The problem of Securing the New iPad 3 within Business

Apple announced the latest edition of their fantastic iPad today, not only is this device irresistible for consumers, but it has become irresistible for business.  This presents a new challenge for information security professionals, as the iPad has been bred for consumerization not for business usage, yet the business application capability of tablets are undeniable. Within main stream businesses up and down the land a change is afoot, it is no longer about giving the odd few magpie like senior executes the latest shinny new toys, as there is an unquenchable thirst for Apple’s latest tablet gadget emanating across entire businesses.

This is not a time to have heads buried in the sand and wishing for risk aspects of business usage of tablets to go away, the tablet is coming to a business near you. In a few years from now they will be as common place on office desks as laptops, and will be smugly grasped by the majority of attendees within meeting rooms. But let us not forget, a corporate used and connected iPad will have the very same type of confidential information to that of a corporate laptop, therefore you would expect the same policies and controls to apply, right? Well perhaps not.

The information security problem is not a problem of control even though iPads are a consumer led invention, as there are third party solutions from the likes of MobileIron which can centrally enforce security controls on iPads within the enterprise. No, it is a problem of risk acceptance.

One of the key fundamental appeals of a tablet is its accessibility, namely it’s “pick up and go” ease of use. But in applying best practice mobile device information security policies and controls to tablets, we find this seriously starts to hinder the device’s accessibility. This trade off kills a key advantage of having the device in the business in the first place. For example a typical best practice mobile device information security policy applied to laptops, which is typically centrally enforced in large businesses, requires users to have an at least 8 character password consisting of upper/lower case alpha, numeric and special characters, and an automatic password lock timeout of ten minutes when the laptop is unused.  We could use a third party solution within the enterprise to enforce the same mobile device policy onto the business’s iPad estate. However in forcing a complex long password to be entered every time someone picks up their iPad, will no doubt be a trade off too much to stomach by many, as it kind of defeats the advantage of having an iPad in the first place.

So what if we were to weaken the mobile security policy to accommodate a better accessibility of iPads, for example enforcing 4 digit passcode with a 30 minute lockout. The question now is shouldn’t the same policy now apply to the laptop and desktop estate as well? I don’t have the answer, and there isn’t really a best practice business tablet security standard to follow at present, so it would come down to a business’s own risk assessment, and ultimately risk acceptances. As this is a business decision, and it was the business that decided to considerably invest cost in bringing the tablets into the enterprise in the first place, it is more than likely we will see security policies and enforced controls will be more relaxed on iPads than on laptops.  Hats off to any security manager which maintains the same mobile device standard on iPads and laptops. I think accepting lack security controls on tablets will be more the typical approach taken by business. The lack of IT enforcement on the iPads transfers risk over to the user, the problem here is most businesses still don’t do employee security awareness very well.

SmartPhone App Security Advice

Smartphones really are a fraudster’s paradise, there are so many opportunities for fraudsters to monetise from them. From Rogue Malicious Apps sending premium rate text messages costing up to £6 a text, to stealing the personal information and passwords held on them. And there are even further fraud opportunities with smarphones being increasingly used for making Payments and with Online Banking. These factors together with a general smartphone user security naivety, are a major incentive for the bad guys to target these little handheld cash cows.

So it is no surprise cyber attacks targeting smartphones are rapidly increasing in the UK, "800% increase in cyber attacks on smartphones" (Nov 11) http://www.mirror.co.uk/news/top-stories/2011/11/07/800-increase-in-cyber-attacks-on-smartphones-115875-23543307/.   In this post we will look at how to go about protecting against one of the most commonly successful attacks at the moment, namely safeguarding against rogue malicious Apps.

Rogue Smartphone Apps
Most malicious or "Rogue" Smartphone Apps are Trojan Apps. A Trojan App can look very professional within the AppStore and once downloaded may well operate as expected and serve the purpose you wanted it for. However once downloaded and used, a Trojan App will perform malicious operations without your knowledge in the background. So the App may well be an entertaining game you play, but as you play the App sends premium rate text messages, suppressing all text message notifications on your phone, so you don't know its happening. The monetisation of the scam is the text messages are going to a premium rate line operated by the fraudsters, costing you £3 each time the App texts. You may not find out until your mobile phone company gets in contact or you clock very high text message costs on your bill. Of course by this time the bad guys will have cashed out and closed the text line.

