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Call for Comments: Model Security Standards for the Indian Fintech Industry
https://cis-india.org/internet-governance/call-for-comments-model-security-standards-for-the-indian-fintech-industry
<b></b>
<p>The Centre for Internet and Society is pleased to make available the Draft document of Model Security Standards for the Indian Fintech Industry, for feedback and comments from all stakeholders. The objective of this document which was first published in November 2019, is to ensure that the data of users is dealt with in a secure and safe manner by the Fintech Industry, and that smaller businesses in the Fintech industry have a specific standard to look at in order to limit their liabilities for any future breaches. <br /><br />We invite any parties interested in the field of technology policy, including but not limited to lawyers, policy researchers, and engineers, to send in your feedback/comments on the draft document by the 16th of January 2020. We intend to publish our final draft by the end of January 2020. We look forward to receiving your contributions to make this document more comprehensive and effective. Please find a copy of the draft document <a href="https://cis-india.org/internet-governance/resources/security-standards-for-the-financial-technology-sector-in-india" class="internal-link" title="Security Standards for the Financial Technology Sector in India">here</a>.</p>
<p>
For more details visit <a href='https://cis-india.org/internet-governance/call-for-comments-model-security-standards-for-the-indian-fintech-industry'>https://cis-india.org/internet-governance/call-for-comments-model-security-standards-for-the-indian-fintech-industry</a>
</p>
No publisherpranavFinancial TechnologyCybersecurityinternet governanceInternet GovernanceCyber Security2019-12-16T13:16:25ZBlog EntryAutomated Facial Recognition Systems (AFRS): Responding to Related Privacy Concerns
https://cis-india.org/internet-governance/automated-facial-recognition-systems-afrs-responding-to-related-privacy-concerns
<b>Arindrajit Basu and Siddharth Sonkar have co-written this blog as the second of their three-part blog series on AI Policy Exchange under the parent title: Is there a Reasonable Expectation of Privacy from Data Aggregation by Automated Facial Recognition Systems? </b>
<p> </p>
<p> </p>
<p>The Supreme Court of India, in <a href="https://indiankanoon.org/doc/91938676/">Puttaswamy I</a><em> </em>recognized<em> </em>that
the right to privacy is not surrendered merely because the individual
is in a public place. Privacy is linked to the individual as it is an
essential facet of human dignity. Justice Chelameswar further clarified
that privacy is contextual. Even in a public setting, people trying to
converse in whispers would signal a claim to the right to privacy.
Speaking on a loudspeaker would naturally not signal the same claim.</p>
<p>The Supreme Court of Canada has also affirmed the notion of
contextual privacy. As recently as on 7 March, 2019, the Supreme Court
of Canada <a href="http://www.thecourt.ca/r-v-jarvis-carving-out-a-contextual-approach-to-privacy/" rel="noreferrer noopener" target="_blank">in a landmark decision</a> defined privacy rights in public areas implicitly applying <a href="https://crypto.stanford.edu/portia/papers/RevnissenbaumDTP31.pdf">Helena Nissenbaum’s theory of contextual integrity</a>.
Helena Nissenbaum explains that the extent to which the right to
privacy is eroded in public spaces with the help of her theory of
contextual integrity.</p>
<p>Nissenbaum suggests that labelling information as exclusively public
or private fails to take into account the context which rationalises the
desire of the individual to exercise her privacy in public. To explain
this with an illustration, there exists a reasonable expectation of
privacy in the restroom of a restaurant, even though it is in a public
space.</p>
<p>In <a href="http://www.thecourt.ca/r-v-jarvis-carving-out-a-contextual-approach-to-privacy/"><em>R v Jarvis</em></a> (Jarvis), the Court overruled a Court of Appeal for Ontario <a href="https://www.canlii.org/en/on/onca/doc/2017/2017onca778/2017onca778.pdf">decision</a>
to hold that people can have a reasonable expectation of privacy even
in public spaces. In this case, Jarvis was charged with the offence of
voyeurism for secretly recording his students. The primary issue that
the Supreme Court of Canada was concerned with was whether the students
filmed by Mr. Jarvis enjoyed a reasonable expectation of privacy at
their school.</p>
<p>The Court in this case unanimously held that students did indeed have
a reasonable expectation of privacy. The Court concluded nine
contextual factors relevant in determining whether a person has a
reasonable expectation to privacy would arise. The listed factors were:</p>
<p>“1. The location the person was in when he or she was observed or recorded,</p>
<p>2. The nature of the impugned conduct (whether it consisted of observation or recording),</p>
<p>3. Awareness of or consent to potential observation or recording,</p>
<p>4. The manner in which the observation or recording was done,</p>
<p>5. The subject matter or content of the observation or recording,</p>
<p>6. Any rules, regulations or policies that governed the observation or recording in question,</p>
<p>7. The relationship between the person who was observed or recorded and the person who did the observing or recording,</p>
<p>8. The purpose for which the observation or recording was done, and</p>
<p>9. The personal attributes of the person who was observed or recorded.” (paragraph 29 of the judgement).</p>
<p>The Court emphasized that the factors are not an exhaustive list, but
rather were meant to be a guiding tool in determining whether a
reasonable expectation of privacy existed in a given context. It is not
necessary that each of these factors is present in a given situation to
give rise to an expectation of privacy.</p>
<p>Compared to the above-mentioned factors in Jarvis, the Indian Supreme Court in <a href="https://indiankanoon.org/doc/127517806/">Justice K.S Puttaswamy (Retd.) v. Union of India</a>: Justice Sikri (Puttaswamy II) <strong>—</strong>
the case which upheld the constitutionality of the Aadhaar project
relied on the following factors to determine a reasonable expectation of
privacy in a given context:</p>
<p>“(i) What is the context in which a privacy claim is set up?</p>
<p>(ii) Does the claim relate to private or family life, or a confidential relationship?</p>
<p>(iii) Is the claim a serious one or is it trivial?</p>
<p>(iv) Is the disclosure likely to result in any serious or significant injury and the nature and extent of disclosure?</p>
<p>(v) Is disclosure relates to personal and sensitive information of an identified person?</p>
<p>(vi) Does disclosure relate to information already disclosed publicly? If so, its implication?”</p>
<p>These factors (acknowledged in Puttaswamy II in paragraph 292) seem
to be very similar to the ones laid down in Jarvis, i.e., there is a
strong reliance on the context in both cases. While there is no explicit
mention of individual attributes of the individual claiming a
reasonable expectation, the holding that children should be given an opt
out indicates that the Court implicitly takes into account personal
attributes (e.g. age) as well.</p>
<p>The Court in Jarvis further (in paragraph 39) took the example of a
woman in a communal change room at a public pool. She may expect other
users to incidentally observe her undress but she would continue to
expect only other women in the change room to observe her and reserve
her rights against the general public. She would also expect not to be
video recorded or photographed while undressing, both from other users
of the pool and by the general public. </p>
<p>If it is later found out that the change room had a one-way glass
which allowed the pool staff to view the users change — or if there was a
concealed camera recording persons while they were changing, she could
claim a breach of her reasonable expectation of privacy under such
circumstances and it would constitute an invasion of privacy.</p>
<p><strong>So, in the context of an AFRS, an individual walking down a
public road may still signal that they wish to avail of their right to
privacy. In such contexts, a concerted surveillance mechanism may come
up against constitutional roadblocks.</strong></p>
<p><strong>What is the nature of information being collected?</strong></p>
<p>The second big question <strong>—</strong> the nature of information
which is being collected plays a role in determining the extent to which
a person can exercise their reasonable expectation of privacy.
