[Bloat] Off-topic: What to Make of the U.K.’s New Code of Practice on Internet-of-Things Security

[David Collier-Brown]

I'm pleased to have seen this discussion on lawfare, 
https://www.lawfareblog.com/what-make-uks-new-code-practice-internet-things-security

Instead of proposing frozen, unmaintainable devices, they expect 
updates, and note that a major UK retailer pulled an insecure product 
because it couldn't be updated.

--dave

-------- Forwarded Message --------
Subject: 	What to Make of the U.K.’s New Code of Practice on 
Internet-of-Things Security
Date: 	Tue, 15 Jan 2019 10:26:40 -0500
From: 	Jack Watson <>, Beau Woods <>



What to Make of the U.K.’s New Code of Practice on Internet-of-Things 
Security

Across the globe, the rapid pace of technology development has made it 
difficult to govern emerging tech effectively. Policymakers struggle 
with several primary issues, including knowledge of the subject matter, 
the potential impact on the pace of innovation, and the rapid rate of 
adoption. The United Kingdom’s “Secure by Design” 
<https://www.gov.uk/government/publications/secure-by-design> program 
intends to meet these challenges, as well as take steps to position the 
country as “best place in the world to do digital business.” As Brexit 
continues, and Britain’s finance sector looks to jump ship, such a goal 
is as timely as it is necessary. At its core, the program will create 
powerful tools for policymakers, industry, consumers, retailers, and 
others. The final U.K. “Code of Practice 
<https://www.gov.uk/government/publications/secure-by-design/code-of-practice-for-consumer-iot-security>” 
for internet-of-things security released on Oct. 14, 2018 by the 
Department for Digital, Culture, Media and Sport in conjunction with 
GCHQ’s National Cyber Security Centre <https://www.ncsc.gov.uk/guidance> 
offers one of the clearest policy positions articulated yet by any 
national government. It sets out a technically literate policy that will 
drive manufacturers to innovate more efficient ways to protect 
internet-connected consumer devices, through market and regulatory 
incentives.

By its own terms, the code of practice—and, more broadly, the Secure by 
Design program—seeks to “support all parties involved in the 
development, manufacturing and retail of consumer [internet-of-things 
devices].” To support this goal, the release is accompanied by awareness 
and educational documents, technical standards guidance, and an 
implementation plan, all of which show the U.K.’s commitment to a 
leadership role in securing the internet of things. The fact that the 
code is translated into eight languages, including Mandarin 
<https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/748194/054718_DCMS_IoT_Code_of_Practice_MANDARIN.pdf>, 
Korean 
<https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/748193/054718_DCMS_IoT_Code_of_Practice_KOREAN.pdf>, 
French 
<https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/748190/054718_DCMS_IoT_Code_of_Practice_FRENCH.pdf>, 
German 
<https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/748191/054718_DCMS_IoT_Code_of_Practice_GERMAN.pdf> 
and Japanese 
<https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/748192/054718_DCMS_IoT_Code_of_Practice_JAPANESE.pdf>, 
is crucial in showing that the U.K. intends to be a global trendsetter, 
but it also reflects the global nature of the markets, supply chains and 
security threats, as well as resilience and confidence in consumer 
internet-of-things devices. A common or coordinated international 
approach increases adoption speed, reduces transactional friction, and 
increases consumer confidence across global markets.

Finally, the implementation plan for the Secure by Design program 
demonstrates GCHQ and DCMS know well the current cybersecurity climate 
writ large. Like the United States, the U.K. has identified a 
significant shortage of trained cyber security professionals. This, 
compounded by the rapid development of internet-of-things devices, 
rollout of 5G, and other technical advances, means there is a lack of 
capacity to protect internet-of-things products and services from 
increasingly complex cybersecurity dangers. The U.K. wants to see the 
code ensure that devices flooding into homes and companies are equipped 
with necessary capabilities for owners to protect themselves—through 
voluntary, market-driven measures ideally, though if that fails they 
will “make these guidelines compulsory through law 
<https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/686089/Secure_by_Design_Report_.pdf>.” 
Consumer awareness, education, and labelling will empower buyers to make 
well-informed decisions and give citizens knowledge to take advantage of 
these capabilities. Finally, NCSC-sponsored CyberFirst summer courses 
will train the next generation of technology professionals to defend 
against security threats to internet-of-things devices.

*What the Code of Practice Is—And What it Isn’t*

Many early 
<https://www.theregister.co.uk/2018/10/15/iot_security_gchq_ncsc/> 
criticisms 
<https://securityledger.com/2018/03/uk-internet-of-things-security-report-lacks-enforcement-gets-cool-reception/> 
of the code are premised on a superficial understanding 
<https://blog.erratasec.com/2018/10/notes-on-uk-iot-cybersec-code-of.html> 
of the program and emerging solutions. At its core, the code details 
several positive, practical steps for device manufactures across the 
supply chain and product lifecycle. For instance, botnets like Mirai 
<https://www.theguardian.com/technology/2016/oct/26/ddos-attack-dyn-mirai-botnet> 
and others gain their destructive power by taking over large numbers of 
internet-connected computers or devices. Steps that the code recommends, 
like prohibiting default passwords and keeping software up to date, 
limit the speed and scale of a botnet’s growth, thus diminishing their 
ability to do harm. The code guides manufacturers away from common 
patterns of security failure that create openings for many types of 
threats, including botnets, and towards those that tend to be more 
successful. We outline the top three recommendations, as well as a few 
others worthy of note. (The paragraph numbers used below are from the 
document itself and do not necessarily reflect our ranking).