Rogue Trojan Smarphone Apps can potentially appear within any of the major AppStores, whether it is operated by Apple (iPhone), RIM (Blackberry), Microsoft (Windows 7) or Google (Android).  Most of these suppliers do perform security testing against Apps for malicious elements before allowing them to be placed in their AppStores.  However it is fair to say the majority of rogue Apps have appeared on Google's Android, with Google removing 27 Rogue Apps just last month (Dec 11). http://www.bbc.co.uk/news/technology-16177013.

Given the 100,000s Apps in AppStores today, and the 1,000s of new Apps which are released every week, there is always the potential new rogue Apps could slip through any of these smartphone heavyweights AppStore security nets, therefore user vigilance is necessary.

5 Steps to Protect Against Rogue Apps

1. Be sure to update your Smartphone (operating system) software as often as possible. These updates often add security features and resolve security vulnerabilities, which can prevent Rogue Apps successfully operating.

2. Before downloading a new App, check and read through the reviews of the App. If the App is dodgy and has been around for a while, no doubt someone will have complained and added a warning in a review.

3. Be careful when allowing an App access to functions and information on your smartphone. Most smartphones have a security feature built in which requires the user to agree to provide an App with access to the various smartphone functions. For instance it doesn't bode well if an App is requesting permission to access your phone book when it is just a game. Don't blindly tap yes on such requests, always ask yourself whether the App really needs the function or information it is asking for, in order for it to work.

4. Rogue Trojan Apps perform functions in the background.  These functions can have a great impact on your smartphone's performance and battery life. So if your battery is draining much quicker than usual, or your phone is becoming more sluggish following the installation of a new App, be suspicious.

5. Check your mobile bill regularly. Typically most rogue Apps in the UK today, secretly send text messages to premium rate lines, therefore it is prudent to check your phone bill for any unusual or unexpected charges. Make it a habit to check your bill at least once a month or straight away if you suspect something is amiss.

Other Related Posts:

Securely Wiping your Personal Data from the iPhone

iPhone Security Guide

Why PCI DSS is good for Information Security

There is a growing consensus within the Information Security Community that the Payment Security Industry Data Security Standard (PCI DSS), is actually proving to be detriment to the general information security across the business. One point regularly made is the Payment Card Industry standard is responsible for diverting precious funding and resource away from the overall business information security strategy, where the breach risks can be much greater for the overall business.  That well maybe the case in larger enterprises which rightly regard best practice information security as a business priority, but consider the medium to small businesses, this is the land where information security ignorance is bliss. Within such SMEs 

PCI can be a real InfoSec wake up call, as in merely attempting to comply with the many PCI DSS requirements, it can provide benefits across the business, where before the business were previously completely unaware of the risks, or perhaps hadn't being treating risks with the proper regard. Forcing them into action to meet the specific PCI requirements, often results in security improvements across the entire business, so not just tightening the security of credit card data in their possession, but personal and confidential information as well.

Love it, Or Hate, PCI does business good

The truth of PCI DSS is most of its laid out 260 odd individual requirements, which set the minimum baseline for PCI compliance, are just best industry information security practices anyway. So businesses are supposed to be doing the lion share of them already. What PCI DSS does in the small to medium business environment (when taken seriously), it forces businesses to take note and ultimately implement these best practices, and in most cases  applying security improvements holistically across the business. For instance measures such as establishing a good patch management process, Anti-Virus deployment and information security policies are applied and benefit the entire business, not just within the cardholder environment, so the business ends up killing many data protection birds with one stone.

Today 90% of the card fraud in the UK occurs within level 4 merchants (the smallest of businesses), specifically due to web application vulnerabilities, vulnerabilities which have been around for over 10 years. Yet if these businesses were PCI DSS compliant, it would be fair to say the majority of these breaches just wouldn't occur This statistic is actually testament to the success of PCI DSS in medium to small businesses, in that larger companies (level 1 to 3), have been chased and forced to address compliance with PCI DSS by acquiring banks, opposed to the highly breached small businesses which have yet to be vigorously chased for compliance, but given the latest fraud stats, they soon can expect to be chased for compliance.

