18 April 2014

Data Subject Breach Notification and Privacy Impact

The EC Article 29 Working Party has published an opinion offering guidance to data controllers to help them to decide whether to notify data subjects in case of a personal data breach.

Photograph of a large crowd of people

Opinion 03/2014 on Personal Data Breach Notification provides advice to telecomms companies subject to mandatory breach notification under Directive 2002/58/EC. Whilst most readers of this blog will not work in this sector, the guidance itself is useful for consideration in any sector.

The opinion recommends organisations should be proactive and plan appropriately. It illustrates the effects of confidentiality, integrity and availability effects on personal data and the impact upon individuals.

The document recommends that all the potential consequences and potential adverse effects on individuals should be examined, and that data breaches should be notified to the data subjects in a timely manner, if the breach is likely to adversely affect the personal data or the privacy of the data subjects.

See also the Information Commissioner's Office (ICO) guidance on Incidents and breach notification.

Posted on: 18 April 2014 at 08:43 hrs

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15 April 2014

Consultation on UK Cyber Essentials Scheme

As mentioned previously, the UK government has now published a draft cyber security standard and assurance framework for SMEs.

Cover from HM Government's 'Cyber Essentials Scheme: Proposed Assurance Framework'

The relevant documents for the Cyber Essentials Scheme are:

The test specification includes "basic web application scanning for [four] common vulnerabilities [in unauthenticated areas only]" , which doesn't seem to be at a level that would be adequate for even the simplest brochureware website. And other types of application, such as mobile apps, are not mentioned at all. I suppose it's a start, but is it enough to make any difference?

The Department for Business, Innovation & Skills is seeking feedback on the draft assurance framework. A response template can be completed and returned by email to cybersecurity@bis.gsi.gov.uk. The consultation closes on 7th May 2014 and the scheme will be launched in the summer.

Posted on: 15 April 2014 at 07:58 hrs

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11 April 2014

Criminal.UK

Nominet, the .uk country code top level domain name registry, has announced an upcoming change to its terms and conditions which expressly prohibits any .uk domains (and from 2014 .cymru and .wales) being used to carry out criminal activity.

Partial view of Nominet's press release 'Nominet formalises approach to tackling criminal activity on .uk domains'

In the announcement, Nominet explains how it will be working with existing bodies, who are able to alert it to criminal activity on a .uk domain name:

The process and criteria used by the law enforcement agencies to identify the domains is not divulged. But following administrative checks by Nominet, it will suspend the identified domain name being used "for any unlawful purpose", with subsequent complaints being referred back to the relevant law enforcement agency. Nominet intends to report after six months, and thereafter quarterly, on the nature and volume of requests received from each law enforcement agency and about the outcome of related complaints.

Furthermore, Nominet is also taking the opportunity to introduce a ban on registering "proscribed" domain names that appear to "indicate, comprise or promote a serious sexual offence and also where there is no reasonable or legitimate use for that domain".

The revised terms and conditions come into force on 4th May 2014 and are available online with changes highlighted in red.

See also my post last Friday about Regulation of Software with a Medical Purpose.

Posted on: 11 April 2014 at 07:48 hrs

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09 April 2014

Third-Party Tracking Cookie Revelations

A new draft paper describes how the capture of tracking cookies can be used for mass surveillance, and where other personal information is leaked by web sites, build up a wider picture of a person's real-world identity.

Title page from 'Cookies that give you away: Evaluating the surveillance implications of web tracking'

Dillon Reisman, Steven Englehardt, Christian Eubank, Peter Zimmerman, and Arvind Narayanan at Princeton University's Department of Computer Science investigated how someone with passive access to a network could glean information from observing HTTP cookies in transit. The authors explain how pseudo-anonymous third-party cookies can be tied together without having to rely on IP addresses.

Then, given personal data leaking over non-SSL content, this can be combined into a larger picture of the person. The paper assessed what personal information is leaked from Alexa Top 50 sites with login support.

This work is likely to attract the attention of privacy advocates and regulators, leading to increased interest in cookies and other tracking mechanisms.

The research work was motivated by two leaked NSA documents.