Puttaswamy II laid down that collection of core biometric information
such as fingerprints, iris scans in the context of the Aadhaar-Based
Biometric Authentication (‘ABBA’) is constitutionally permissible. The
basis of this conclusion is that the Aadhaar Act does not deal with the
individual’s intimate or private sphere.</p>
<p>The judgement of the Supreme Court in Puttaswamy II is in a very
specific context (i.e. the ABBA). It does not explain or identify the
contextual factors which determine the extent to which privacy may be
reasonably expected over biometrics generally. In this judgment, the
Court observed that demographic information and photographs do not raise
a reasonable expectation of privacy under Article 21 unless there exist
special circumstances such as the disclosure of juveniles in conflict
of law or a rape victim’s identity.</p>
<p><strong>Most importantly, the Court held that face photographs for
the purpose of identification are not covered by a reasonable
expectation of privacy. The Court distinguished face photographs from
intimate photographs or those photographs which concern confidential
situations. </strong></p>
<p><strong>Face photographs, according to the Court, are shared by
individuals in the ordinary course of conduct for the purpose of
obtaining a driving </strong>l<strong>icense, voter id, passport,
examination admit cards, employment cards, and so on. Face photographs
by themselves reveal no information.</strong></p>
<p>Naturally, this pronouncement of the Apex Court is a huge boost for the introduction of AFRS in India.</p>
<p>Abroad, however, on 4 September 2019, in <a href="https://www.judiciary.uk/wp-content/uploads/2019/09/bridges-swp-judgment-Final03-09-19-1.pdf">Edward Bridges v. Chief Constable of South Wales Police</a>, a Division Bench of the High Court in England and Wales heard a challenge against an AFRS introduced by law enforcement (<em>see</em>
Endnote 1). The High Court rejected a claim for judicial review holding
that the AFRS in question does not violate inter alia the right to
privacy under Article 8 of the European Convention of Human Rights
(‘ECHR’).</p>
<p>According to the Court, the AFRS was used for specific and limited
purposes, i.e., only when the image of the public matched a person on an
existing watchlist. The use of the AFRS was therefore considered a
lawful and fair restriction.</p>
<p>The Court, however, acknowledged that extracting biometric data
through AFRS is “well beyond the expected and unsurprising”. This seems
to be a departure from the Indian Supreme Court’s observation in
Puttaswamy II that there is no reasonable expectation of privacy over
biometric data in the context of ABBA, and may be a wiser approach for
the Indian courts to adopt.</p>
<h6><strong>Endnote </strong></h6>
<p>1. The challenge was put forth by Edward Bridges, a civil liberties
campaigner from Cardiff for being caught on camera in two particular
deployments of the AFRS a) when he was at Queen Street, a busy shopping
area in Cardiff and b) when he was at the Defence Procurement, Research,
Technology and Exportability Exhibition held at the Motorpoint Arena.</p>
<p> </p>
<p>This was published by <a class="external-link" href="https://aipolicyexchange.org/2019/12/28/automated-facial-recognition-systems-afrs-responding-to-related-privacy-concerns/">AI Policy Exchange</a>.</p>
<p>
For more details visit <a href='https://cis-india.org/internet-governance/automated-facial-recognition-systems-afrs-responding-to-related-privacy-concerns'>https://cis-india.org/internet-governance/automated-facial-recognition-systems-afrs-responding-to-related-privacy-concerns</a>
</p>
No publisherArindrajit Basu, Siddharth SonkarCybersecurityCyber Securityinternet governanceInternet Governance2020-01-02T14:09:14ZBlog EntryAutomated Facial Recognition Systems and the Mosaic Theory of Privacy: The Way Forward
https://cis-india.org/internet-governance/automated-facial-recognition-systems-and-the-mosaic-theory-of-privacy-the-way-forward
<b> Arindrajit Basu and Siddharth Sonkar have co-written this blog as the third of their three-part blog series on AI Policy Exchange under the parent title: Is there a Reasonable Expectation of Privacy from Data Aggregation by Automated Facial Recognition Systems? </b>
<p> </p>
<p><strong>The Mosaic Theory of Privacy</strong></p>
<p>Whether the data collected by the AFRS should be treated similar to
face photographs taken for the purposes of ABBA is not clear in the
absence of judicial opinion. The AFRS would ordinarily collect
significantly more data than facial photographs during authentication.