I am not saying PCI DSS is perfect, lord knows it isn't, and I do understand the arguments made by infosec leaders working within larger enterprises, which already focus on information security as a business service priority. But I find it very hard to argue that PCI DSS is not helping medium to small businesses not only protect cardholder data, but to improve their general information security, even if they aren't strictly fully compliant with the standard. As in trying to comply and to meet most of the PCI DSS requirements, it seriously reduces their breach risks, not just of cardholder data, but with the personal data they hold as well.

One final point I want to be crystal clear on, a business cannot be considered PCI DSS compliant if they are not meeting all of the PCI DSS requirements, not just on the date of PCI assessment, but for 365 days a year ,7 days a week, 24 hours a day. The QSA's successful Report on Compliance will not save a business from fines, if a breach were to occur due to the business not meeting just a single compliance requirement. How many businesses are truly compliant in this way is up for debate.

Securely Wiping your Personal Data from the iPhone

It seems like every year Apple release a better 'must have' version of the amazing iPhone, sparking a rush to upgrade by the masses. Ensuring all your precious personal information is securely removed from your old iPhone is an essential step to take before trading in or selling your old iPhone on eBay. Like any smartphone, the iPhone hoards all types of sensitive information about you, not just your embarrassing ABBA playlist and dodgy drunken pictures from the weekend, but all your Emails including access to future mails, username and passwords for websites and social media, and even sensitive financial information such as bank account and credit card details are often stored. So unless you are putting your iPhone through an industrial crusher, you really need to ensure you erase all the data from it before passing it on, this post explains how.

This data erasing advice and method also applies to the iPad and iPod Touch

If your old iPhone is a 3GS or an above model, then securely erasing your personal data is simple enough. The 3GS and above iPhone models comes with built in hardware encryption by default (not that you can switch it off), namely the iPhone uses AES-256 encryption, which encrypts all data stored on the iPhone to a strong industry accepted standard. This is not to say your personal data is safe if your iPhone is lost or stolen, due to the way Apple have implemented this encryption, however that is the subject of another blog post, the important thing here is all the your personal data that is stored on the iPhone, is strongly encrypted, therefore by merely deleting the encryption key securely from the iPhone (and everywhere else), will render all the personal data inaccessible.

Built into the iPhone iOS is an option to erase all the data on it and restore it to factory conditions. Apple states the encryption keys are removed (which doesn't take long) and then a series of ones are written to the entire data partition, which is why it takes a couple of hours to complete the process.

"When you opt to “Erase All Content and Settings,” the process can take up to several hours. The time this process takes will vary by device:


Devices that support hardware encryption: Erases user settings and information by removing the encryption key to the data. This process takes just a few minutes.
Devices that overwrite memory: Overwrites user settings and information, writing a series of ones to the data partition. This process can take several hours, depending on the storage capacity of your iPhone or iPod touch. During this time, the device displays the Apple logo and a progress bar." - Apple

The overwrite of the entire data partition with ones post encryption key removal makes the process secure enough to trust in terms of general third party data recovery risk in my personal view, however military organisations and some industries (and the paranoid) may well require further overwrite passes of the data partition with further 1s and 0s, for which there is commercial software available, such as iShredder. If anyone has managed to recover data from an iPhone following Apple's erasing process, I'm yet to hear about it.

How to Erase your Personal Data from the iPhone
1. Backup your iPhone in iTunes, you may well want to restore your personal information to your new iPhone.
2. Make sure the iPhone has power, this process might take a couple of hours to complete, you don't want the iPhone to run out of battery life before finishing.
3. On the iPhone go into "Settings"
4. Then select "General"
5. At the bottom tap "Reset>"
6. Select "Erase All Content and Settings"

6. Tap "Erase iPhone"
7. Wait a couple of hours and you are done.

Finally don't forget to remove the SIM card. The iPhone doesn't store any data on the SIM card but it is a wise precaution just in case your mobile operator doesn't de-active it properly, also its not like the person you are selling the iPhone to needs it anyway.