Posted on: 09 April 2014 at 10:02 hrs

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07 April 2014

Do You Know OWASP AppSensor on Twitter?

At the weekend I received an email message from Twitter to OWASP Cornucopia with the subject line "Do you know OWASP AppSensor on Twitter?".

Screen capture of an email from Twitter to @OWaspCornucopia woth subject line 'Do you know OWASP AppSensor on Twitter?'

That's a "yes". I am a Project Leader for both of these OWASP projects with their own Twitter accounts:

Good guess Twitter!

My own Twitter account is @clerkendweller.

Posted on: 07 April 2014 at 12:31 hrs

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04 April 2014

Regulation of Software with a Medical Purpose

I seem to have a series of regulation-related posts at the moment. Perhaps the time of year. An article on OutLaw.com discusses how mobile apps and other software medical purpose may be subject to regulation.

Photograph of shelves in a shop displaying rows of medications

The UK's Medicines and Healthcare Products Regulations Agency (MHRA) is responsible for regulating all medicines and medical devices in the UK by ensuring they work and are acceptably safe. It has issued new guidance on "medical device stand-alone software (including apps)" which is defined as "software which has a medical purpose which at the time of it being placed onto the market is not incorporated into a medical device". Thus "software... intended by the manufacturer to be used for human beings for the purpose of:

  • diagnosis, prevention, monitoring, treatment or alleviation of disease,
  • diagnosis, monitoring, treatment, alleviation of or compensation for an injury or handicap,
  • investigation, replacement or modification of the anatomy or of a physiological process,
  • control of conception..."

Guidance on Medical Device Stand-alone Software (Including Apps) describes the scope, requirements and software-specific considerations. Product liability and safety considerations are also mentioned.

This introduces the potential need for registration, documentation, self-assessment, validation, monitoring and incident reporting, especially if the software performs any form of diagnosis or assessment. The OutLaw.com article provides a good analysis and views from experts.

Posted on: 04 April 2014 at 10:11 hrs

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31 March 2014

Regulator Weighs into the Consumer Software Sector

The US Federal Trade Commission has brought two companies to task over inadequate data protection in their mobile apps.

The settlements require Fandango and Credit Karma to establish comprehensive security programs designed to address security risks during the development of their applications and to undergo independent security assessments every other year for the next 20 years. The settlements also prohibit Fandango and Credit Karma from misrepresenting the level of privacy or security of their products and services.

In the proceedings against Credit Karma Inc, the complaint describes the company's website and mobile app which consumers can use to monitor and evaluate their credit and financial status. And, in the proceedings against Fandango LLC the complaint describes how the company has a website and mobile application that allow consumers to purchase movie tickets and view showtimes, trailers, and reviews.

The cases describe a number of problems with security but focus on how the apps had disabled SSL certificate validation leading to the possibility attackers could redirect and intercept network traffic, decrypt, monitor, or alter any of the information transmitted from or to the application, including personally identifiable information. The FTC also said the companies mis-represented the security of the apps to consumers.

The consent orders require the companies not to misrepresent how the apps maintain and protect the privacy, security, confidentiality, or integrity of information. Additionally they must establish and implement, and thereafter maintain, a comprehensive security program including in summary:

  • Designated employee to coordinate the security programme and be accountable for it
  • Assessment of security and privacy risks and safeguards that mitigate these
  • Security throughout the software development lifecycle including employee training and management; secure engineering and defensive programming; product design and development, secure software design, development, and testing; review, assessment, and response to third-party security vulnerability reports; and prevention, detection, and response to attacks, intrusions, or systems failures
  • Implementation, testing and periodic re-assessment of security controls, systems and procedures
  • Due diligence and assessment of service providers
  • Monitoring, review and improvement of the security programme.

Furthermore, these programmes are to be independently assessed initially and then biennially for 20 years by an independent third-party professional who is suitably qualified. The orders mention the assessor may be a "Certified Secure Software Lifecycle Professional (CSSLP) with experience in secure mobile programming; Certified Information System Security Professional (CISSP) with professional experience in the Software Development Security domain and secure mobile programming, or a similarly qualified person or organisation approved by the FTC.

