04 April 2015

Privacy

Posts relating to the category tag "privacy" are listed below.

04 April 2015

International Personal Data Transfers within AWS

The European Commission's Article 29 Working Party (Art. 29 WP) and lead authority the Luxembourg National Commission for Data Protection (Commission Nationale pour la Protection des Données - CNPD) have announced their decision of a review of Amazon Web Services in relation to the international transfer of personal data.

The Dear Mr Dubois letter

The letter states that the lead authority has analysed Amazon Web Services (AWS) "Data Processing Addendum" and its Annex 2 "Standard Contractual Clauses" which incorporates Commission Decision 2010/87/EU.

The conclusion is that "...by using the 'Data Processing Addendum' together with its annexes, AWS will make sufficient contractual commitments to provide a legal framework to its international data flows, in accordance with Article 26 of Directive 95/46/EC".

This would imply that AWS customers will be able to assume that any transfers of personal data to non European Economic Area (EEA) AWS regions will have the same level of protection as it receives within the EEA.

Posted on: 04 April 2015 at 09:50 hrs

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23 January 2015

Undertaking by Office for Data Protection Act Breach

UK privacy regulator The Information Commissioner's Office (ICO) has published details of its enforcement action against shoe retailer Office.

Partial screen capture of a page from Office e-commerce website www.office.co.uk

The action relates to the unauthorised access of more than a million customer records on a legacy system that was not being protected adequately.

Office Holdings Ltd has signed an undertaking to comply with the fifth (retention) and seventh (security) data protection principles.

The undertaking requires Office to:

  • Undertake regular penetration testing of its websites and servers
  • Implement new data protection policy documents, including a retention and disposal policy for customer data
  • Provide initial and refresher formal data protection training to all Office employees
  • Implement any other security measures as necessary to protect personal data
  • Only retain personal data as long as necessary.

Office seem lucky not to have been fined. There is nothing above that they shouldn't already have been doing and "exposure of decommissioned software/services" is one of the most common classes of IT security vulnerabilities in online systems that result in failures to secure personal data identified by the ICO last May. This document was published by the ICO at about the same time as the Office incident occurred so I think other retailers have been warned and would not be treated as lightly for a similar breach now.

Posted on: 23 January 2015 at 08:34 hrs

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09 January 2015

FTC Final Order Against Snapchat

Following a public comment period in May-June 2014, at the end of December the US consumer protection body Federal Trade Commission has approved a final order settling charges against Snapchat that lasts for twenty years.

Part of the FTC's final order against Snapchat Inc showing the text 'VII. IT IS FURTHER ORDERED that respondent within ninety (90) days after the date of service of this order, shall file with the Commission a true and accurate report, in writing, setting forth in detail the manner and form of its compliance with this order. Within ten (10) days of receipt of written notice from a representative of the Commission, it shall submit an additional true and accurate written report. VIII. This order will terminate on December 23, 2034, or twenty (20) years from the most recent date that the United States or the Commission files a complaint (with or without an accompanying consent decree) in federal court alleging any violation of the order, whichever comes later; provided, however, that the filing of such a complaint will not affect the duration of: A. any Part in this order that terminates in fewer than twenty (20) years; B. this order's application to any respondent that is not named as a defendant in such complaint; and C. this order if such complaint is filed after the order has terminated pursuant to this Part.'

The charges related to how Snapchat deceived consumers about the automatic deletion of private images sent through the service.

The key FTC documents are:

The final order, 23rd December 2014::

  • Prohibits Snapchat from misrepresenting how its products or services maintain and protect the privacy, security, or confidentiality of any covered information
  • Requires Snapchat to establish and implement, and thereafter maintain, a comprehensive privacy program
  • Requires Snapchat to obtain an initial and, for 20 years, biennial assessments and reports from a qualified, objective, independent third-party professional, who uses procedures and standards generally accepted in the profession
  • Requires Snapchat to retain for 5 years records of all communications, complaints, notifications about possible order compliance failures, and assessment materials
  • Requires Snapchat to ensure it provides a copy of the order, and keep evidence of this, to all current and future subsidiaries, current and future principals, officers, directors, and managers, and to all current and future employees, agents, and representatives having responsibilities relating to the subject matter of the order
  • Requires Snapchat to notify the FTC of relevant corporate structure changes
  • Requires Snapchat to provide, within 90 days of the order, a document detailing the manner and form of its compliance with the order.

The order ends on 23rd December 2034 — an additional twenty year compliance overhead on top of the privacy program they should already have had in place.

I wonder if US consumers are also affected by the Moonpig API saga.

Posted on: 09 January 2015 at 08:42 hrs

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16 December 2014

Guidance on the ASA's Online Remit Extension

The UK's Advertising Standards Authority (ASA) has had a digital remit since 2011 in the form of the CAP Code Digital Remit for Advertisements and Other Marketing Communications.

Advertisements and other marketing communications by or from companies, organisations or sole traders on their own websites, or in other non-paid-for space online under their control, that are directly connected with the supply or transfer of goods, services, opportunities and gifts, or which consist of direct solicitations of donations as part of their own fundraising activities.

