Thought I would post this for anyone in the UK who does not know about this
bill.
The Regulation of Investigatory Powers Bill –
Technically inept: ineffective against criminals while undermining the
privacy,
safety and security of honest citizens and businesses
by Ian Brown and Brian Gladman
Introduction
The Regulation of Investigatory Powers (RIP) Bill currently going through
Parliament will introduce powers to allow a number of UK authorities to
intercept Internet communications and to seize encryption keys used for the
protection of such traffic and for the protection of stored computer data.
Such
powers are not limited in their application to those involved in criminal
activities and this means that law abiding individuals and businesses may be
subject to interception activities as well as demands to hand over their
encryption keys. Although abuse of these powers may well be limited, there
can
be no doubt that this will sometimes occur and this means that honest
computer
and Internet users will bear increased risks to their privacy, safety and
security once this legislation is enacted.
This paper aims to show that the envisaged powers for interception and for
the
seizure of encryption keys are technically inept. It also aims to offer
honest
computer and Internet users advice on the practical steps they can take to
maintain their privacy, safety and security in the presence of the
oppressive
powers introduced by this legislation.
There are three areas of risk that will be covered separately:
the interception of electronic mail;
the seizure of information on a user’s computer;
the seizure of encryption keys.
Preventing Email Interception
In order to understand how to avoid the risks of email interception
introduced
by the RIP Bill it is necessary to understand in outline how the Internet
works.
This is covered in the next section, which can be skipped by those who
already
have this knowledge.
The Internet Protocol
The Internet is built on a simple but powerful way of moving data from one
computer to another called the Internet Protocol (IP). In basic terms any
data
that needs to be exchanged is chopped up into small pieces called ‘packets’,
these packets are marked so they can be checked and reassembled later,
destination labels are added and they are then sent to the Internet for
delivery. The packets then pass individually across the Internet and when
they
reach their destination they are checked and reassembled in the right order
to
recreate the original data item. Many different types of data can be handled
in
this way, for example, electronic mail messages, web pages or even direct
voice
and video messaging.
Most home users connect to the Internet using a telephone line and a
computer
fitted with a device called a modem. When a user wishes to connect to the
Internet, their computer uses the modem to dial the access number of an
‘Internet Service Provider’ (ISP), after which it is given an ‘IP address’
which
allows it to exchange data packets with any other computer that is also
connected in the same way.
IP addresses are in a numeric form (e.g. 94.60.38.75) but there are special
computers on the Internet running the Domain Name System (DNS) that act like
telephone directories so that somewhat more meaningful names (e.g.
www.parliament.uk) can be converted into the numeric addresses that
computers
need. Many sites have permanent IP addresses but users are often only given
a
temporary IP address when they are actually Internet connected (that is,
when
they are ‘on-line’).
Electronic Mail
Although two IP connected computers could exchange electronic mail (email)
directly, such an approach would often be inconvenient because both
computers
would have to be on-line at the same time. To avoid this difficulty
Internet
users are provided with a ‘post office box’ in which their incoming email is
stored for them until they next make a connection. In fact there will often
be
different servers for incoming and outgoing email. This approach is often
referred to as ‘store and forward’.
After a user connects to the Internet and starts their email software, the
latter connects to the incoming and outgoing mail servers using IP
connections.
Once such connections are made, the server will then ask the user’s computer
to
supply details of their account name and password in order to ensure that
any
email is accepted from a legitimate customer or correctly delivered to its
intended recipient. After these account details have been checked, a
prearranged set of messages (a protocol) is then used to manage the
collection
and delivery of each item of email. And when this has been completed the
connections between the users’ computer and the two servers are terminated.
Although it is normal for a customer to obtain their IP connection and their
email service from the same service provider, such an arrangement is not
necessary – the only essential service is an IP service since this can be
used
to access email servers anywhere on the Internet. In consequence once a user
has
such an IP service, they can then obtain their email service elsewhere they
want. There are now a large number of independent email services available,
very many of which are free.
The ability of UK users to obtain an email service that employs servers
outside
the UK has serious consequences for the interception of email messages. If,
for
example, such servers are located in a country where email interception is
unlawful, a UK user’s email cannot be intercepted while it is on these
servers.
However, a UK user’s email still seems to be vulnerable to interception when
they make a connection to their mail service from the UK. However, this
turns
out to be incorrect since these data exchanges can be encrypted and this can
be
done in a way that does not allow keys to be seized.
In practice there are several easy ways in which UK citizens can reduce or
even
eliminate the risk of email interception.
