Memorandum by Nick Hubbard LLB (hons)
I write in response to the call for evidence
on Personal Internet Security.
I acknowledge that I am a security practitioner,
engaged in the public sector as an Information Security Officer,
and I therefore have a perspective on your subject. But I do not
intend to reveal the identity of my employer: this submission
is a personal one and not corporate. Unfortunately this denies
me the use of my employers' incident records and my comments are
therefore largely anecdotal.
I am pleased that Parliament is considering
these issues, and I am extremely keen to help as much as I am
able.
DEFINING THE
PROBLEM
I think it is first worth discussing what the
requirement for Personal Internet Security is.
Individuals rarely think through this question,
but their requirement is for a system which is readily available
for most (say more than 99%) of the time; which does not expose
them to significant risk of crime perpetrated against them; and
which affords them a reasonable degree of privacymeaning
confidentiality and not being bothered by unwanted material (such
as pop-ups, spyware, phishing attacks and spam). The requirement
also includes a degree of confidence in the material which is
presented to themso protecting them from fraud, and again
from phishing attacks. Like the use of their motor car, they do
not expect a perfect standard of safety, but a fairly high onemore
so when their families are involved.
There may be a wider issuethat they take
it for granted that their personal security is preserved when
they give personal information to others on the internet. They
do not expect the use of a chat room or a web site to lead to
the disclosure to third parties of their information. They expect
that organisations to whom they give their information will respect
their privacy and related interests (as required by the Data Protection
Act 1998 in the UK).
The very idea of a security requirement is problematic
in that it is not explicit but assumed and inferred, and taken
for granted. That it is only seriously considered after something
has gone wrong, when in practice it is usually too late for any
satisfactory remedy.
So to the threat. I have heard it said that
any offence may now be committed via a computer. The offences
of personal harm are more difficult, but one can argue that they
are possible. In my five years experience of Infosec, I have seen
examples of many of these.
Fraud is extremely common. So are hacking attacks,
phishing, viruses and spyware. Hacking on a corporate network
is attempted several million times a year. Viruses arrive at the
rate of about 20,000 viruses a year. We cannot quantify fraud
attempts, but I would guess at around 20,000 attempts per year.
We receive more unwanted e-mail than the personal and business-related
combined.
At home, my computers are much less active,
so attacks are much less numerous. I do not document them, but
I regard them as commonplace. About three times a year, I rebuild
a machine belonging to friends or family after damage by a virus.
My credit card details have apparently been
compromised this summer, for the first timeas a result
of an eBay transaction.
More recently I find that my e-mail contains
dozens of messages which are from other computersrejecting
e-mails which I have never sent. One obvious explanation for this
is a virus on another computer which holds my e-mail address.
Another is that my address has been obtained from a web transaction.
The first "bounceback" messages were to Thomson@...this
is an address which we have used only once on a holiday company
web site (I use this mechanism routinely to trace the source of
problems). So it seems probable, but less than certain, that this
address was compromised in that transaction: it leaked as a result
of accident or otherwise by the holiday company. I feel entitled
to expect that they would treat my information with respect: with
due care. Now a large number of spam and virus e-mails are being
sentapparently from me. My reputation may be damaged.
So I believe that these events are reasonably
commonplace. The threat is very high.
I believe that the threats and trends are the
same for home computing as for corporate. But the numbers are
far smaller.
Sensitised at work, I apply the same techniques
and solutions at home. I spend a huge amount of effort at work
on raising user awareness: one of my techniques is to relate the
topic to their own information and their home computers.
For many years I relied on the Norton/Symantec
solutions. I have come to prefer the BT Yahoo environment, which
provides and manages them for me. I recommend that to friends
and family. However, since moving away from Norton, I no longer
notice attacks on my machines, and I now rely on personal judgement
and reports of anomalous behaviour in order to detect breaches.
My credit card company, Halifax, and PayPal (relates to eBay)
detected the problem with my credit card, much to my surprise,
they were very astute.
I believe that a huge majority of users do not
even attempt to understand the issue. They follow somebody's recommendations,
implement anti-virus and often a firewall, and then forget about
security unless/until something goes wrong. So patching and updating
virus signatures is largely a matter of luck. They assume that
there is a low level of threat, as when they drive their car.
Many users have still only the sketchiest ideas
of security problems and solutions because they have very little
knowledge/confidence/commitment to their computers in the first
place. My parents, my brothers and sister, and my in-laws are
a good example of thisof 20 users in my family, only four
of us have any interest in managing the computer as distinct from
using it. I suspect that is a relatively high proportion.