Internet Troll Stomping

I was featured in The Sun newspaper today in relation to Internet Trolls.  Trolling or a Troll is net slang for an individual who intentionally posts inflammatory, insulting or threatening remarks online. Pretty much anywhere where people can feedback comments on the Internet, such as on Forums, Facebook pages, Twitter, YouTube, Newspaper comments, is often subject to abusive comments. People can say the most extreme things when they think they are protected with the shroud of anonymity, words they’d never dream of saying to anyone face to face. However there are increasingly individuals that post abusive comments which go well beyond the boundaries of decency and taste, these are the individuals which are really regarded as the trolls under the definition.

Recently a troll was convicted for abusing tribute websites of deceased girls, bringing the whole trolling issue into the public arena - http://www.bbc.co.uk/news/uk-england-14907590

You're not as anonymous as you might think
Forget China, the UK is one of the most high-tech surveillance counties in the world, we are most certainly not as anonymous as we might think online.  Many of the suggested workarounds to provide anonymity I hear about just don’t work. For instance Google stores every search you type in, these searches are linked to your physical computer(s), or if you have a Google account, direct to you individually. Google covertly provide all this info to the Police and our government security agencies when requested.  Apple monitor your movements and usage, while phone network providers, Internet Service Providers (ISPs),  Social Network websites all record every little detail about what you do and when you do it.  We do live in an Orwellian 1984 society, just accept it, there is no going back, there is no escape and there is no hiding place online, they’ll catch up with you eventually. All this is not quite as exciting as portrayed by Hollywood blockbuster movies or CSI Miami, just thousands of lines information which is being collected, recording what we are doing online, however the real life law enforcement is just getting to grips in using this vast amount of information, aside from the troll conviction, terrorism prevention and several murder cases, the many arrests and convictions for incitement of riots by individuals online is another example. If you ever did want to disappear and live anonymously, the first thing you should do is stop using the Internet!

Here are my comments on The Sun article today (Page 9/15-Sept-11)

"Idiots are very easy to locate
These twisted individuals are idiots — they assume they are anonymous online.
But their internet service provider can track their IP address and hand over their details to the cops.
Everyone has an IP address for their internet account which is linked to their name, address and any other details they gave to set up the account.
If the police want to track someone posting abusive messages, they simply speak to the internet service providers who have a record of everything which is written online.
There are some things you can do to limit the chances of being attacked.
Only be Facebook friends with people you know and trust. Parents can also make themselves friends with their kids, to monitor anything going on.
There are no instant answers to eradicating this kind of cyber-bullying, but if kids get educated about the internet they can avoid it much more easily.
The internet has the very best of life, but also the very worst."

Trolling Advice

1. Prevention
Trolling can be simple to prevent in certain circumstances. If you have at webpage at risk, which has the ability to enable comment pre-screening, namely you or other trusted individuals approving all comments before they can be posted, do it, as it will almost certainly prevent trolling. Trolls won’t even bother to make a remark if they know their comments are going to be checked before they are posted.

2. Dealing with Trolling Incidents
Trolling is most definitely illegal as per the Communications Act 2003, Section 127.  Therefore if you are a victim of trolling, by that I mean abusive comments which go beyond the pale of decency, consider reporting them to your local Police. http://www.police.uk/

http://www.legislation.gov.uk/ukpga/2003/21/section/127
127Improper use of public electronic communications network
(1)A person is guilty of an offence if he—
(a)sends by means of a public electronic communications network a message or other matter that is grossly offensive or of an indecent, obscene or menacing character; or
(b)causes any such message or matter to be so sent.
(2)A person is guilty of an offence if, for the purpose of causing annoyance, inconvenience or needless anxiety to another, he—
(a)sends by means of a public electronic communications network, a message that he knows to be false,
(b)causes such a message to be sent; or
(c)persistently makes use of a public electronic communications network.
(3)A person guilty of an offence under this section shall be liable, on summary conviction, to imprisonment for a term not exceeding six months or to a fine not exceeding level 5 on the standard scale, or to both.
(4)Subsections (1) and (2) do not apply to anything done in the course of providing a programme service (within the meaning of the Broadcasting Act 1990 (c. 42)).

Evolution of UK Home Banking Security - In progress?

I was featured in an article by MSN Money titled "Online Banking Security gets more Complex"

http://money.uk.msn.com/news/crime/articles.aspx?cp-documentid=159017310

Nothing ground breaking, but it would appear UK banking consumers are starting to feel the pain of increased online banking security trade-offs, due to UK banks trying to save money by cutting previously acceptable losses from online account fraud.