1. Choose a Small ISP
Firstly, since the Government has said that it only expects to implement
email
interception at a small number of ISPs, it is quite easy to reduce the risk
of
interception. For example, it is very unlikely that the Government will
install
interception equipment at the many small ISPs since the overall costs of
doing
this will be high and the gains involved will be very limited. It is very
likely that any interception capability will be at larger ISPs and this
means
that using a small ISP can reduce the likelihood that email is vulnerable to
interception. Some care would be needed in the choice because some small
ISPs
obtain services from larger ones and their email may still be subject to
interception. In practice a user who employs this approach could not be
certain
that their email was safe, but the chances that it could be intercepted
would be
small. If they were really worried, they could use several different ISP
accounts and alternate between them to increase the difficulties involved in
intercepting their email.
2. Email Accounts Hosted Outside the UK
But there is a much better way of avoiding interception by setting up email
accounts outside the UK. As indicated earlier, provided that the location
of
the mail servers have been chosen to be outside the jurisdiction in which
RIP
powers apply, any email stored on these servers cannot be read by UK
authorities.
At first sight it might seem that email could be intercepted when a UK user
connects to their overseas server to send or receive their email but this is
incorrect. Using a technique called Diffie-Hellman key negotiation it is
possible for the user’s computer and a mail server to negotiate, generate
and
use unique encryption keys to encrypt all data passing between them. And
once
such keys have been used they can be immediately destroyed so that they
cannot
be seized. The data exchanges required for a user to send and receive their
email from an overseas mail server can hence be completely protected. As a
result, the only place in the UK where the email could be obtained by UK
authorities is on the user’s own computer.
In fact many popular email applications already include facilities to
encrypt
these data exchanges with mail servers so all a UK user has to do to avoid
email
interception is to sign up with one of these services (many are completely
free). Examples of electronic mail services that can be used to circumvent
RIP
email interception powers in this way include:
·
http://www.messagerx.com·
http://www.mail2web.comIt will be important to use strong cryptography to protect email account
access
because the use of such accounts is likely to attract GCHQ interest using
certificated warrants (“trawling warrants”) targeted against encrypted
traffic.
3. Direct Email Delivery
If most computers had permanent connections to the Internet any email could
then
be sent directly without the need for mail servers. While permanent
connections
are somewhat unusual at the moment, the introduction of ADSL and cable based
Internet access will mean that many Internet users are likely to migrate to
permanent Internet connections and this will mean that email packages will
become available that can make use of direct connections for email delivery.
This will mean that the success of interception based on the existence of
email
servers is certain to decline with time and seems likely to have a very
limited
useful life. In consequence it is very hard to see the implementation of
such
approaches as a good investment of taxpayers’ money in the fight against
criminals on the Internet.
4. Secure Internet Protocols
There is a powerful new Internet Protocol currently being introduced –
IPv6 –
that will allow two Internet connected computers to negotiate, use and
destroy
unique encryption keys for each data exchange. This will provide secure
encryption using keys that cannot be seized and will protect all the traffic
between the computer systems involved. This is now being progressively
deployed
and is likely to become the universal standard for IP data exchange well
before
the end of this decade. If implemented properly such secure IP services will
protect all Internet services – email, voice, video and all other services –
from attempts at interception. Again, therefore, investments in Internet
interception will become completely ineffective as new Internet technologies
are
introduced.
Conclusions for Email Interception
From this analysis it can be seen that:
· RIP powers for email interception are already trivially easy to
circumvent;
· The already questionable value of such powers will be completely
undermined as new Internet technologies are introduced over the next few
years.
Storing Data Securely on Computer Systems
Legislation already provides powers for law enforcement authorities to seize
computer systems and the data they contain if they suspect owners of
criminal
wrongdoing. The RIP Bill extends these powers by allowing authorities faced
with encrypted data to demand that it be decrypted or, in some
circumstances, to
demand copies of the encryption keys that have been used to protect it. One
of
the arguments used to support the RIP legislation has been that criminals
will
see the dangers of computer data being seized and will increasingly resort
to
the use of encryption. In practice this argument appears to be based more
on
fear than on reality since there is very little evidence to suggest it is
actually happening to any significant extent at the moment.
But RIP powers for key seizure are not limited to those suspected of
criminal
activity and this means that honest users who are concerned that their
computer
data might be seized need to understand how they can protect themselves from
the
risks to their privacy, security and safety that this would involve. In
practice anyone who really wants to avoid their data being seized has many
ways
of doing this.
