Memorandum by BT
INTRODUCTION
1. The Committee's inquiry is welcomed as
a means of taking stock of where we are on this important issue.
The Internet continues to grow in importance for individuals as
well as businesses. Unfortunately, it is a sad fact of life that
BT and others, including individuals, need to spend considerable
time and effort in devising ways to protect themselves, their
customers, their customers' information, and their assets from
fraudsters and pranksters.
2. As in so many similar situations, as
countermeasures develop so does the sophistication of those intent
on causing problems. It is a constant battle to stay ahead that
needs dedicated resources and a co-operative approach between
individuals, industry and Government.
3. However, it is important to retain a
sense of proportion. Existing laws are almost certainly adequate
to deal with most of the issues that arisethere is very
little that is actually new here, it is mainly just that today's
electronic communication channels offer a different way for the
issues to come to the fore. In any event, companies such as BT
are working very hard to implement protective measures and are
introducing new services, some applying automatically and some
to be used by customers if they wish, that provide increasingly
sophisticated protection. We are working both to protect our own
end consumers and with other businesses who use our services and
need themselves to help their customers.
4. Raising awareness of the issues leads
to greater understanding by customers about what can be done to
protect themselves, but this is an ongoing process. For example,
there is plenty of advice on how to spot scam emails apparently
offering good deals, amazing returns, cash and so onall
if you provide bank or other personal details. A measure of commonsense
goes a long way too. However, whilst it may be obvious to most
people that anything that seems too good to be true probably is,
there seem to be lots of people who can be taken in when faced
with such "amazing" offers.
5. In this response we provide comments
on the specific questions posed in the questionnaire as well as
a summary of some recent research into the issues surrounding
trust, security and privacy in the electronic world.
DEFINING THE
PROBLEM
What is the nature of the security threat to private
individuals? What new threats and trends are emerging and how
are they identified?
6. Most of the issues considered to be "threats"
in the online world are actually just current manifestations of
existing problems as seen through the medium of electronic communication.
People need to be aware of potential threats, but to keep them
in proportion. They need to take commonsense precautions, and
take advantage of protection services, some automatic, some that
must be applied, that are offered by companies such as BT.
7. There are three main areas of concern
for private individuals relating to Internet security:
online fraud, including identity
crime;
viruses, trojans and other malicious
attacks; and
8. Impersonating someone else was an issue
long before the advent of electronic communication. Gathering
personal information about another individual is not something
that can only happen through the Internet but, nevertheless, identity
crime, as it is known, is a growing issue. In February 2006 BT
published an Internet security report[2]
on Online Identity Theft, written in conjunction with CPP, Get
Safe Online, Lloyds TSB, Metropolitan Police and Yahoo! The report
highlighted the growth of online threats and included advice on
protecting identity and where to go for advice or help if problems
arise.
9. BT has recently added Identity Theft
Protection[3]
to the other security measures available on its consumer broadband
product BT Total Broadband.
10. Viruses, trojans, worms, spam and botnets[4]
are still the most likely way in which online security will be
breached. BT is committed to providing the best possible protection
for its customers and to do this BT not only offers a range of
protection in the network but also a wide range of security features
are provided as part of the email, narrowband and broadband ISP
service to UK consumers.
11. As well as BT and others providing security
features, and individuals taking responsibility, companies offering
online services work with each other and with Government on various
initiatives to deal with these problems. For example, as well
as the standard anti-virus and firewall products we provide, we
are also working with anti-spam and anti-botnet groups led from
the UK (ISP and DTI led groups) and international groups such
as the OECD. We are members of the International Botnet Task Force.
In all cases we are working with law enforcement agencies.
12. On Child Safety there are various initiatives
designed to make for a safer online environment, recognising that
children are less experienced in the ways of the world and may
have a propensity to divulge more information about themselves
to strangers than they ought. This, of course, is an issue much
wider than just in the online environment. BT has led the way
in trying to deal with child pornography through its Cleanfeed
project,[5]
which prevents access to sites identified by the Internet Watch
Foundation as illegal. We are one of the sponsors of Get Safe
Online, which provides advice on Internet security. Our own BT
Broadband services offer inclusive online security features, including
Parental Controls as well as anti-virus and firewall products.
What is the scale of the problem? How are security
breaches affecting the individual user detected and recorded?
13. It is not possible to provide a meaningful
answer to this question. The February 2006 report mentioned above
contains some research data but this does not pretend to be definitive
nor does it cover all issues that might be thought to represent
what is covered by the term "security breaches". Individuals
will become aware of matters relating to, for example, viruses
or identity, at different stages, depending on the nature of the
issue and their own online behaviour patterns.
How well do users understand the nature of the
threat?