This can be explained with the help of the <em><a href="https://www.lawfareblog.com/defense-mosaic-theory" rel="noreferrer noopener" target="_blank">mosaic theory of privacy</a></em>.</p>
<p>The mosaic theory of privacy suggests that data collected for long
durations of an individual can be qualitatively different from single
instances of observation. It argues that aggregating data from different
instances can create a picture of an individual which affects her
reasonable expectation of privacy. This is because a mere slice of
information reveals a lot less if the same is contextualised in a broad
pattern — a mosaic. </p>
<p>The mosaic theory of privacy does not find explicit reference in
Puttaswamy II. The petitioners had argued that seeding of Aadhaar data
into existing databases would bridge information across silos so as to
make real time surveillance possible. This is because information when
integrated from different silos becomes more than the sum of its parts.</p>
<p>The Court, however, dismissed this argument, accepting UIDAI’s
submission that the data collected remains in different silos and
merging is not permitted within the Aadhaar framework. Therefore, the
Court did not examine whether it is constitutionally permissible to
integrate data from different silos; it simply rejected the possibility
of surveillance as a result of Aadhaar authentication.</p>
<p>Jurisprudence in other jurisdictions is more advanced. In <em>United States v. Jones</em>,
the United States Supreme Court had observed that the insertion of a
global positioning system into Antoine Jones’ Jeep in the absence of a
warrant and without his consent invaded his privacy, entitling him to
Fourth Amendment Protection. In this case, the movement of Jones’
vehicle was monitored for a period of twenty-eight days. Five concurring
opinions in Jones acknowledges that aggregated and extensive
surveillance is capable of violating the reasonable expectation of
privacy irrespective of whether or not surveillance has taken place in
public.</p>
<p>The Court distinguished between prolonged surveillance and short term
surveillance. Surveillance in the short run does not reveal what a
person repeatedly does, as opposed to sustained surveillance which can
reveal significantly more about a person. The Court takes the example of
how a sequence of trips to a bar, a bookie, a gym or a church can tell a
lot more about a person than the story of any single visit viewed in
isolation.</p>
<p>Most recently, in<a href="https://www.supremecourt.gov/opinions/17pdf/16-402_h315.pdf" rel="noreferrer noopener" target="_blank"> <em>Carpenter v. United States</em></a>,
the Supreme Court of the United States held that the collection of
historical cell data by the government exposes the physical movements
of an individual to potential surveillance, and an individual holds a
reasonable expectation of privacy against such collection. The Court
admitted that historical-cell site information allows the government to
go back in time in order to retract the exact whereabouts of a person.</p>
<p>Judicial decisions have not addressed specifically whether facial
recognition through law enforcement constitutes a search under the
Fourth Amendment or a “mere visual observation”.</p>
<p>The common thread linking CCTV footages and cellular data is the
unique ability to track the movement of an individual from one place to
another, enabling extreme forms of surveillance. It is perhaps this
crucial link that would make ARFS-enabled CCTVs prejudicial to
individual privacy.</p>
<p> The mosaic theory as understood in <em>Carpenter</em> helps one
understand the extent to which an AFRS can augment the capacities of law
enforcement in India. This in turn can help in understanding whether it
is constitutionally permissible to install such systems across the
country.</p>
<p>AFRS enabled-CCTV footages from different CCTVs. if viewed in
conjunction could reveal a sequence of movements of an individual,
enabling long-term surveillance of a nature that is qualitatively
distinct from isolated observances observed across unrelated CCTV
footages.</p>
<p>Subsequent to <em>Carpenter</em>, <a href="https://www.lawfareblog.com/four-months-later-how-are-courts-interpreting-carpenter" rel="noreferrer noopener" target="_blank">federal district courts</a>
in the United States have declined to apply Carpenter to video
surveillance cases since the judgement did not “call into question
conventional surveillance techniques and tools, such as security
cameras.”</p>
<p>The extent of processing that an AFRS-enabled CCTV exposes an
individual to would be significantly greater. This is because every time
an individual is in the zone of a AFRS-enabled CCTV, the facial image
will be compared to a common database. Snippets from different CCTVs
capturing the individual’s physical presence in two different locations
may not be meaningful per se. When observed together, the AFRS will make
it possible to identify the individual’s movement from one place to
another.</p>
<p>For instance, the AFRS will be able to identify the person when they
are on Street A at a particular time and when they are Street B in the
immediately subsequent hour recorded by respective CCTV cameras,
indicating the person’s physical movement from A to B. While a CCTV
camera only records movement of an individual in video format, AFRS
translates that digital information into individualised data with the
help of a comparison of facial features with a pre-existing database.</p>
<p>Through data aggregation, which appears to be the aim of the Indian
government in their tender that links three databases, it is apparent
that the right to privacy is in danger. Yet, at present, there does not
exist any case law or legislation that can render such efforts illegal
at this juncture.</p>
<p><strong>Conclusions and The Way Forward</strong></p>
<p>Despite a lack of judicial recognition of the potential
unconstitutionality of deploying AFRS, it is clear that the introduction
of these systems pose a clear and present danger to civil rights and
human dignity. Algorithmic surveillance alters a human being’s life in
ways that even the subject of this surveillance cannot fully comprehend.
As an individual’s data is manipulated and aggregated to derive a
pattern about that individual’s world, the individual or his data no
longer exists for itself<sup> </sup>but are massaged into various categories.</p>
<p>Louis Amoore terms this a ‘<a href="https://journals.sagepub.com/doi/abs/10.1177/0263276411417430?journalCode=tcsa" rel="noreferrer noopener" target="_blank">data-derivative</a>’,
which is an abstract conglomeration of data that continuously shapes
our futures without us having a say in their framing. The branding of an
individual as a criminal and then aggregating their data causes
emotional distress as individuals move about in fear of the state gaze
and their association with activities that are branded as potentially
dangerous — thereby suppressing a right to dissent — as exemplified by
their use reported use during the recent protests in Hong Kong.</p>
<p>Case law both in India and abroad has clearly suggested that a right
to privacy is contextual and is not surrendered merely because an
individual is in a public place. However, the jurisprudence protecting
public photography or videography under the umbrella of privacy remains
less clear globally and non-existent in India.</p>
<p>The mosaic theory of privacy is useful in this regard as it prevents
mass ‘data-veillance’ of individual behaviour and accurately identifies
the unique power that the volume, velocity and variety of Big Data
provides to the state. Therefore, it is imperative that the judiciary
recognise safeguards from data aggregation as an essential component of a
reasonable expectation of privacy. At the same time, legislation could
also provide the required safeguards.</p>
<p>In the US, Senators Coons and Lee recently introduced a draft Bill titled ‘<a href="https://www.coons.senate.gov/imo/media/doc/ALB19A70.pdf" rel="noreferrer noopener" target="_blank">The Facial Recognition Technology Warrant Act of 2019’</a>.