Many people think of financial details in relation
to information security, but my background makes me aware that
the interests of my children are inextricably linked with the
security of my computer. Their personal informationincluding
habits and venues, descriptions, and possibly sound and images
of them could be exposed. The computer can easily be used as a
medium to manipulate their actions. Somebody who purports in an
e-mail or a chat room to be a 12 year old girl can easily be a
50 year old paedophile.
There is at present very little assurance that
any computer-based statement is true or honestly made.
"Spoofing" is easy. I could purchase
for a pittance five domain names such as houseofcommons.uk.net
for example and thus purport to be a Government Ministerreasonably
convincingly and with little chance of detection.
TACKLING THE
PROBLEM
I am deeply impressed by the offerings of BT
Yahoo. These allow individuals to implement good levels of security
on their computersfirewalls, antivirus, pop up controls,
anti-spyware, anti-spam, and parental controls on web surfing,
all for a modest price, and requiring a very small input from
the users.
Unfortunately, most users are not sensitive
to security issues, but are extremely sensitive to price, and
competitors are cheaper than BT, so this is making limited inroads
into the problem so far.
Many police officers simply reject computer
technology as far as they can. Few have any degree of IT competence,
let alone in matters of security, investigation of "cyber
crime" or the gathering of computer-based evidence.
Cost and effort are critical.
The Government is attempting to lead us towards
electronic transactions in preference to the paper and personal
ones from the past. These depend upon the availability of a computerat
both ends. To that extent, the private computers are important.
My son and my daughter rely on the Internet
for help with their studies. My wife and I use it extensively
for all sorts of purposes. The loss would be significant because
of their studies; otherwise the loss would be no more than a nuisance.
And I believe that we are more dependent on computers than most
families. So the availability of the system is not as important
as business critical systems (such as the payroll) are within
an organisation.
I have a relevant professional position: the
personal security of the individual members of the organisation's
staff is important. So for five and a half years, I have worked
hard to raise their awareness. I cannot quantify the present level
of awareness, but I am sure that it is a minority who have taken
much notice. An important part of the context is that I am able
to provide evidence of incidents which take placeso to
prove that security is not merely "just in case". I
have never heard our staff refer to national initiatives for securityI
believe they are unknown.
I believe that the following of appropriate
security practices requires intellect, motivation, effort, and
funding. Hard enough for government organisations to adopt, let
alone private individuals. In my view, organisations must somehow
spoon-feed individuals with sound security.
It is my view that today's PC design traces
its history back to a time in which the computers were not linked
to networks and could be adequately secured within a locked building.
Security has been an addition, made reluctantly.
As most computer products come to market the
supplier's priority is to deliver quickly and initiate the revenue
stream. As a result, software often matures in patches and modifications
made after the product is first sold. And it seems safe to say
that security features are rarely a major selling point.
Microsoft XP, for example, has been on sale
for several years, with a firewall capability but it is only recently
that this capability has been enabled by default.
In the end, only the individual can be responsible
for his own security, like locking one's car.
I cannot conceive of successfully making suppliers
responsible, especially given the international nature of the
business, and the issues of jurisdiction.
It seems to me that in the same way that government
influences health issues such as smoking and obesity, there is
an obligation to work on personal computer security.
Police forces have a responsibility for investigating
computer crime. They have arguably an obligation to prevent crimeincluding
computer crime. But they have very little of the skills and resources
to do so. And they are culturally inclined to reject the idea.
Chief Constables would presumably say that they have no computer
crime problem (because they have no mechanism for addressing it).
The work of the national information security
authorities is very important and influential. They provide training
and help with the selection of security products, but their target
audience is corporateand primarily in the public sector.
And public sector authorities struggle to slowly adopt credible
security measures. I believe that little of this work percolates
through to individuals' computers.
It seems important to note that the threats
and trends of incident change very rapidly. Anti-virus software
now needs updating daily to keep up. New vulnerabilities and attacks
also emerge daily (see Communications Electronic Security Group
publications).
Password technology was perfectly adequate say
10 years ago. But more computing power than ever is available
to the mischievous; and password cracking techniques have come
on in leaps and bounds. Today a password is fairly unconvincing
as a security measure.
It is also important to note that technical
defence is only a part of the solution. Some years ago, several
individuals in my organisation received a perfectly ordinary uninfected
e-mail. It told them that their computer had a virus, and provided
detailed instructions. Two individuals followed the instructions
diligently and removed critical software components from their
operating system. It was a do-it-yourself virus.
Some hoaxes are almost as damaging as the attacks
they describe.
Equally "phishing" attacks rely successfully
on gullible users supplying information.