14. Trustguide[6]
is a collaborative project between BT Group and HP Labs, in partnership
with the University of Plymouth's Network Research Group, continues
the dialogue that began with the Foresight Cyber Trust and Crime
Prevention project focused on building a safer cyber world. Trustguide
was concerned with exploring issues of trust, security and privacy
in ICT based applications and services via a series of workshops
and discussion groups that covered as broad and appropriate a
spectrum of the UK's citizens as the scope of the project allowed.
The aim of the project was to use this dialogue and its outputs
to establish recommendations and guidelines for the research,
development and delivery of trustworthy ICT and to inform the
policymaking processes used by government, industry and other
key organisations.
15. In summary, the report suggests that
consumers have a basic level of understanding that threats exist
and that they need to protect themselves against them. The depth
of that knowledge is less obvious; while people were confident
in using appropriate terms, further investigation revealed little
evidence of in depth appreciation and awareness of the dangers.
TACKLING THE
PROBLEM
What can and should be done to provide greater
computer security to private individuals? What, if any, are the
potential concerns and trade-offs?
16. Internet security is both a product
issue and a consumer concern. Amongst other things, consumers
should:
understand the risks and safeguards
available;
ensure firewall, anti-virus and anti-spyware
software are installed;
keep these protections up to date;
keep their computer operating systems
up to date;
protect personal and financial details;
and
set up parental controls where children
are computer users and move the computer to a family room.
17. To supplement the actions consumers
should be taking themselves in terms of managing protection software,
ISPs can take additional measures on their behalf. For example
on 12 October, BT announced it was implementing a new spam detection
system "Spam Buster", which not only tracks down "professional"
spam emanating from the BT network but also protects individual
PCs against being hijacked to produce more spam.
18. There is also an issue for hardware
and software development in that products are often released to
the market before being fully checked for flaws, which means that
many software vulnerabilities are only discovered once a product
is in live use. Greater checking beforehand could, of course,
lead to more costly products and later market availability, so
there is a balance to be struck.
What is the level of public awareness of the threat
to computer security and how effective are current initiatives
in changing attitudes and raising that awareness?
19. See the Trustguide report for awareness
levels. Set against a background of plentiful advice from ISPs,
government, campaigns of various sorts, it is clear that changing
attitudes and awareness is a matter of educationand education
from an early age is as important as "educating" older
sections of the population through advertising and advice.
What factors may prevent private individuals from
following appropriate security practices?
20. There may be a lack of awareness of
what is available and what can be done. There may be a confidence
issuehow to get the best from the services and software
possibilities on offer? Even with awareness and competence, however,
people do not always do the "right" thingwe know
we shouldn't smoke, or drink and drive, or break the speed limit,
or cross the road without looking, etc. But people do all of these
things and there is nothing special about them not taking all
the precautions available online.
What role do software and hardware design play
in reducing the risk posed by security breaches? How much attention
is paid to security in the design of new computer-based products?
21. Some security should be built into operating
systems or hardware and enabled by default. A high degree of automation
will avoid customers having to configure services themselves,
which will reduce the potential security risk. An example of hardware
security is contained in the BT Home Hub. It contains Firewall
and Intruder Protection software which are switched on as the
default setting. Where customers need to proactively download
or activate new protection software, ISPs in general are trying
to make this simpler.
Who should be responsible for ensuring effective
protection from current and emerging threats?
22. ISPs, software vendors, network operators,
government, educators and customers all have a part to play.
What is the standing of UK research in this area?
23. BT is actively engaged in a wide-range
of research and innovation activities, engaging with world-leading
teams around the world. Other UK companies are similarly engaged.
24. As is common in Internet-related activities,
sources of innovation are globally distributed. Investment in
research in this area probably reflects the patterns indicated
in recent R&D surveys, ie UK spending in terms of a percentage
of GDP is higher than in some EU countries, but is lower than
the USA. The rate of research spending, including the development
of post-graduate researchers, in the Far East is rising quickly.
Overall, surveys indicate that the quality of UK research is high,
but there is a need to ensure that gaps in investment in research
between the UK and other countries and regions are closed.
GOVERNANCE AND
REGULATION
How effective are initiatives on IT governance
in reducing security threats?
How far do improvements in governance and regulation
depend on international co-operation?
Is the regulatory framework for Internet services
adequate?
25. Increasing usage of ICT and the Internet
has led to an increase in the perpetration and propagation of
security issues with a cross-border element. A corresponding increase
in focus on developing effective mutual co-operation between relevant
agencies to investigate and pursue harmful cross-border activities
is needed, together with increased resources to deliver results.
26. However, rapid progress is an unrealistic
expectation, given delicate issues of national sovereignty, different
priorities of governments and the absence of uniform global standards
in this evolving area. Continuing dialogue and exchange of best
practice would seem to be the appropriate model to cultivate a
shared understanding of the issues and challenges and the motivation
to provide effective mutual assistance. The example of the recent
successful prosecution and harsh sentences handed out in Russia
to perpetrators of a Denial of Service attack illustrates that
progress is being made.[7]
27. We believe it is for users and service
providers alike to take security measures, rather than for regulation
or law to be relied upon to drive this. Security is a matter of
great importance and service providers in a competitive market,
such as we have in the UK, are driven by the demands of customers
and by the pressure from other providers to offer and provide
ever more sophisticated and powerful security services in order
to maintain their competitiveness.