The Bill aims to impose reasonable restrictions on the use of facial
recognition technology by law enforcement. The Bill creates safeguards
against sustained tracking of physical movements of an individual in
public spaces. The Bill terms such tracking ‘ongoing surveillance’ when
it occurs for over a period of 72 hours in real time or through
application of technology to historical records. The Bill requires that
ongoing surveillance only be conducted for law enforcement purposes <em>and</em> in pursuance of a Court Order (unless it is impractical to do so).</p>
<p>While the Bill has its textual problems, it is definitely worth
considering as a model going forward and ensure that AFR systems are
deployed in line with a rights-respecting reading of a reasonable
expectation of privacy. <a href="http://datagovernance.org/report/adoption-and-regulation-of-facial-recognition-technologies-in-india" rel="noreferrer noopener" target="_blank">Parsheera</a>
suggests that the legislation should narrow tailoring of the objects
and purposes for deployment of AFRS, restrictions on the person whose
images may be scanned from the databases, judicial approval for its use
on a case by case basis and effective mechanisms of oversight, analysis
and verification.</p>
<p>Appropriate legal intervention is crucial. A failure to implement
this effectively jeopardizes the expression of our true selves and the
core tenets of our democracy.</p>
<p>
For more details visit <a href='https://cis-india.org/internet-governance/automated-facial-recognition-systems-and-the-mosaic-theory-of-privacy-the-way-forward'>https://cis-india.org/internet-governance/automated-facial-recognition-systems-and-the-mosaic-theory-of-privacy-the-way-forward</a>
</p>
No publisherArindrajit Basu, Siddharth SonkarCybersecurityCyber Securityinternet governanceInternet Governance2020-01-02T14:12:38ZBlog EntryCryptocurrency Regulation in India – A brief history
https://cis-india.org/internet-governance/blog/cryptocurrency-regulation-in-india-2013-a-brief-history
<b>In March 2020, the Supreme Court of India quashed the RBI order passed in 2018 that banned financial services firms from trading in virtual currency or cryptocurrency.
Keeping this policy window in mind, the Centre for Internet & Society will be releasing a series of blog posts and policy briefs on cryptocurrency regulation in India
</b>
<p id="docs-internal-guid-18286fb9-7fff-c656-6a5b-a01a2e2b3682" style="text-align: justify;" dir="ltr"> </p>
<p style="text-align: justify;" dir="ltr">The story of cryptocurrencies
started in 2008 when a paper titled “Bitcoin: A Peer to Peer Electronic
Cash System” was published by a single or group of pseudonymous
developer(s) by the name of Satoshi Nakamoto. The actual network took
some time to start with the first transactions taking place only in
January 2009. The first actual sale of an item using Bitcoin took place a
year later with a user swapping 10,000 Bitcoin for two pizzas in 2010,
which attached a cash value to the cryptocurrency for the first time. By
2011 other cryptocurrencies began to emerge, with Litecoin, Namecoin
and Swiftcoin all making their debut. Meanwhile, Bitcoin the
cryptocurrency that started it all started getting criticised after
claims emerged that it was being used on the so-called “dark web”,
particularly on sites such as Silk Road as a means of payment for
illegal transactions. Over the next five years cryptocurrencies steadily
gained traction with increased number of transactions and the price of
Bitcoin, the most popular cryptocurrency shot up from around 5 Dollars
in the beginning of 2012 to almost 1000 Dollars at the end of 2017.</p>
<p style="text-align: justify;" dir="ltr">Riding on the back of this
wave of popularity, a number of cryptocurrency exchanges started
operating in India between 2012 and 2017 providing much needed depth and
volume to the Indian cryptocurrency market. These included popular
exchanges such as Zebpay, Coinsecure, Unocoin, Koinex, Pocket Bits and
Bitxoxo. With the price of cryptocurrencies shooting up and because of
its increased popularity and adoption by users outside of its
traditional cult following, regulators worldwide began to take notice of
this new technology; in India the RBI issued a Press Release cautioning
the public against dealing in virtual currencies including Bitcoin way
back in 2013. However, the transaction volumes and adoption of
cryptocurrencies in India really picked up in earnest only after the
demonetisation of high value currency notes in November of 2016, with
the government’s emphasis on digital payments leading to alternatives to
traditional online banking such as cryptocurrencies forcing their way
into the public consciousness. Indian cryptocurrency exchanges started
acquiring users at a much higher pace which drove up volume for
cryptocurrency transactions on all Indian exchanges. The growing
popularity of cryptocurrencies and its adoption by large numbers of
Indian users forced the RBI to issue another Press Release in February
2017 reiterating its concerns regarding cryptocurrencies raised in its
earlier Press Release of 2013. </p>
<p style="text-align: justify;" dir="ltr">In October and November, 2017
two Public Interest Petitions were filed in the Supreme Court of India,
one by Siddharth Dalmia and another by Dwaipayan Bhowmick, the former
asking the Supreme Court to restrict the sale and purchase of
cryptocurrencies in India, and the latter asking for cryptocurrencies in
India to be regulated. Both the petitions are currently pending in the
Supreme Court.</p>
<p style="text-align: justify;" dir="ltr">In November, 2017 the
Government of India constituted a high level Inter-ministerial Committee
under the chairmanship of Shri Subhash Chandra Garg, Secretary,
Department of Economic Affairs, Ministry of Finance and comprising of
Shri Ajay Prakash Sawhney (Secretary, Ministry of Electronics and
Information Technology), Shri Ajay Tyagi (Chairman, Securities and
Exchange Board of India) and Shri B.P. Kanungo (Deputy Governor, Reserve
Bank of India). The mandate of the Committee was to study various
issues pertaining to Virtual Currencies and to propose specific actions
that may be taken in relation thereto. This Committee submitted its
report in July of 2019 recommending a ban on private cryptocurrencies in
India.</p>
<p style="text-align: justify;" dir="ltr">In December 2017 both the RBI
as well as the Ministry of Finance issued Press releases cautioning the
general public about the dangers and risks associated with