GOVERNANCE AND
REGULATION
IT governance initiatives have some influence
in reducing security threatsin corporations, but almost
none in the private environment. In my own organisation, we have
adopted national standards (in 2001) and we now claim, with honesty,
an 83% level of compliance.
I believe that the British Standard (BS7799:
ISO 17799) has been extremely useful as a language of security
and a model, but only for corporations, and then not for all of
them. My Local Authority still aspires to any degree of compliance.
Their networks are regularly paralysed by viruses, to the extent
of damaging children's education. For example, my son was recently
preparing an A Level coursework submission, when his school network
failed for about a fortnight. I am aware that teachers routinely
carry details of child pupils on laptops which have no effective
protection.
Few individuals have even heard of the document.
As the production of hardware and software is
international, so governance and regulation must also be international.
But it seems unlikely that effective agreements could be reached
with enough agility to address the changing problems. So I see
this as a fairly hopeless issue.
I do not accept that the regulatory framework
for internet services is adequate. But given the jurisdiction
and agreement issues, I think that this can never be totally effective.
I am utterly certain that the main barriers
relate to awareness and motivation. The Government's drive to
e-government was heedless of the security issues. These were assumed
to be solvable by practitioners, and to some extent this was true.
Government departments are reluctant to adopt sound security practices
(the press daily publishes security scandals). Police forces are
reluctant and unable to attach any significant priority to their
own security or anyone else's, suppliers are motivated by profitnot
the interests of the consumers, and there is a very limited public
awareness of the issues.
The Bichard Report has gone some way to raise
government awareness of the importance of Information Management.
It is my view that Information should now be
a Cabinet Level issuea Ministry of Information is called
for if we are to make much progress in relation to the security
of corporations or individuals. I believe that Britain plays a
leading role in the Information Ageand we should develop
it fully rather than stifle it.
I suggest that the police service, and the criminal
justice community, should be driven to address computer crime
matters competently and adequately.
There is some assumption that computer crime
is the work of rather benign nerds. This overlooks paedophiles,
fraudsters, mercenary hackers and virus writers. But I do not
believe that quantitative evidence is available to define the
source of attacks adequately.
CRIME PREVENTION
I am "in the business"; and my enthusiasm
is probably evident by now. I am wholly unaware of any government
crime prevention policy relating to information.
I do not believe that my local HiTech Crime
Unit has the skills or resources to tackle the volume of computer
crime. I am aware of the Serious and Organised Crime Agency which
may be better equipped to tackle more serious aspects of the problemI
cannot comment on their adequacy.
The legislative framework will always struggle
with the international dimension of the problem.
The Data Protection Act 1998 seems to me to
be phrased with vaguenessenough to deter most resulting
legal action. This act contributes very little to the debate on
security and affects only corporationsnot individuals.
This could usefully be revised.
The Computer Misuse Act 1990 is now well out
of date, and is limited to purely technical attacks. It does not,
for example, address the issues of the Do-It-Yourself virus I
described earlier, and it does not address the issues of Denial
of Service attacks.
The Regulation of Investigatory Powers Act creates
an offence of intercepting communications, and thus attempts to
protect the privacy of e-mails.
It is often said that computers merely provide
new avenues for the commission of all the old offences. Older
laws such as Theft Acts and Criminal Damage Act create offences
which can be carried out through a computer. The legislation was
phrased with such clarity that these seem unlikely to cause a
problem.
A paedophile may groom his victims through computers,
and eventually commit physical assaults. These areas are adequately
catered for in the existing criminal law.
Initially there was a great deal of concern
about the law of evidence as it relates to computers. But I understand
that in practice, there has been little difficulty here. Defendants
have not challenged computer based evidence significantly, but
we seem to be relying on old principles carried into modern times.
I suspect that if and when defence lawyers become IT literate,
more difficulties will emerge in this area.
There is one practical problem which remains.
It is that it may be easy to prove that whoever used the computer
committed an offence: but without an admission by the offender,
or some unusual circumstance, it is extremely difficult to prove
who used the computers. As I have said, my machines at home are
shared by four family members and visitors occasionally have access
to them. So in practice, almost anything I do is deniable. The
law could specify access controls, or creates strict liability
offences, but I do not envisage that either of these approaches
would be foolproof.
The problem is not so much the adequacy of the
law as the adequacy of the resources required to enforce it.
I am aware that security authorities collaborate
on an international basis to prevent, manage and investigate threats.
I am aware of very few successful prosecutions resulting from
thousands of incidents.
In conclusion, you will see by now that I believe
that Personal Information Security is a problem which urgently
demands action in several areas: action in relation to suppliers,
in relation to awareness of individuals, and in relation to enforcement
of the law. Even then some fundamental problems remain because
of the international nature of the Internet.
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