What, if any, are the barriers to developing information
security systems and standards and how can they be overcome?
28. Money may be considered to be one barrier
but there are organisations, like BT, who implement security initiatives
such as Cleanfeed without making them commercial investments.
They are seen as part of our corporate responsibility to our customers
and beyond.
29. Indeed, there are strong incentives
to invest in security issues in order to build and maintain a
good reputation, and to match what others are offering, even if
such investments are not immediately seen as commercial propositions.
CRIME PREVENTION
How effective is Government crime prevention policy
in this area? Are enforcement agencies adequately equipped to
tackle these threats?
Is the legislative framework in UK criminal law
adequate to meet the challenge of cyber-crime?
30. As stated earlier, we believe the existing
legal and regulatory provisions to be adequate for dealing with
issues arising from the use of electronic communication services.
There must be a sense of proportion when considering "problems"
and potential solutions. For example, not all spam is criminal
or a security issue, and not all mass-mailings are "wrong".
How effectively does the UK participate in international
actions on cyber-crime?
31. The Internet operates across borders
and so we need international co-operation to manage issues around
its security. The UK has taken a very sensible decision to foster
cross-border co-operation rather than looking at issues in national
isolation.
32. The UK Government, regulatory and law
enforcement authorities are involved in partnership with industry
(including BT) in a broad range of initiatives in the OECD, ASEM
(Asia-Europe Meeting) and EU. The Virtual Global Taskforce (police
forces from around the world working together to fight online
child abuse) is one such initiative in which initially bilateral
co-operations are being successfully developed into a broader
matrix of co-operation with agencies around the world.
33. We believe that the UK has a key role
in these initiatives as a consistent, balanced and credible "voice
of reason". This is made possible by the shared understanding
in the UK across all stakeholders that:
dealing with personal Internet security
is a risk-management issue in which there is shared responsibility;
personal behaviour is ultimately
more important in managing the risks than a purely technical approach;
many features which impact on security
are not intrinsically and unequivocally malign and damaging, but
the context for their use may lead to negative outcomes;
technology and behaviour continue
to evolve; and
considerable variation exists between
different countries in their traditions and cultural approach
to security and protection issues and widespread usage of ICT
(including the Internet) exacerbates the challenges of reconciling
these different approaches.
34. This means that the UK brings to such
international actions a pragmatic, nuanced and holistic approach
that recognises that rushing into legal and regulatory interventions
is inappropriate and has real potential to create unwanted, unintended
consequences.
35. BT is an active supporter of both national
and international co-operative action. As we move into the implementation
of our 21st Century Network we will continue to secure our Networks
and work with various organisations to stay one step ahead of
problems as far as we can. For example, BT is currently involved
in several initiatives, such as:
G8 Working group on strengthening
partnerships within Government and Businesses;
International Botnet Task Force (Microsoft
and LEA initiative to combat organised crime and protect the public);
GIAIS (Global Internet Alliance for
Information Security. A Microsoft run programme to help ISPs and
Corporates protect their customers);
FIRST (Forum of Incident Response
and Security Teamsa trusted group of over 130 Blue Chip
companies that share information on Internet Security);
TF CSIRT (a trusted European forum
of Computer Security Incident Response Teams that have pressed
the EU into funding training legal handbooks and several other
projects. They also share information and provide and early warning
network); and
ETIS (the global IT Forum for Telecommunications).
October 2006
2 http://www.btplc.com/onlineidtheft/onlineidtheft.pdf Back
3
Free of charge on BT Total Broadband options 2 and 3. Back
4
The term "virus" is used to cover all kinds of malicious
or undesirable software. A "worm" is like a virus in
that it replicates itself but it does so without attaching itself
to a host program. A "trojan" is an apparently useful
program containing hidden functions that can exploit the privileges
of the user to do things the user did not intend. "Spam"
refers to electronic junk mail or junk newsgroup postings. A "botnet"
is a term for number of Internet computers that, although their
owners are unaware of it, have been set up to forward transmissions
(including spam or viruses) to other computers on the Internet. Back
5
A filter which blocks child abuse sites. It is available to all
ISPs. Back
6
http://www.trustguide.org.uk/Trustguide%20-%20Final%20Report.pdf Back
7
http://www.kommersant.com/page.asp?id=709912 "Eight Years
for Extorting Millions" The Balakov City Court, Saratov region,
has sentenced to eight years in colony with a strict regime and
100,000-ruble penalty each of three hackers of Russia accused
of extortion, causing material damage and establishing and applying
hostile software. Investigating the case of Russian hackers that
used to blackmail British companies lasted for a year. Back
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