Last week the ASA announced guidance on the remit extension. Broadly the new guidance explains through example cases that the ASA Council will take into account the entire context in which claims are made, in determining whether the primary purpose of the communication is to sell something and therefore whether it falls within the remit of the CAP Code.

The guidance provides six illustrative case studies that show that if the primary purpose of a web page is to sell something it is almost certain to be in scope, and how the scope can grow by including other marketing communication copy on a web site. Similarly, the context of the page in regards purpose and navigation can affect whether the remit applies, advertgames that are closely linked to products increase the likelihood of being in scope, and user generated content (UGC) can be misused so that it then becomes within scope

So I believe a claim of security or privacy that is intended to help complete a sale would perhaps fall within the remit.

Posted on: 16 December 2014 at 19:27 hrs

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07 December 2014

On Anonymity and Accountability

A post by information security practitioner Robert Hansen titled Anonymity or Accountability raised an interesting topic.

I wonder about the language here — "safety" and "freedom" are not opposites...

I think there is a terminology problem, and some misunderstandings about privacy from this security viewpoint. But a useful discussion to have. Read more on the WhiteHat Security blog.

Posted on: 07 December 2014 at 13:58 hrs

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25 November 2014

Two ENISA Reports on Cryptography

At the end of last week, the European Union Agency for Network and Information Security (ENISA) published two reports on the use of cryptography.

One of the tables from ENISA's report 'Algorithms, Key Size and Parameters 2014'

Algorithms, Key Size and Parameters 2014 (PDF) provides guidance on appropriate cryptographic protective measures for the protection of personal data in online systems. The report defines primitives/schemes that can be considered for use today, as well as those for new/future systems. The document is intended for technical specialists designing and implementing cryptographic solutions..

The second report, Study on Cryptographic Protocols (PDF) extends the previous report to look at how the primitives/schemes are used in cryptographic protocols.

Both reports are free to access without registration.

Posted on: 25 November 2014 at 18:27 hrs

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20 November 2014

TRUSTe Privacy Deception and Misrepresentation

US regulator Federal Trade Commission (FTC) has taken to task self-appointed privacy certifier TRUSTe (True Ultimate Standards Everywhere, Inc.) which labels itself as "powering trust and compliance".

Partial screen capture of a page from the TRUSTe web site showing some of its web privacy certification products

In a press release issued this week, the FTC states that TRUSTe has agreed to settle charges that it "deceived consumers about its recertification program for company's privacy practices, as well as perpetuated its misrepresentation as a non-profit entity".

Apart from a $200,000 fine, the proposed extensive settlement requires "TRUSTe will be prohibited from making misrepresentations about its certification process or timeline, as well as being barred from misrepresenting its corporate status or whether an entity participates in its program. In addition, TRUSTe must not provide other companies or entities the means to make misrepresentations about these facts, such as through incorrect or inaccurate model language.".

TRUSTe CEO Chris Babel's comment about the settlement can be found on the TRUSTe blog.

The United Kingdom TRUSTe web site is http://www.truste.co.uk/ which lists many UK clients. Sadly, a Google search indicates many of their clients haven't realised what's been going on and are still promoting the label.

Posted on: 20 November 2014 at 14:15 hrs

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07 November 2014

75,000 GBP Fine For SQL Injection From ICO But With 90% Discount

Lancaster-based apartment booking company Worldview Limited has been fined under the Data Protection Act for allowing unauthorised access to customers' details. The company operates under two UK brands, Citybase Apartments and Central London Apartments.

Although customers' payment details had been encrypted, the means to decrypt the information - known as the decryption key - was stored with the data.

The Information Commissioner's Office (ICO) press release states that a SQL injection vulnerability that existed for 3 years was the root cause, so this might imply the the decryption key was either stored in the database or the database could be used to read the key from elsewhere, such as the file system. The information taken included 3,814 payment card details; this mentions that both primary account numbers (PANs) and three digit security codes were accessed, which is even more interesting. The terms and conditions (Citybase, Central London) state:

Your payment card details will be securely held for the purpose of processing the booking until the day of check in. On the day of check-in, the credit card details are removed from our systems.

That's the travel industry problem of stored card data.

Apparently the fine would have been £75,000 but this may have put the company out of business. However, I suspect the fact that Worldview Limited will also be paying forensic investigation charges, card re-issue fees, card monitoring fees and fines relating to their PCI DSS contractual obligations will also have been taken into account by the ICO. However, £7,500 is a lot less than Worldview should be spending to ensure their customer data is secure. The fine is reduced further to £6,000 if payment is made by 1st December 2014.

The monetary penalty notice is available on the ICO web site.

The two "site security" pages on both web sites (Citybase, Central London) put a lot of faith in the use of "industry standard Secure Socket Layer (SSL) encryption technology" only:

When you submit your card details the information is encrypted (scrambled) so that it can only be read by the secure server, making the transaction as secure as possible.