Effective Information Security
A key concept for effective information security is that of ‘defence in
depth’ –
information that needs to be highly secure should be given several layers
and
several different forms of protection. An analogy is that of the medieval
castle:
· built on a hill to reduce the possibility of surprise attacks;
· surrounded by a wide moat;
· protected by a strong outer wall (with little ground between the
wall
and the moat);
· an inner walled area – for example, a keep – so that attackers who
penetrate the outer defences have further hurdles to overcome;
where there are several layers of defence, each posing different problems
for
attackers and each arranged so that they are mutually reinforcing.
Exactly the same principles apply for protecting information stored on
computer
systems and some of techniques involved in building layers of protection
will
now be described. Used carefully and in combination these can provide
barriers
that are close to impregnable for stored data.
Data Storage on Computers
Most computer systems typically have a single large hard disc drive with
space
for several gigabytes of data. If there is sensitive data on such a drive
it
can be encrypted to protect it but it may still be vulnerable if the
encryption
keys used are not properly protected or if they cab be seized using RIP
powers.
In fact, such storage is not very safe for many other reasons. For example
deleted data will often be very easy to recover and, even when a
considerable
effort has been made to remove it, sophisticated techniques will sometimes
be
able to recover it.
For these reasons the most important first question to ask about storing
critical secret information on any computer is ‘does it really need to be
there?’. Computers, especially ones that are used to connect to the
Internet,
are not very secure and this means that they should not be used to store
secret
information unless this is absolutely unavoidable.
Encryption
Encryption allows data to be scrambled in such a way that it can only be
recovered by using special keys. It offers a powerful technique for
protecting
information but one that is subject to a number of risks including the
following:
· if keys are lost the owners of encrypted information will no longer
be
able to access it;
· if keys are stolen (or seized) others may be able to access any of
the
information that they protect;
· encryption capabilities may not be properly engineered and there
may be
easy ways around the protection which they seem to provide;
· encryption software is often quite difficult to use and this will
sometimes mean that users make mistakes that undermine the protection that
is
available.
In practice, these difficulties mean that encryption is much less valuable
for
protecting stored data than many people expect. While some of the above
problems
will eventually be overcome as the technology develops, relying on the use
of
encryption alone to protect stored computer data is not sensible at present.
This will be especially true once the RIP powers are available since honest
people may well be forced to give up the keys on which their privacy, safety
and
security depend.
Steganography
Steganography – information hiding – provides a powerful technique for
protecting information simply by hiding its existence. With encryption data
is
scrambled but its existence is not hidden and this means that anyone who
obtains
scrambled data will know that there is a key to it somewhere. This is an
immediate vulnerability that can be avoided by hiding the existence of the
information in question.
Ross Anderson, Roger Needham and Adi Shamir[1] have described a powerful
concept
known as a ‘Steganographic File System’ (SFS) in which the filing system on
a
computer is set up in such a way that the existence of files can be hidden
by a
password. Importantly there can be several layers of protection so that,
for
example, revealing the password to the top layer does not reveal anything
about
lower layers. Faced with a demand for access to data held on such a system
a
user could hence provide passwords to several layers of files but not reveal
the
fact that more layers exist. Any authority that seized a computer with such
a
file system could never be certain that they had scanned all the data on the
computer since there might be hidden layers that the owner has not revealed
to
them.
At the moment the availability of steganographic file systems is somewhat
limited. Examples are available on Linux and Unix systems but users of the
popular Microsoft Windows operating systems are less well served. But there
can
be little doubt that this will soon change.
Such file systems are more powerful than encryption for protecting stored
data
since they mean that anyone who gains access to a computer using such a
system
can never be sure that they have gained access to all of the information
that it
contains. Of course, encryption can be used in combination with
steganography
to provide a formidable challenge for anyone trying to access this
information
against the owner’s wishes.
Physical Steganography
A major problem with the use of encryption or steganographic techniques to
protect stored computer data is that law enforcement authorities will
eventually
wake up to the need to develop the expertise needed to overcome these types
of
protection. The possible law enforcement use of experts is the most powerful
approach to combating criminals on the Internet. It is undoubtedly the
right
approach and will, hopefully, be limited to such ends but abuse cannot be
ruled
out so it is worth asking what honest owners of computer data can do to
limit
such risks.
If computer data is stored on a typical hard drive, expert examination of
its
contents is likely to reveal a lot about the data it holds. The best way of
avoiding such vulnerabilities is not to store sensitive data on such discs
but
to rely instead on removable disc drives.
Disc drives that use removable disc cartridges are now quite inexpensive and
have capacities ranging from 100 megabytes up to several gigabytes. By
using
such removable cartridges, critical data can be stored away from the
computer
when it is not in use and this greatly reduces its vulnerability. Moreover,
if
such a removable cartridge is not loaded on a computer when the latter is
used
for Internet access, the vulnerability of the data to access via the
Internet is
significantly reduced.