"One person, one bank: three devices

But despite the evidence that new measures are more than just inconvenient, many banks are pressing ahead. Lloyds, Barclays, Cooperative Bank, RBS and Nationwide Building Society all require customers to use a card reader when amendments are made to standing orders, direct debits or when setting up payments.

"This is called two-factor authentication," said independent bank security expert Dave Whitelegg.

How two-factor authentication works
The idea is that no fraudster can access your account, however much they know about your life, your pets and your mother's maiden name, unless they also physically possesses the device. "It's the same theory as for chip and pin," Whitelegg told MSN.

Chip and pin dramatically cut credit card fraud, and banks are hoping that two-factor identification will have the same effect on online bank fraud.

The biggest worry for banks is phishing attacks, by which fraudsters send emails hoping to get customers to log into cloned bank websites and enter their details, which are then captured and used to empty the real accounts.

"Phishing emails are sent out by the million, so even if 0.1% of recipients fall for them, they are a success," Whitelegg said.
Most such phishing attempts are easy to spot, failing to address the customer by name and littered with bad grammar and mis-spelling. But a new generation are more convincing. They may not only have your name, but much more convincing cloned websites.

Mobile banking: a worrying new frontier
The next frontier in banking fraud is coming with smartphones, which are increasingly enabled for transactions, but which experts say add a new vulnerability.

"They have never been targeted before, so they have never matured with fraud in the same way that PCs have," Whitelegg said.

Sending a text to confirm payment changes, which Santander among others allows, will become less secure if the entire transaction was originated from a stolen mobile.

So who are the people behind online fraud? There is a whole ecosystem out there, with software masterminds writing key logger and phishing programmes and devising convincing copies of bank websites. Then there are communities of hackers and fraudsters who meet online, and buy this software off the shelf, Whitelegg says.

"You have the people who steal cards, or personal data, who can be from anywhere, and then there are the Far Eastern networks of botnets, clusters of remotely controlled computers, which actually generate the phishing attacks," Whitelegg said.

The result is that just a few clever people have seeded a whole crime industry for thousands of criminals who would never have the brains to devise the whole process themselves.

How you can protect yourself
There are no absolutely foolproof ways to avoid data or identity theft but here are a few sensible precautions.

1) Treat your personal data like cash: Don't leave it lying around. Shred unwanted documents, don't disclose financial details or potential answers to security question (eg your mother's maiden name) except on verifiable and encrypted sites.

2) Use reputable anti-virus software and keep it up to date.

3) Never download an attachment from an untrusted source as it may contain viruses.

4) Phishing attempts usually begin with alarming warnings about a breach of your security. Banks never alert their customers this way. Even if you are concerned by an email, either ring your bank, or type in the web address from a bank statement. Never follow a link on the email.

5) Change your email address so it's not identical to your real name as used in any financial accounts, so you can easily spot crude phishing attempts which address you by your email name.

6) If you must write down passwords or security details, disguise them. This is particularly important if they are kept on a computer. Use a long and secure password to 'lock' laptops.

7) When inputting details onto a bank website, don't input them in the same order as the questions appear, and use the mouse rather than tab buttons to move around the screen. This can help foil key loggers and other trojan devices.

8) Go ex-directory: keeping your phone details out of circulation stops most phone-based frauds as well as irritating sales calls.

9) If your bank phones you unexpectedly, protect your interests by asking THEM a security question. Ask what your balance was on the date of your last statement, or a recent transaction that you can check. Banks will not ask for online security codes by phone, so don't give them. If in doubt say you are going to ring them back on the usual customer service number."

How to comply with the EU Cookie Law in the UK

There is still much confusion and to be completely frank, some plain old nonsense being sprouted about the so called EU Cookie Law. So I thought it is high time to explain what it is all about, and specifically what UK businesses should be doing about complying with it. I am not a lawyer or an EU Law expert, therefore you should regard this blog entry as guidance and personal opinion. Having said that, it has not escaped my attention, there are some in the legal profession that are jumping on the EU Cookie Directive bandwagon in order to make a quick buck, and even providing very questionable technical advice to UK businesses.

If you are already in the know with this issue, you may just want to skip to the bottom paragraph, where I provide my advice – “How to comply with EU Cookie Law and avoid Fines.”