When Lush Cosmetics had an ecommerce incident in 2010-11 with a similar number of cards and other personal data compromised, there was no fine — just an undertaking (and of course the PCI DSS costs). I suspect this stronger response from the ICO reflects its view that SQL injection is a basic fault that is below any acceptable level of security.

Update 7th November 2014: Link to monetary penalty notice and details of early payment discount added.

Posted on: 07 November 2014 at 08:59 hrs

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06 November 2014

OWASP Snakes and Ladders

In a month's time we will probably be in full office party season. I have been preparing something fun to share and use, that is an awareness document for application security risks and controls.

OWASP Snakes and Ladders Mobile Apps

Snakes and Ladders is a popular board game, with ancient provenance imported into Great Britain from Asia by the 19th century. The original game showed the effects of good and evil, or virtues and vices. In this OWASP version, the virtuous behaviours (ladders) are secure coding practices and the vices (snakes) are application security risks. I have created two versions so far:

I created the game to use as an ice-breaker in application security training, but it potentially has wider appeal simply as a promotional hand-out, and maybe also more usefully as learning materials for younger coders. To cover all of that, I use the phrase "OWASP Snakes and Ladders is meant to be used by software programmers, big and small".

OWASP Snakes and Ladders Web Applications

The game might be a useful transition from learning about the OWASP Top Ten Risks and before moving into the Top Ten Proactive Controls in a PCI DSS developer training session for example.

Snakes and Ladders Web Applications is available in German and Spanish, as well as in (British) English. Translations to Chinese, Dutch and Japanese are also in progress. The OWASP volunteers who are generously translating the text and performing proof reading are:

  • Manuel Lopez Arredondo
  • Tobias Gondrom
  • Martin Haslinger
  • Riotaro Okada
  • Ferdinand Vroom
  • Ivy Zhang

Print-ready PDFs have been published - these are poster sized A2 (international world-wide paper sizes). But the original files are Adobe Illustrator, so these are also available for anyone to use and improve upon. OWASP Snakes and Ladders is free to use. It is licensed under the Creative Commons Attribution-ShareAlike 3.0 license, so you can copy, distribute and transmit the work, and you can adapt it, and use it commercially, but all provided that you attribute the work and if you alter, transform, or build upon this work, you may distribute the resulting work only under the same or similar licence.

Just print out the sheet as large as you can make them. It is better to play using a real die and counters (markers), but you can cut out and make these from the paper sheet itself if you have scissor and glue skills.

You can also follow two mock games on Twitter which upload a position image every hour:

Please enjoy and share.

Further information, and all the PDFs and source files, are available on the Snakes and Ladders project website. Please keep in touch by joining the project mailing list.

Posted on: 06 November 2014 at 08:31 hrs

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04 November 2014

Payment Checkout Flaws and Bugs

The announcement last week by researchers from Newcastle University about a problem with Visa's contactless cards reminded me to mention again commons issues with checkout and payment functions in web and mobile applications.

Photograph of customers in a household lighting stand during Clerkenwell Design Week 2014

The Visa fault relates to not enforcing the same limits on transactions when using foreign currencies. The paper is being presented this week at the 21st ACM Conference on Computer and Communications Security in Scottsdale, Arizona. While we hope we would not make similar mistakes ourselves, almost every web/mobile checkout/payment system I come across has some sort of problems.

I do not believe I have mentioned it previously, but if you are developing an online payment API, mobile or web payment application, you should read a paper from Microsoft Research issued in 2011. How to Shop for Free Online - Security Analysis of Cashier-as-a-Service Based Web Stores (presented at IEEE Symposium on Security & Privacy 2011 in Oakland, California) describes findings from research into the security of several web payment applications.

Many of these problems are data validation or authorisation issues, but can be labelled as "business logic flaws". My own checklist for reviewing payment application functionality is below:

  • Buy at arbitrary price
  • Buy at nil price
  • Buy without paying
  • Buy one at item at another item's price
  • Pay for one basket at another basket's price
  • Update the basket while paying for the original one
  • Voucher, gift card and discount enumeration or manipulation
  • Repeat order/payment
  • Missing "mandatory" steps
  • Refund after payment
  • Chargeback after payment
  • Pay customer instead of seller
  • Missing checks/enforcement of data validation/signing
  • Enumeration of accounts, customers, payment cards, baskets, orders, email addresses, phone numbers
  • Manipulation of out-of-band messages (e.g. emails, SMS, direct messaging)
  • Payment confirmation manipulation
  • Tax and currency conversion manipulation
  • Rate of use and floor limits
  • Staff/internal backdoors
  • Fraud opportunities
  • Test data/cards works/present
  • Third-party hosted content
  • Privacy contraventions
  • PCI DSS contraventions.

This does not describe every method, but I hope the list is of use to others anyway. Generic attacks (e.g. injection, path traversal, cross-site request forgery, man-in-the-middle, unpatched components) also crop up in ecommerce payment functions, like everywhere else.

Posted on: 04 November 2014 at 20:11 hrs

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