the Jane Badger case, the McGaughey case and the failures of fraud reporting. Go back into the 1990s and we find the Halifax again as the complainant in R v Munden; John Munden was prosecuted for attempted fraud after complaining about phantom withdrawals. The Halifax couldn’t produce any evidence and he was acquitted.

A truly marvellous proof of a transaction

When you transact with an EMV payment card (a “Chip and PIN” card), typical UK operation is for the bank to exchange three authentication “cryptograms”. First comes the request from the card (the ARQC), then comes the response from the bank (the ARPC) and finally the transaction certificate (TC). The idea with the transaction certificate is that the card signs off on the correct completion of the protocol, having received the response from the bank and accepted it. The resulting TC is supposed to be a sort of “proof of transaction”, and because it certifies the completion of the entire transaction at a technical level, one can presume that both the money was deducted and the goods were handed over. In an offline transaction, one can ask the card to produce a TC straight away (no AQRC and ARPC), and depending on various risk management settings, it will normally do so. So, what can you do with a TC?

Well, the TC is sent off to the settlment and clearing system, along with millions of others, and there it sits in the transaction logs. These logs get validated as part of clearing and the MAC is checked (or it should be). In practice the checks may get deferred until there is a dispute over a transaction (i.e. a human complains). The downside is, if you don’t check all TCs, you can’t spot offline fraud in the chip and pin system. Should a concerned party dispute a transaction, the investigation team will pull the record, and use a special software tool to validate the TC – objective proof that the card was involved.

Another place the TC gets put is on your receipt. An unscientific poll of my wallet reveals 13 EMV receipts with TCs present (if you see a hex string like D3803D679B33F16E8 you’ve found it) and 7 without – 65% of my receipts have one. The idea is that the receipt can stand as a cryptographic record of the transaction, should the banks logs fail or somehow be munged.

But there is a bit of a problem: sometimes there isn’t enough space for all the data. It’s a common problem: Mr. Fermat had a truly marvellous proof of a proposition but it wouldn’t fit in the margin, and unfortunately while the cryptogram fits on the receipt, you can’t check a MAC without knowing the input data, and EMV terminal software developers have a pretty haphazard approach to including this on the receipts… after all, paper costs money!

Look at the following receipts. Cab-Inn Aarhus has the AID, the ATC and various other input goodies to the MAC (sorry if I’m losing you in EMV technicalities); Ted Baker has the TC, the CVMR, the TSI, TVR and IACs (but no ATC), and the Credit Agricole cash withdrawal has the TC and little else. One doesn’t want to be stuck like Andrew Wiles spending seven years guessing the input data! Only at one shop have I seen the entire data required on the receipt (including CID et al) and it was (bizarrely) from a receipt for a Big Mac at McDonalds!

Various POS receipts

Now in case of dispute one can brute force the missing data and guess up to missing 40 bits of data or so without undue difficulty. And there is much wrangling (indeed the subject of previous and current legal actions) about exactly what data should be provided, whether the card UDKs should be disclosed to both sides in a dispute, and generally what constitutes adequate proof.

A "fake" transaction certificate
A “fake” transaction certificate

But most worrying is something I observed last week, making a credit card purchase for internet access at an Airport: a fake transaction certificate. I can tell its a fake because it firstly its the wrong length, and secondly, it’s online — I only typed in my card number, and never plugged my card into a smartcard reader. Now I can only assume that some aesthetically minded developer decided that the online confirmation needed a transaction certificate so took any old hex field and just dumped it. It could be an innocent mistake. But whether or not the “margin was too small” to contain this TC, its a sad reflection on the state of proof in EMV when cryptographic data fields only appear for decorative purposes. Maybe some knowledgeable reader can shed some light on this?