cryptocurrencies, with the Ministry of Finance Press Release saying that
cryptocurrencies are like ponzi schemes and also declaring that they
are not currencies or coins. It should be mentioned here that till the
end of March 2018, the RBI and the Finance Ministry had issued various
Press Releases on cryptocurrencies cautioning people against their
risks, however none of them ever took any legal action or gave any
enforceable directions against cryptocurrencies. All of this changed
with the RBI circular dated April 6, 2018 whereby the RBI prevented
Commercial and Co-operative Banks, Payments Banks, Small Finance Banks,
NBFCs, and Payment System Providers not only from dealing in virtual
currencies themselves but also directing them to stop providing services
to all entities which deal with virtual currencies.</p>
<p style="text-align: justify;" dir="ltr">The effect of the circular was
that cryptocurrency exchanges, which relied on normal banking channels
for sending and receiving money to and from their users, could not
access any banking services within India. This essentially crippled
their business operations since converting cash to cryptocurrencies and
vice versa was an essential part of their operations. Even pure
cryptocurrency exchanges which did not deal in fiat currency, were
unable to carry out their regular operations such as paying for office
space, staff salaries, server space, vendor payments, etc. without
access to banking services. </p>
<p>As a the operations of cryptocurrency exchanges took a severe hit and
the number of transactions on these exchanges reduced substantially.
People who had bought cryptocurrencies on these exchanges as an
investment were forced to sell their crypto assets and cash out before
they lost access to banking facilities. The cryptocurrency exchanges
themselves found it hard to sustain operations in the face of the dual
hit of reduced transaction volumes and loss of access banking services.
Faced with such an existential threat, a number of exchanges who were
members of the Internet and Mobile Association of India (IMAI), filed a
writ petition in the Supreme Court on May 15, 2018 titled Internet and
Mobile Association of India v. Reserve Bank of India, the final
arguments in which were heard by the Supreme Court of India in January,
2020 and the judgment is awaited. If the Supreme Court agrees with the
arguments of the petitioners, then cryptocurrency exchanges would be
able to restart operations in India; as a result the cryptocurrency
ecosystem in India may be revived and cryptocurrencies may become a
viable investment alternative again.</p>
<p>
For more details visit <a href='https://cis-india.org/internet-governance/blog/cryptocurrency-regulation-in-india-2013-a-brief-history'>https://cis-india.org/internet-governance/blog/cryptocurrency-regulation-in-india-2013-a-brief-history</a>
</p>
No publishervipulCybersecurityinternet governanceBitcoinInternet GovernanceCryptocurrenciesCyber Security2020-03-05T18:36:09ZBlog EntryCIS Cybersecurity Series (Part 6) - Lhadon Tethong
https://cis-india.org/internet-governance/cis-cybersecurity-series-part-6-lhadon-tethong
<b>CIS interviews Lhadon Tethong, Tibetan human rights activist, as part of the Cybersecurity Series</b>
<p><i>"In authoritarian states, and in this case, in Tibet, I think that every person that we can teach and pass knowledge to, that can help them stay out of jail, stay in the streets, for one, two, three days longer, one week longer, that is a valuable time of time and resources. And I think we cannot rely on only tools and technology solutions to protect people. I think we can't just rely on government policies at the highest levels, and on export controls... the approach to digital security has to be comprehensive and we have to engage citizens. And not just in cases like the Tibetans or for activists or for people living under repression, but for people in free and open societies too." - Lhadon Tethong, Tibetan human rights activist.</i></p>
<p>Centre for Internet and Society presents its sixth installment of the CIS Cybersecurity Series.</p>
<p>The CIS Cybersecurity Series seeks to address hotly debated aspects of cybersecurity and hopes to encourage wider public discourse around the topic.</p>
<p>In this installment, CIS interviews Lhadon Tethong, Tibetan human rights activist. Lhadon is the Director of the Tibet Action Institute, where she leads a team of technologists and human rights advocates in developing and advancing open-source communication technologies, nonviolent strategies and innovative training programs for Tibetans and other groups facing heavy repression and human rights abuses.</p>
<p>Link for Tibet Action Institute: <a href="https://tibetaction.net/">https://tibetaction.net/</a></p>
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<p><b><i>This work was carried out as part of the Cyber Stewards Network with aid of a grant from the International Development Research Centre, Ottawa, Canada.</i></b></p>
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For more details visit <a href='https://cis-india.org/internet-governance/cis-cybersecurity-series-part-6-lhadon-tethong'>https://cis-india.org/internet-governance/cis-cybersecurity-series-part-6-lhadon-tethong</a>
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No publisherpurbaCybersecurityInternet GovernanceCyberculturesCyber SecurityCyber Security Interview2013-08-01T09:54:46ZBlog EntryCIS Cybersecurity Series (Part 11) - Anja Kovacs
https://cis-india.org/internet-governance/blog/cis-cybersecurity-series-part-11-anja-kovacs
<b>CIS interviews Anja Kovacs, researcher and activist, and director of the Internet Democracy, Project as part of the Cybersecurity Series.</b>
<p><em>"Having the cyber security debate become more and more important was a real challenge for civil society. I think in part because many of us who were focused on human rights aren't necessarily techies. And so, when you have a conversation with a government bureaucrat, and ask questions about the kind of decisions they decided to take, very often they will come up with a technical answer in response. And then, if you don't have that expertise, it is difficult to react. In the meantime though, I think it has become clear that this is one of the biggest issues in the internet field at the moment. It is also one of the big issues that is driving the desires of governments to have a bigger role to play in internet governance. So it is an area that is unavoidable for activists. What has happened slowly is that we have come to realize that the first thing, as in most other areas, is not the technical details, but principles, and those principles are fairly similar to how they are in many other fields." - Anja Kovacs, Internet Democracy Project</em></p>