What is the EU Cookie Directive and its requirements?

All member countries (states) of the European Union are obligated to adopt EU Directives. One such EU Directive, known as the “Privacy and Electronic Communications Directive”, and also known as the “E-Privacy Directive”, was amended in 2009. The controversial addition involves requirements around the usage of website cookies, which applies to all websites servicing European Union citizens.

The updated Directive came into force on 26 May 2011, which means all EU countries should have brought the new requirements over cookie usage into law. There is some leeway and discretion on how Directives are interpreted by each individual EU member country.  However most EU countries haven’t done anything about meeting the new requirements at all, only Denmark and Estonia have attempted to comply by the deadline.

Meanwhile in the UK, the government has deferred the new directive requirements for a year while they try to work out a common sense way for UK businesses to comply with the updated Directive requirements, remember the government has some leeway on how meet the directive’s requirements. The Department of Culture, Media and Sports (DCMS), the Information Commissioners Office (ICO), and other commercial government departments are currently reviewing how the UK will comply. The ICO, who are responsible for enforcing data protection laws in the UK, has stated it expects UK businesses to be activity working towards compliance, even though no clear practical government requirements or advice has been set out. enforcement_cookies_rules_news_release

What is a Cookie anyway & is my business affected?

Nearly all websites and web applications use cookies, which are often stored locally on a website consumer’s PC, and are commonly required for functions such as tracking user login, remembering user personal preferences, tracking visitors and advertising. Therefore the implied change of law will affect all UK businesses which have websites. A full explanation of ‘cookies’ can be found at http://www.allaboutcookies.org/

What are the new EU Directive Cookie Requirements?

In simple terms, the change means all UK websites must provide information on their cookie usage. This is not a major business issue, just additional text to the website privacy statement, which explains how cookies are used on the website, and what information they hold. I have to say this requirement actually does make good sense.  However there is another new requirement in the Directive, which is causing all the controversy and confusion, namely that websites must obtain user consent before they use a cookie.

http://eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=OJ:L:2009:337:0011:0036:En:PDF

“Article 5(3) shall be replaced by the following:

‘3. Member States shall ensure that the storing of information, or the gaining of access to information already stored, in the terminal equipment of a subscriber or user is only allowed on condition that the subscriber or user concerned has given his or her consent, having been provided with clear and comprehensive information, in accordance with Directive 95/46/EC, inter alia, about the purposes of the processing. This shall not prevent any technical storage or access for the sole purpose of carrying out the transmission of a communication over an electronic communications network, or as strictly necessary in order for the provider of an information society service explicitly requested by the subscriber or user to provide the service.’

Cookie Usage Consent

Cookie usage consent on a website is a pretty crazy idea, as the Directive implies every time you visit any website, a pop-box or an in screen warning box appears, which forces you to tick a box before allowing you to access the website. As I said the vast majority of websites on the internet need to use cookies, and they just can’t work without them.  I have previously blog ranted about this before -

http://blog.itsecurityexpert.co.uk/2011/03/eu-cookie-wars-nanny-state-vs-common.html

Why has this change in law?

The intent of the EU Cookie Directive is to protect all individual European citizen’s privacy rights, as cookies can be used to track an individual’s interests, which can be exploited by third party advertisers. I guess the folks at Brussels think it is in our own best interest, for them to create laws to protect us from this practice, no matter how high a price the inconvenience trade off is, a trade off which affects millions of daily European web users, a trade off which would be totally unacceptable to the vast majority of web users.

There is little doubt the vast majority of the UK public just don’t care about this law or cookie usage. Privacy is the currency and price we knowingly pay for using ‘free’ online services. Web services as provided by the likes of Google, Facebook, YouTube, news websites, the whole of e-commerce, free information sharing like this blog, these are the foundation of the Internet’s success, and so are the essence of how the web revolution has changed and driven human kind, in a way like no other human invention.  The reason why these amazing web services we take for granted are free to use, is they are paid for by advertisers, advertisers who feed off our privacy. For instance as I compose a Gmail Email, if I write about mountain climbing, sure enough unobtrusive advertisements offering to sell me outdoor equipment will appear on the right side of the page.  Does this bother me? No, all it is targeted marketing, and is really no different than advertising a beer brand at a football match, it’s the same type of targeted advertising, made against people’s predicted “wants” based on their interests, this is just the capitalistic world we all live in. Marketers would argue this type of advertising benefits consumers, as it presents consumers with only products they have an actual interest in.