If a computer system is seized it is quite possible that an associated
removable
cartridge might not be found. Of course if the removable drive is present on
the
computer, the authorities will be looking for removable cartridges so it
will be
important to have some around that contain innocuous data that they can
seize.
But once removable cartridges are being used, any authority that seizes a
computer can never be certain that they have gained access to all the data
held
by the owner since they cannot be sure how many cartridges are in use.
Protection is limited only by the ingenuity of the owner in physically
hiding
disc cartridges and this means that this form of information hiding –
physical
steganography – provides a remarkably simple and yet extremely powerful
technique for maintaining the secrecy of stored computer data. PACE and RIP
are
powerless against these techniques so there is no reason for any careful
computer user who really needs to protect their critical data to worry about
such laws. Of course it is best not to lie to law enforcement authorities
so
the question about how many removable cartridges are in use should simply
not be
answered!
There are many associated things that can be done to make it more difficult
to
find computer data stored on a removable hard disc system:
· As discussed already, if a removable disc drive is permanently
fitted,
several cartridges containing innocuous data can be stored near the computer
to
mask the possible existence of other more sensitive cartridges.
· some removable disc drives can be detached from the computer system
when not in use so that law enforcement authorities would not even be aware
that
the computer can use removable cartridges (but care is needed to ensure that
loaded software and drivers do not betray the existence of such a drive).
· The removable disc could use both data encryption and a
steganographic
file system to guard against the possibility that it may be found in a
search.
Data Storage Outside the UK
The RIP legislation provides the power to seize the keys that protect data
that
has already itself been seized so an obvious step is to ensure that critical
data is not subject to seizure, for example, by storing outside the
jurisdiction
of UK authorities. If data can be stored in this way, encryption can then be
used, as discussed earlier, to protect access to it without using keys that
can
be seized.
Fortunately there are now many companies that offer users free disc space to
store their computer data at remote locations so anyone who has data that
they
want to store in a way that UK authorities cannot seize has many easy
options to
choose from. One example of an organisation providing free disc space
outside
the UK is:
·
http://www.freedrive.comThere are many organisations offering similar facilities. These not only
store
data beyond the reach of UK authorities but also make it very difficult to
discover the full range of data available to anyone who uses such services.
Techniques That Criminals Will Use
The techniques discussed so far are those that it is sensible for honest
people
to use to protect their email and their stored computer data. Of course,
all of
these techniques are available to criminals as well but there are even more
powerful ways in which criminals can create almost insuperable difficulties
for
law enforcement authorities when faced with stored computer data.
Quite a few of the sites that offer free disc space, also offer facilities
that
allow such space to be shared among a number of users. Some already offer
fully
anonymous access and those that do not can easily be accessed through
services
that provide anonymity. Services offering both shared access and anonymity
seem
ideal for use by paedophiles and others who want to store and share obscene
material without taking the risks involved in storing material on their own
computer systems. It is hard to believe that such evil people are unaware
of
these capabilities but even if they are, the very existence of the RIP
legislation seems certain to publicise their existence and their value in
hiding
criminal activities.
Many other techniques are available to criminals but will not be discussed
here
as they are unlikely to be worthwhile for honest computer users. But when
combined with the approaches described here, these additional techniques
(which
criminals undoubtedly know about) will present law enforcement authorities
with
almost impregnable barriers that will consume enormous resources in efforts
to
overcome them.
Conclusions for Stored Data
The task faced by law enforcement in recovering protected stored computer
data
can be made very difficult by using steganography. While encryption and
steganographic file systems offer extensive protection, the use of ‘physical
steganography’ in the form of removable hard disc drives and cartridges is a
simple and highly effective way of hiding critical data. Moreover, it is
limited only by the ingenuity of a user in physically hiding the disc
cartridges
involved. If necessary any users who want to put their sensitive data
beyond
the reach of UK authorities can easy do so using the capabilities offered by
the
many organisations that now provide free disc storage space combined with
anonymous Internet access.
In consequence PACE and RIP powers for access to stored computer data do not
pose a threat to anyone who is prepared to be careful and well organised
about
the way in which they store and use their computer data.
Criminals who are careful and clever in their use of their computers and the
Internet have many ways of ensuring that their data cannot be seized. In
consequence, there is little reason to have any confidence that the measures
introduced in the RIP Bill will be effective against them. Some less
careful
criminals may be caught but the detrimental impact of the legislation on the
rights of honest computer and Internet users is a high price to pay when it
seems most likely that such criminals would be caught without the need for
such
powers.