<p>Centre for Internet and Society presents its eleventh installment of the CIS Cybersecurity Series. </p>
<p>The CIS Cybersecurity Series seeks to address hotly debated aspects of cybersecurity and hopes to encourage wider public discourse around the topic.</p>
<p>In this installment, CIS speaks to Anja Kovacs, director of the Internet Democracy Project. Her work focuses on a wide range of questions regarding freedom of expression, cybersecurity and the architecture of Internet governance as they relate to the Internet and democracy. Anja is currently also a member of the of the Investment Committee of the Digital Defenders Partnership and of the interim Steering Group of Best Bits, a global network of civil society members.</p>
<p><em>(Bio from internetdemocracy.in) </em></p>
<p>Internet Democracy Project homepage: http://internetdemocracy.in/</p>
<p> <iframe src="//www.youtube.com/embed/uWH2oup6ND8" frameborder="0" height="315" width="420"></iframe></p>
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<p><strong><em>This work was carried out as part of the Cyber Stewards Network with aid of a grant from the International Development Research Centre, Ottawa, Canada.</em></strong></p>
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For more details visit <a href='https://cis-india.org/internet-governance/blog/cis-cybersecurity-series-part-11-anja-kovacs'>https://cis-india.org/internet-governance/blog/cis-cybersecurity-series-part-11-anja-kovacs</a>
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No publisherpurbaCybersecurityInternet GovernanceCyberculturesCyber SecurityCyber Security Interview2013-10-15T15:25:07ZBlog EntryGood Intentions, Recalcitrant Text - I: Why India’s Proposal at the ITU is Troubling for Internet Freedoms
https://cis-india.org/internet-governance/blog/good-intentions-going-awry-i-why-india2019s-proposal-at-the-itu-is-troubling-for-internet-freedoms
<b>The UN's International Telecommunications Union (ITU) is hosting its Plenipotentiary Conference (PP-14) this year in South Korea. At PP-14, India introduced a new draft resolution on ITU's Role in Realising Secure Information Society. The Draft Resolution has grave implications for human rights and Internet governance. Geetha Hariharan explores.</b>
<p style="text-align: justify; "> </p>
<p style="text-align: justify; ">At the 2014 Plenipotentiary Conference (‘PP-14’ or ‘Plenipot’) of the International Telecommunications Union (ITU), India has tabled <a href="https://cis-india.org/internet-governance/blog/india-draft-resolution-itus-role-in-securing-information-security/at_download/file">a draft proposal</a> on “ITU’s Role in Realising Secure Information Society” [Document 98, dated 20 October 2014] (“<strong>Draft Resolution</strong>”). India’s proposal has incited a great deal of concern and discussion among Plenipot attendees, governments and civil society alike. Before offering my concerns and comments on the Draft Resolution, let us understand the proposal.</p>
<p style="text-align: justify; ">Our Draft Resolution identifies 3 security concerns with exchange of information and resource allocation on the Internet:</p>
<ul style="text-align: justify; ">
<li><i>First</i>, it is troubling for India that present network architecture has “<i>security weaknesses</i>” such as “<i>camouflaging the identity of the originator of the communication</i>”;<a href="#_ftn1">[1]</a> random IP address distribution also makes “<i>tracing of communication difficult</i>”;<a href="#_ftn2">[2]</a></li>
<li><i>Second</i>, India is concerned that under the present allocation system of naming, numbering and addressing resources on the Internet, it is impossible or at the very least, cumbersome to identify the countries to which IP address are allocated;<a href="#_ftn3">[3]</a> </li>
<li><i>Third</i>, India finds it insecure from the point of view of national security that traffic originating and terminating in the same country (domestic traffic) often routes through networks overseas;<a href="#_ftn4">[4]</a> similarly, local address resolution also routes through IP addresses outside the country or region, which India finds troubling.<a href="#_ftn5">[5]</a></li>
</ul>
<p style="text-align: justify; ">In an effort to address these concerns, the Draft Resolution seeks to instruct the ITU Secretary General:</p>
<ul style="text-align: justify; ">
<li><i>First</i>,<i> </i>to develop and recommend a ‘traffic routing plan’ that can “<i>effectively ensure the traceability of communication</i>”;<a href="#_ftn6">[6]</a></li>
<li><i>Second</i>, to collaborate with relevant international and intergovernmental organisations to develop an<i> </i>“<i>IP address plan</i>”<i> </i>which facilitates identification of locations/countries to which IP addresses are allocated and coordinates allocation accordingly;<a href="#_ftn7">[7]</a></li>
<li><i>Third</i>, to develop and recommend “<i>a public telecom network architecture</i>” that localizes both routing<a href="#_ftn8">[8]</a> as well as address resolution<a href="#_ftn9">[9]</a> for local/domestic traffic to “<i>within the country</i>”.</li>
</ul>
<p style="text-align: justify; ">Admittedly, our Draft Resolution is intended to pave a way for “<i>systematic, fair and equitable allocation</i>” of, <i>inter alia</i>, naming, numbering and addressing resources,<a href="#_ftn10">[10]</a> keeping in mind security and human rights concerns.<a href="#_ftn11">[11]</a> In an informal conversation, members of the Indian delegation echoed these sentiments. Our resolution does not, I was told, raise issues about the “<i>concentration of control over Internet resources</i>”, though “<i>certain governments</i>” have historically exercised more control. It also does not, he clarified, wish to make privacy or human rights a matter for discussion at the ITU. All that the Draft Resolution seeks to do is to equip the ITU with the mandate to prepare and recommend a “<i>roadmap for the systematization</i>” of allocation of naming, numbering and addressing resources, and for local routing of domestic traffic and address resolution. The framework for such mandate is that of security, given the ITU’s role in ‘building confidence and security in the use of ICTs’ under Action Line C5 of the <a href="http://www.itu.int/wsis/docs/geneva/official/poa.html">Geneva Plan of Action</a>, 2003.</p>