There are more pressing privacy laws to which the EU should be focusing.  The public do care about companies breaching and losing their personal information a lot more than cookie exploitation. Yet private business still has no legal obligation to publicly disclosure EU citizen personal data breaches in the UK. I have previously blogged about this as well - http://blog.itsecurityexpert.co.uk/2009/01/why-uk-data-breach-disclosure-laws-are.html

Common Sense Solution for those who do Care about Cookies

For the very few individuals who do care about cookie usage, there is a simple solution they are probably doing already. Anyone can set consent (prompt) for all cookie usage within their web browser configuration, so a pop-up appears every time a cookie wants to be created or is changed. My sources tell me this will be very likely be the UK government response to the EU Directive, namely introduce a law which mandates the placing of instructions on the website, explaining to users how to set their web browser to screen cookie usage.

Although I still very much doubt if anyone would put up with nagging Cookie pop-ups for too long.  At a talk on this, someone raise a point that in their business they still operated an old browser, where cookie consent couldn’t be set. He said their business used a web browser that was several years out of date as they feared new browsers would break their internal web applications.  My response, “running really old web browser versions, and (due) to out of date business web applications, points to a security hole. Specifically it shows there is a patch management problem to be addressed. Its security 101 to ensure applications, especially web applications, are patched and kept up-to-date, while out of date web browsers (which are also applications) are at a much higher risk of being taken advantage of by malware. Nearly all newer versions of web browsers, whether Internet Explorer, Chrome or Firefox, come with many security and anti-malware features”, this response brought an applause in the room, which suggests a general consensus.

How to comply with EU Cookie Law and avoid Fines
The ICO will be currently satisfied if your business is preparing for a change in law on website cookie usage, and if your business makes an effort to inform consumers about your website’s cookie usage. Therefore, at this time I advise the following approach in order to avoid fines and to prepare for compliance.

1. Conduct an audit of ALL Cookie usage
This business wide audit must cover all Internet facing websites and web applications. Record all cookie usage, including similar technologies like flash cookies, ensure you detail how each cookie is technically being used by the website/web application, and log the type of information stored within the cookie file (on local consumer’s PC). Ensure you note any cookie usage connected with third party advertisements, as these will be the highest concern to the law makers.

2.  If it exists, take a copy of the current website privacy and/or cookie statement

3. Create (or) update the website privacy/cookie statement, to include details of cookie usage. For example, review The Guardian’s Newspapers website cookie statement, which makes an good example covering most types of Cookie usage - http://www.guardian.co.uk/help/privacy-policy#cookies

4. Make sure your privacy/cookie statement explains in plain English what a cookie actually is. http://www.allaboutcookies.org/

5; Provide instructions on how to switch on web browser cookie screening, including all the major web browsers.

So get the audit done and update your website privacy statement accordingly. After all it shouldn’t take too long, and this has a very low cost to deliver. It is the right thing to provide this type of information to your customers, plus it will  protect your business from criticism and fines.

Finally the last step is to wait until there is a further announcement by the UK government.  I suggest not wasting any of your time and money in trying to develop a cookie acceptance box for your website. The ICO website has such an acceptance tick box http://www.ico.gov.uk/, however it is an epic fail, as you don’t need to tick the ICO acceptance in order to use the website!

How will the UK deal with "Consent"
This is speculation, but to my knowledge none of the UK government agencies and departments involved with addressing the EU Directive are even considering a solution which involves the website/web application code blocking a cookie prior to a user accepting it. They are viewing consent as providing clear information to users on cookie usage within websites, together with making web browser suppliers change default cookie settings. The International Chamber of Commerce is currently working on these solutions with ICO.

http://www.international-chamber.co.uk/press/19-icc-uks-response-to-the-new-eu-e-privacy-directive 

http://www.international-chamber.co.uk/blog/2011/07/22/compliance-with-eprivacy-directive/

http://www.culture.gov.uk/news/news_stories/8052.aspx

"the Government has said it will work with browser manufacturers to see if browser setting can be enhanced to meet the requirements of the directive"