1. /No default passwords. /Passwords are meant to restrict access to 
systems only to those who know them. Default passwords, like “admin” or 
“password,” ensure anyone can know them, thus defeating their utility 
when defaults are published, well-known, or easily guessable. Many 
devices already ship with unique passwords, requiring a change on first 
use. Default and common passwords on internet-facing interfaces (such as 
Telnet and SSH) allow network worms like Mirai to propagate very 
quickly, though improving security of other interfaces also improves 
“security by default” for internet-of-things systems.

2./Implement a vulnerability disclosure policy. /As more of the “things” 
around us depend on software and become exposed to the internet, more 
adversaries will take advantage of their flaws. A coordinated 
vulnerability disclosure policy invites allies, acting in good faith, to 
report these flaws to the manufacturer so they can be fixed. The device 
maker has an obligation to acknowledge and address issues in a timely 
manner. (The leading international standard for coordinated 
vulnerability disclosure, ISO 29147 
<https://standards.iso.org/ittf/PubliclyAvailableStandards/c045170_ISO_IEC_29147_2014.zip>, 
calls for acknowledgement in 7 days. And the Code’s additional 
explanatory notes section makes a case for manufacturers to address the 
issue in less than 90 days.)

3./Keep software updated. /Software updates can address bugs and 
vulnerabilities once manufacturers know about them. Most 
internet-of-things devices have the capability for software updates 
today, though laggards still exist. For instance, a major U.K. retailer 
removed GPS watches made for children 
<https://www.bbc.com/news/technology-41652742> over concerns that they 
were insecure and could not be updated. The code goes further and asks 
manufacturers to preserve basic functions during an update and that the 
update process be secured. The code also asks manufacturers to disclose 
a minimum timeline for software updates and makes provisions for devices 
or components that cannot be updated through software, noting that the 
manufacturer can replace them—in fact, under U.K. law they must repair 
or replace faulty products for 6 years 
<https://www.citizensadvice.org.uk/consumer/somethings-gone-wrong-with-a-purchase/claim-using-a-warranty-or-guarantee/>.

6. /Minimize exposed attack surfaces./ The code aims to eliminate 
exposure and attack surface where the value to the consumer is 
outweighed by the risk associated with the vulnerability. Many devices 
already minimize feature sets due to resource constraints. With better 
hardware capabilities at lower cost, the trade offs for increasing the 
number of exposed services to the internet or taking a default-enable 
approach to elective services.

9. /Make systems resilient to outages./ Boosting resilience to outages 
will be increasingly important in coming years, as internet-of-things 
infrastructure changes, such as migrating to a new domain, end of life, 
going out of business, and other circumstances impossible to predict. 
Mature design processes include failure-mode analysis to guide how the 
device will perform during different environmental or system failures. 
This can mean the device notifies the person it’s in some kind of 
degraded mode or that mechanical systems replace software-driven ones. 
My Amazon Echo tells me when my internet connection (or its servers) are 
out, and internet-connected locks usually have mechanical keys as 
backups when connectivity or power are unavailable.

10. /Monitor system telemetry data./ Mobile phones and apps send masses 
of telemetry information back to their developers, who can analyze and 
improve the products as well as look for security or safety anomalies. 
Microsoft, Apple and Google detect emerging threats against their 
products and issue updates to address them, while doing so in a 
privacy-neutral way.

Threats, vulnerabilities and industry practices change over time. The 
code of practice is a snapshot in time, meant to be goal- or 
outcome-based rather than prescriptive, so organizations can adapt as 
necessary while still hitting these objectives. It isn’t meant to 
supplant technical standards, but instead the U.K. government has mapped 
the code to technical standards for ease of implementation.

Securing systems may increase cost of doing business, and eventually the 
price of consumer goods. On the other hand, buyers and owners already 
bear costs for insecurity. Widescale harm from events like WannaCry 
<https://www.theguardian.com/commentisfree/2017/may/15/nhs-cyber-attacks-ransomware-crisis> 
and NotPetya 
<https://www.theregister.co.uk/2018/06/27/notpetya_anniversary/> greatly 
escalate those costs, including harm to third-parties through no fault 
of their own <https://en.wikipedia.org/wiki/The_Market_for_Lemons>. In 
conversation, U.S. and U.K. retailers have mentioned costs associated 
with employees educating consumers and increased rates of return for 
security issues.