<p style="text-align: justify; ">Unfortunately, the text of our Draft Resolution, by dint of imprecision or lack of clarity, undermines India’s intentions. On three issues of utmost importance to the Internet, the Draft Resolution has unintended or unanticipated impacts. <strong><i>First</i></strong>, its text on tracing communication and identity of originators, and systematic allocation of identifiable IP address blocks to particular countries, has impacts on privacy and freedom of expression. Given Edward Snowden’s <a href="http://www.theguardian.com/world/interactive/2013/nov/01/snowden-nsa-files-surveillance-revelations-decoded">NSA files</a> and the absence of adequate protections against government incursions or excesses into privacy,<a href="#_ftn12">[12]</a> either in international human rights law or domestic law, such text is troublesome. <strong><i>Second</i></strong>, it has the potential to undermine multi-stakeholder approaches to Internet governance by proposing text that refers almost exclusively to sovereign monopolies over Internet resource allocation, and <strong><i>finally</i></strong>, displays a certain disregard for network architecture and efficiency, and to principles of a free, open and unified Internet, when it seeks to develop global architecture that facilitates (domestic) localization of traffic-routing, address resolution and allocation of naming, numbering and addressing.</p>
<p style="text-align: justify; ">In this post, I will address the first concern of human rights implications of our Draft Resolution.<span> </span></p>
<h3 style="text-align: justify; ">Unintended Implications for Privacy and Freedom of Expression:</h3>
<p style="text-align: justify; ">India’s Draft Resolution has implications for individual privacy. At two different parts of the preamble, India expresses concerns with the impossibility of locating the user at the end of an IP address:</p>
<ul style="text-align: justify; ">
<li>Pream. §(e): “<i>recognizing</i>… that the modern day packet networks, which at present have many security weaknesses, <i>inter alia</i>, camouflaging the identity of originator of the communication”;</li>
<li>Pream. §(h): “<i>recognizing</i>… that IP addresses are distributed randomly, that makes the tracing of communication difficult”.</li>
</ul>
<p style="text-align: justify; ">The concerns here surround difficulties in tracking IP addresses due to the widespread use of NATs, as also the existence of IP anonymisers like Tor. Anonymisers like Tor permit individuals to cover their online tracks; they conceal user location and Internet activity from persons or governments conducting network surveillance or traffic analysis. For this reason, Tor has caused much discomfort to governments. <a href="http://www.wired.com/2014/10/laura-poitras-crypto-tools-made-snowden-film-possible/">Snowden used Tor</a> while communicating with Laura Poitras. Bradley (now Chelsea) Manning of Wikileaks fame is<i> </i><a href="http://belfercenter.ksg.harvard.edu/files/maurer-dp-2011-10-wikileaks-final.pdf">reported</a> to have used Tor (page 24). Crypto is increasingly the safest – perhaps the only safe – avenue for political dissidents across the world; even Internet companies were <a href="http://gizmodo.com/the-nsa-was-going-to-fine-yahoo-250k-a-day-if-it-didnt-1633677548">coerced</a> into governmental compliance. No wonder, then, that governments are doing all they can to dismantle IP anonymisers: the <a href="http://arstechnica.com/security/2013/10/nsa-repeatedly-tries-to-unpeel-tor-anonymity-and-spy-on-users-memos-show/">NSA</a> and <a href="http://www.itproportal.com/2013/10/04/nsa-and-gchq-repeatedly-tried-infiltrate-tor-documents-reveal/">GCHQ</a> have tried to break Tor; the Russian government has <a href="http://www.bloomberg.com/news/2014-07-29/putin-sets-110-000-bounty-for-cracking-tor-as-anonymous-internet-usage-in-russia-surges.html">offered a reward</a> to anyone who can.</p>
<p style="text-align: justify; ">Far be it from me to defend Tor blindly. There are reports <a href="http://www.theguardian.com/world/2013/oct/04/nsa-gchq-attack-tor-network-encryption">suggesting</a> that Tor is being <a href="http://news.softpedia.com/news/Tor-Attracts-More-and-More-Cybercriminals-Experts-Warn-430659.shtml">used by offenders</a>, and not merely those of the Snowden variety. But governments must recognize the very obvious trust deficit they face, especially after <a href="http://www.statewatch.org/news/2014/may/ep-LIBE-Inquiry-NSA-Surveillance.pdf">Snowden’s revelations</a>, and consider the implications of seeking traceability and identity/geolocation for every IP address, in a systematic manner. The implications are for privacy, a right guaranteed by Article 17 of the International Covenant on Civil and Political Rights (ICCPR). Privacy has been <a href="http://www.hrw.org/sites/default/files/related_material/UNGA_upload_0.pdf">recognized</a> by the UN General Assembly as applicable in cases of surveillance, interception and data collection, in Pream. §4 of its resolution <i>The Right to Privacy in the Digital Age</i>. But many states do not have robust privacy protections for individuals and data. And while governments may state the necessity to create international policy to further effective criminal investigations, such an aim cannot be used to nullify or destroy the rights of privacy and free speech guaranteed to individuals. Article 5(1), ICCPR, codifies this principle, when it states that States, groups or persons may not “<i>engage in any activity or perform any act aimed at the destruction of any of the rights and freedoms recognized herein…</i>”.</p>