It looks like the year for comprehensive security software development lifecycle initiatives such as Open SAMM, MS-SDL and the Bits Framework.

Posted on: 31 March 2014 at 09:11 hrs

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28 March 2014

OWASP East Scotland Next Week

There is an OWASP East Scotland meeting next week in central Edinburgh on 3rd April 2014.

Photograph of the National Monument on Calton Hill, Edinburgh, Scotland, lit up by blue lighting at night.

The main presentations are:

  • E-Crime and Fraud Intelligence Management in Financial Institutions, Dougie Haywood
  • The Inner HTML Apocalypse: How mXSS Attacks Change Everything we Believed so Far, Dr.-Ing. Mario Heiderich

I will also be doing the warm-up session about the web security requirements card game OWASP Cornucopia.

Further details and registration. 18:00 for 18:30 hrs start. The event is being held in the University of Edinburgh in the Appleton Tower, 11 Crichton Street, Edinburgh EH8 9LE.

Update 9th April 2014: My presentation is available here.

Posted on: 28 March 2014 at 11:00 hrs

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27 March 2014

Web Security Incident Records and Classifications

I just went through the list of recent enforcement actions taken by the ICO.

Screen shot of the submitted response that reads 'Would it be possible for the ICO to classify the vulnerabilities/weaknesses related to software (e.g. websites) in monetary penalty notices, enforcement actions and undertakings? i.e. any published vulnerabilities (CVEs), misconfigurations (CCEs) or software weaknesses (CWEs) that were exploited. Where an incident involves a mis-directed email or fax, or an unencrypted laptop, the root cause is easily identified, but in software-related incidents, there is not the same degree of clarity from the ICO. This information would be invaluable for research, help raise awareness, and assist other organisations to focus their efforts. References https://cve.mitre.org/ http://cce.mitre.org/ http://cwe.mitre.org/ http://scap.nist.gov/'

Periodically I collect information from there and submit incidents to the Web Hacking Incident Database (WHID) using their submission form.

It was disappointing to note the lists of monetary penalty notices, enforcement actions and undertakings on the ICO web site have been truncated and there is no archive. The site's search can be used for some, but I still had to access the helpful Breach Watch to access some past ICO documents. I submitted website feedback about this to the ICO.

The WHID incident submission form asks for the attack method, weakness exploited and outcomes. In many cases this will be unknown, but this prompted me to make a request to the ICO that they classify incidents to raise awareness and help others and help the prioritisation of risk reduction measures. There wasn't an appropriate place on the main ICO web site to do this, so I submitted the suggestion (see image above) on the latest blog post by their Group Manager, which also mentions the recent British Pregnancy Advice Service data breach (BPAS). Awaiting moderation.

Update 9th April 2014: Just noticed, my comment has been published.

Posted on: 27 March 2014 at 11:24 hrs

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21 March 2014

Track Your Domain Name and SSL Certificate Expiry

It can be embarrassing if your website domain registration is not renewed on time or an SSL certificate expires.

Partial screen capture of a web browsing showing a warning for a name mismatch on an SSL certificate

SSL certificates can usually be replaced relatively quickly, in the case of a domain name, there is a risk the name is lost forever. Domain names can be particularly troubling, as some registrars will redirect traffic to their own or random other websites, possibly containing material you would not want to be associated with.

While you ought to have your own processes in place to ensure these events do not occur for any domain names and certificates assigned to systems, I came across a handy service that might also be able to provide early warning reminders.

You need to make sure all the relevant domains are set up correctly. Identifying all domain names in use for supporting web systems and other services, including those that redirect can be a challenge, but needs to be done and maintained. I have used the service for a few months now; the domain alerts seem to work for non .uk domains only, and I'm not sure the SSL certificate expiry service is fully working. Still it might be useful for some.

Not paying the bills of your hosting and DNS service providers is another way for these events to occur!

PS If you want to examine whether there are similar domain names which someone may mis-type when trying to access your site, there is a handy online tool to help with that too.

Posted on: 21 March 2014 at 17:35 hrs

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