Monday 31 December 2012

The Office of Communications v IC

The Information Rights Tribunal has ruled on an ongoing matter about disclosure of the precise location and other details of mobile operators' base stations under the Environmental Information Regulations 2004, holding that Ofcom must release the information supplied to it by mobile operators, including information about the TETRA network, which is used for emergency services communications.

The decision is EA/2006/0078.

The tribunal adopted much of the reasoning of the tribunal which originally heard the case, with some added discussion about the nature of the public interest test and its application, in determining certain qualified exemptions to the regulations.

The result of this case is that, in a few days, a lot of detailed information about cell site locations, power outputs and directions and the like will be released to the applicant in the case by Ofcom. It remains to be seen what the applicant will do with this information — the tribunal acknowledges that the operators' claims to database rights may well be valid, and that, whilst the claimant is entitled to receive these data, it does not get a licence for any act restricted by copyright — but I would have expected it to be posted online.

What do you think? Should this sort of information be made public? Or is it right that it should be kept confidential? Do you think there's a risk here that, if operators cannot trust their regulator to keep information private, they will stop providing information, potentially frustrating a regulator's ability to regulate?

Sunday 9 December 2012

From Freiburg


I'm, along with Steve Saxby, in snowy Freiburg at the moment attending a very interesting conference on the future of the Council of  Europe Cybercrime Convention. It is advertised as a  meeting of experts (about 15 of us). Especially in the later sessions  I have the feeling that I am here under false pretences!

At first  the focus was on substantive law and the specific offences laid down in the Convention. There was a lot of discussion how the technology had moved on since the Convention was drafted. A couple of points which may be of interest. A lot of concern was expressed  that trying to tie criminal  provisions to telecommunications terminology no longer works. The notion of messages being in the course of communication (or not) is problematic. One issue which attract a lot of attention is when and to what extent emails are protected legally against interception? Generally once it has read by the recipient a message  is classed as being stored and ( at least in continental legal systems) gets a lot less protection than when it is being communicated. As one person commented, in the age of the cloud, storage is merely a slow form of communication. In a slightly different context, there is evidence that criminals/terrorists are using email systems such as google or yahoo. Member one can post a message in draft format n the mail server. If member 2 ( or 3 or 4 ...) can access the email box they can amend the message but in traditional terms there is no communication. But  there is communication!

We considered also the need to harmonise the provisions of data protection and computer crime legislation. A linked topic was the suggestion that we need to extend data protection laws to include commercial data (as happens to some extent under the Communications Privacy Directive. This might give criminal law protection to things like trade secrets without having to wrestle with the thorny topic whether data might be consider property. In the UK , and moving away  from Freiburg, there is a very interning High Court decision on the point - Fairstar v.Adkins ([2012] EWHC 2952).

A good deal of time was spent on the topic of copyright law. Perhaps surprisingly, there was little support from copyright owners attempts to involve the criminal law. We has a senior German policeman present and he indicated that the German police were not interested in acting against ordinary users. He recounted a tale of one copyright owner who, with the aid of dishonest lawyers, actually uploaded materials to a file sharing web site and then got the lawyer to demand money with menaces from individuals who had downloaded materials.

Day one saw a bit of momentum for (limited changes to the Convention), At the start of day 2 we heard from a senior Council of Europe person who spoke in some detail about the problems any attempt to make changes would be. What the Council are planning is to make more use of Guidance Notes. There were he considered ( and those of us from the UK will know the truth of his comments) too many misunderstandings by police, prosecutors and judges as to what the legislation means. The criminality  of denial of service attacks was an example he gave. In addition, there might be more protocols attached to the Convention although the basic instrument is likely to email unchanged. A number of new countries ( including Japan) have now ratified the Convention and more are in the pipeline.

The focus of the second day was on procedural issues and we started with a discussion about transborder issues. If police in England execute a search warrant and find a computer with a link to an email account in the United States, can they access it. he general consensus was that laws were rather vague but that law enforcement agencies would access data unless they knew that it was held outside their jurisdiction. A difficult test! There are tensions in the field. We talk much about cyber terrorism and it got publicity in the UK last week with the publication of a Ministerial statement on the working of the UK's cyber terrorism strategy. All countries need to build defences against such attacks but the danger or difficulty is that attempts to pre-empt attacks may involve accessing sites on foreign  territories. The analogy was drawn with sending troops into foreign territories to rescue citizens being held hostage. Politically risky if done without the knowledge and consent of the territory in question.

Perhaps not surprisingly but rather depressingly, there was little confidence in cross border cooperation between law enforcement agencies and aspects of the session had me first baffled by some of the technologies that scientific experts were talking about but also with the feeling that only clever criminals have any real expectation of privacy in the modern world. Encryption poses real challenges to law enforcement and the only real solution identified was to attack suspected computers at source - before data was encrypted for transmission. Again, arrangements for intercepting communications have become more complex in recent  years and again the point came over that there was too much reliance on telecommunications terminology. Can SKYPE be required to maintain a capability to intercept communications at the behest of law enforcement?

I have to say that I can only hope that I have given an accurate account of the procedural discussions. There were times when, although all the sessions were conducted in English, I could have benefited from simultaneous translation of the technologies.

All in all, a fascinating 2 and a half days ( and rather long days). I certainly learned a lot ( and also found an Irish pub to watch the Celtic Champions League game) but suspect we are still at the stage which does make IT law both fascinating and frustrating. We are increasingly aware that old models are not working but are not sure what can replace them. In a networked world we need global solutions but as we can see in the Euro crisis, this is not easy to achieve even at a regional level. The Council of Europe Convention is achieving success in being ratified but it is very general in its provisions, especially at the procedural level.

Hopefully I will be able to post more formal minutes of the meting in a month or so. In the meantime,  maybe this account will be f interest in showing the possible form of future developments.

Tuesday 4 December 2012

"When in China, don't leave your laptop alone"

InfoWorld makes a very bold assertion: "If you travel to China or Russia, assume government or industry spooks will steal your data and install spyware."

Is this something which all companies need to be aware of, from a basic data protection point of view, if employees are traveling with laptops which have on them, or enables easy access to, customer data, to meet the requirement of "appropriate security"?