Manufacturers are in the best position to reduce systemic cost and risk, 
as their available options are much greater than those of owners. 
Shifting responsibility and costs across the supply chain has been 
difficult in the past, without strong financial or regulatory 
incentives. The U.K. intends to drive these changes through labeling, 
consumer awareness, (if it must) regulation, and (I strongly suspect) by 
requiring devices they buy to adhere to the code.

Crucially, the Department of Digital, Culture, Media and Sport (DCMS) 
has made it clear that they do not intend to reinvent the wheel. An 
accompanying document maps the code against over 100 documents from 
nearly 50 organizations 
<https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/747977/Mapping_of_IoT__Security_Recommendations_Guidance_and_Standards_to_CoP_Oct_2018.pdf>, 
representing “published standards, recommendations and guidance on 
[internet-of-things] security and privacy from around the world.” This 
is, first and foremost, an effort grounded in a practical understanding 
of the problem, the effective approaches, and what has failed in the 
past. DCMS know that manufacturers “are already implementing a range of 
standards,” and the mapping document shows how those efforts fit with 
the code.

While most of the elements of the code are well understood, some of the 
objectives it lays out are only beginning to enter common practice. 
Though they have long been technically possible, these innovative 
approaches have only recently been needed due to increases in attacks 
against internet-of-things devices and buyer pressure for higher 
security, largely among retailers and corporate buyers. Publishing the 
code will serve to stimulate innovation toward better capabilities in 
the hands of more manufacturers, buyers, and owners.

Most device makers should have no problem meeting the objectives laid 
out in the Code within the next couple of years. Several of the world’s 
largest manufacturers have already committed to a similar high-level 
doctrine called the “Charter of Trust 
<https://www.siemens.com/innovation/en/home/pictures-of-the-future/digitalization-and-software/cybersecurity-charter-of-trust.html>.” 
The manufacturers most likely to be impacted are those that buy very low 
cost, low quality devices from China or elsewhere and repackage them 
under a variety of names. These brands tend to exit the market after 
only a year or two, replaced by other brands selling nearly 
identical-looking products from the same factories, making it hard to 
enforce accountability for support. They live on, connected to the 
internet, vulnerable and exposed to global accidents and adversaries. 
This kind of market confusion drives out better products leaving buyers 
with low choice and low quality—a market for lemons 
<https://en.wikipedia.org/wiki/The_Market_for_Lemons>.

Yet the code is not a cure-all for every internet-of-things security 
concern. First, it only applies to home, or consumer-grade 
internet-of-things devices. Yet similar technologies—and their 
associated security risks—have been adopted across automotive, aviation, 
maritime, energy, and other sectors. Each of these has distinct 
ecosystems, challenges, and leverage points to evaluate if the U.K. 
wants to apply the code in those industries. Second, the unimplemented 
policies cannot make change, and the Secure by Design program is light 
on how the government plans to achieve market adoption. This will 
inevitably take resources, focus, and time that must be allocated amid a 
turbulent national and global political landscape. Third, global supply 
chains and markets demand international cooperation and collaboration. 
While policymakers have shied away from corralling rapidly advancing 
technologies, such as internet-of-things devices and 5G, they seem more 
willing now than ever before in key regions like North America, Europe, 
and China.

*****

The code is a positive step forward for consumer IoT security and has 
positive traction. HP and Centrica have already formally signed on to 
the code, and others are likely to follow, given the resources the U.K. 
government seems to be putting behind adoption and enforcement. DCMS 
contend that at least eight of the code’s guidelines are already legally 
enforceable 
<https://www.gov.uk/government/publications/secure-by-design/government-response-to-the-secure-by-design-informal-consultation> 
through the U.K. Data Protection Act 
<https://www.gov.uk/data-protection> and GDPR. Germany 
<https://www.bsigroup.com/en-GB/about-bsi/media-centre/press-releases/2018/may/bsi-launches-kitemark-for-internet-of-things-devices/> 
and the EU 
<https://ec.europa.eu/commission/news/cybersecurity-act-2018-dec-11_en> 
have begun adopting compatible (though much less effective) policies, 
and in the United States, California’s internet-of-things bill (SB-327) 
<https://leginfo.legislature.ca.gov/faces/billTextClient.xhtml?bill_id=201720180SB327> 
requires manufacturers to equip internet connected devices with 
“reasonable” and “appropriate” security features. (In the deliberations 
captured in the bill’s history, the legislature emphasized that security 
must be both reasonable and appropriate to the device, and that it’s up 
to the device makers to determine that. The code could serve as a good 
model for meeting this standard of care for consumer internet-of-things 
devices.) Globally, policymakers are reaching for clear guidelines and 
implementable solutions, coupled with adverse market pressure for 
companies that come up short.

Most of the internet-of-things devices that ever exist will be designed 
in the future. Policies like the U.K. Code of Practice are meant to be 
forward-looking, driving innovators toward better products. Many of the 
objectives it lays out are commonplace among moderate- and high-quality 
devices, even those at low price points. But the Code will raise the bar 
for /all/ manufacturers and reduce susceptibility to cyber security, 
safety, and privacy issues. And it will give retailers and consumers a 
common measuring stick for comparing devices.

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