Minimising the Risks Posed by Government Access to Keys (GAK)
The powers in the RIP Bill providing for GAK pose serious threats to the
privacy, safety and security of computer and Internet users. A basic and
crucial principle that underpins the use of public key cryptography is that
the
private components of cryptographic key pairs should never be revealed under
any
circumstances but once GAK powers are in place honest key owners can never
guarantee this. In significant measure the implementation of GAK powers in
the
UK will hence undermine confidence in cryptographic security and this in
turn
will undermine confidence in data confidentiality and in digital signatures.
Current cryptographic applications are designed around the principle that
the
private key components of key pairs are kept fully secure but once RIP
powers
come into play design changes will be needed to provide new approaches that
are
not so susceptible to being undermined by GAK.
Short Term Measures
An immediate change that can be made is to reduce the lifetime of
public/private
key pairs. Many users keep the same key pairs for years with the
consequence
that many messages will be encrypted using them. If such keys are seized,
all
items encrypted with them are vulnerable to exposure and this makes it
sensible
to change keys more frequently so that the damage done by the loss or
seizure of
any one key is limited.
The popular PGP encryption programme supports this approach by providing for
a
sequence of data confidentiality keys to be coupled to a single digital
signature key. At the moment PGP does not securely wipe keys once they are
no
longer needed so the key owner has to arrange this manually but it would not
be
difficult to extend the software to automate this process
Another feature needed in PGP is the automatic revocation of any private key
that is exported in plaintext form. The UK Government has said that key
revocation is allowed in the event that a key is seized but there are
ambiguities in their position so it would be better from a user’s
perspective to
ensure that key revocation is completely automatic when a private key is
exposed
by plaintext export. Ian Brown, Adam Back and Ben Laurie have published
proposals for such an extension to the open PGP standard[2].
Perfect Forward Secrecy
If two computers are on-line at the same time the Diffie-Hellman key
negotiation
technique discussed earlier can be used to obtain an encryption key that is
used
just once and then destroyed. Since such a key cannot be seized, this
provides
fully effective message security that is not in any way undermined by the
GAK
powers in the RIP Bill. The use of ‘one-time’ keys is sometimes referred to
as
‘perfect forward secrecy’.
But this approach is more difficult to arrange for email since the computers
involved do not normally use the direct connection needed to negotiate a key
at
the time a message is sent. Instead of on-line key negotiation it is normal
to
use longer-term keys and this means that they become subject to possible
seizure
using GAK powers.
But the protocols used for secure email can be re-engineered to use one-time
keys. Fortunately messages between correspondents tend to run in sequences
of
messages and responses and this means that it is possible to use each
message in
such a sequence to set up the key for the next message so that each key is
used
only once and then destroyed. There is a higher overhead in generating many
more
keys but ways exist to minimise this cost.
When two people want to exchange secure email messages, the originator of
the
correspondence generates a new initial key pair and sends the public key
with
the first message. The recipient then uses this public key to encrypt their
response, which also contains a new public key. When the originator receives
this message they use the initial private key to decrypt it and then
immediately
destroy this key. If they want to continue the exchange they use the public
key
in the message they have just decrypted to do this and send a new public key
for
use in the next response.
It can hence bee seen that even email can be engineered to use one-time
keys.
Provided that decryption with such one-time keys is always followed by
immediate
key deletion, GAK powers are of no use in decrypting any intercepted
messages.
This is more complex than current secure email approaches since users do
have to
store a number of ‘one-time’ private keys until they are used in message
replies. These keys would be subject to seizure prior to their use but in
this
situation a user is free to revoke them and hence ensure that they are not
used
in protecting any future messages.
In fact this is one of several approaches that can be used to ensure that
GAK
powers are ineffective. The extension to RFC2440 to specify such new
approaches
has already been published and work is already being planned to add these
capabilities to existing encryption applications. As in other areas,
therefore,
RIP Bill powers will be obsolete and ineffective almost as soon as they are
introduced.
Conclusions
The technical thinking behind the Regulation of Investigatory Powers Bill is
inept. Criminals can easily circumvent the measures envisaged and the ways
in
which they are likely to react will actually pose much more serious problems
for
UK law enforcement authorities than the problems the legislation is intended
to
solve. At the same time the measures will damage confidence in cryptography
and
this will be detrimental to the privacy, safety and security interests of
honest
individuals and businesses and to the UK’s aspirations in e-commerce.
mm0...@freeuk.com