<p style="text-align: justify; "><span>Erosion of privacy has a chilling effect on free speech [</span><i><a href="http://www.law.cornell.edu/supremecourt/text/376/254">New York Times v. Sullivan</a></i><span>, 376 U.S. 254], so free speech suffers too. Particularly with regard to Tor and identification of IP address location and users, anonymity in Internet communications is at issue. At the moment, most states already have anonymity-restrictions, in the form of identification and registration for cybercafés, SIM cards and broadband connections. For instance, Rule 4 of India’s </span><a href="http://deity.gov.in/sites/upload_files/dit/files/GSR315E_10511(1).pdf">Information Technology (Guidelines for Cyber Cafe) Rules, 2011</a><span>, mandates that we cannot not use computers in a cybercafé without establishing our identities. But our ITU Draft Resolution seeks to </span><i>dismantle</i><span> the ability of Internet users to operate anonymously, be they political dissidents, criminals or those merely acting on their expectations of privacy. Such dismantling would be both violative of international human rights law, as well as dangerous for freedom of expression and privacy in principle. Anonymity is integral to democratic discourse, held the US Supreme Court in </span><i><a href="http://www.law.cornell.edu/supct/html/93-986.ZO.html">McIntyre v. Ohio Elections Commission</a></i><span> [514 U.S. 334 (1995)].</span><a href="#_ftn13">[13]</a><span> Restrictions on Internet anonymity facilitate communications surveillance and have a chilling effect on the free expression of opinions and ideas, </span><a href="http://www.ohchr.org/Documents/HRBodies/HRCouncil/RegularSession/Session23/A.HRC.23.40_EN.pdf">wrote Mr. Frank La Rue</a><span>, Special Rapporteur on the promotion and protection of the right to freedom of opinion and expression (¶¶ 48-49).</span></p>
<p style="text-align: justify; ">So a law or international policy for blanket identification and traceability of IP addresses has grave consequences for and <i>prima facie </i>violates privacy, anonymity and freedom of speech. But these rights are not absolute, and can be validly restricted. And because these human rights are implicated, the ITU with its lack of expertise in the area may not be the adequate forum for discussion or study.</p>
<p style="text-align: justify; "><span>To be valid and justified interference, any law, policy or order interfering with privacy and free speech must meet the standards of reasonableness and proportionality, even if national security were the government’s legitimate aim, laid down in Articles 19(3) and 17 of the Covenant on Civil and Political Rights (CCPR) [</span><i><a href="http://www1.umn.edu/humanrts/undocs/html/vws488.htm">Toonen v. Australia</a></i><span>, Communication No. 488/1992, U.N. Doc CCPR/C/50/D/488/1992 (1994), ¶6.4]. And as the European Court of Human Rights found in </span><i><a href="http://hudoc.echr.coe.int/sites/eng/pages/search.aspx?i=001-76586">Weber & Saravia v. Germany</a></i><span> [Application no. 54934/00, 29 June 2006 (ECHR), ¶95], law or executive procedure that </span><i>enables</i><span> surveillance without sufficient safeguards is </span><i>prima facie</i><span> unreasonable and disproportionate. Re: anonymity, in </span><i><a href="http://hudoc.echr.coe.int/sites/eng/pages/search.aspx?i=001-126635">Delfi AS v. Estonia</a></i><span> [Application no. 64569/09, 17 February 2014, ¶83], while considering the liability of an Internet portal for offensive anonymous comments, the ECHR has emphasized the importance of balancing freedom of expression and privacy. It relied on certain principles such as “</span><i>contribution to a debate of general interest, subject of the report, the content, form and consequences of the publication</i><span>” to test the validity of government’s restrictions.</span></p>
<p style="text-align: justify; ">The implications of the suggested text of India’s Draft Resolution should then be carefully thought out. And this is a good thing. For one must wonder why governments need perfect traceability, geolocation and user identification for <i>all</i> IP addresses. Is such a demand really different from mass or blanket surveillance, in scale and government tracking ability? Would this not tilt the balance of power strongly in favour of governments against individuals (citizens or non-citizens)? This fear must especially arise in the absence of domestic legal protections, both in human rights, and criminal law and procedure. For instance, India’s Information Technology Act, 2000 (amended in 2008) has Section 66A, which criminalizes offensive speech, as well as speech that causes annoyance or inconvenience. Arguably, arrests under Section 66A have been <a href="http://timesofindia.indiatimes.com/city/bangalore/Man-arrested-for-allegedly-sending-offensive-MMS-against-Modi-confirmed-innocent-by-police-released/articleshow/35624351.cms">arbitrary</a>, and traceability may give rise to a host of new worries.</p>
<p style="text-align: justify; "><span>In any event, IP addresses and users can be discerned under existing domestic law frameworks. Regional Internet Registries (RIR) such as APNIC allocate blocks of IP addresses to either National Internet Registries (NIR – such as IRINN for India) or to ISPs directly. The ISPs then allocate IP addresses dynamically to users like you and me. Identifying information for these ISPs is maintained in the form of </span><a href="http://www.irinn.in/whoisSearchform.action">WHOIS records</a><span> and </span><a href="file://localhost/pub/stats/apnic">registries</a><span> with RIRs or NIRs, and this information is public. ISPs of most countries require identifying information from users before Internet connection is given, i.e., IP addresses allocated (mostly by dynamic allocation, for that is more efficient). ISPs of some states are also regulated; in India, for instance, ISPs require a </span><a href="http://www.dot.gov.in/licensing/data-services">licence</a><span> to operate and offer services.</span></p>
<p style="text-align: justify; ">If any government wished, on the basis of some reasonable cause, to identify a particular IP address or its user, then the government could first utilize WHOIS to obtain information about the ISP. Then ISPs may be ordered to release specific IP address locations and user information under executive or judicial order. There are also technical solutions, such as <a href="http://traceroute.monitis.com/">traceroute</a> or <a href="http://ip-lookup.net/">IP look-up</a> that assist in tracing or identifying IP addresses. Coders, governments and law enforcement must surely be aware of better technology than I.</p>
<p style="text-align: justify; ">If we take into account this possibility of geolocation of IP addresses, then the Draft Resolution’s motivation to ‘systematize’ IP address allocations on the basis of states is unclear. I will discuss the implication of this proposal, and that of traffic and address localization, in my next post.</p>
<p style="text-align: justify; "> </p>
<hr size="1" style="text-align: justify; " width="33%" />
<p style="text-align: justify; "><a href="#_ftnref1">[1]</a> Pream. §(e), Draft Resolution: “recognizing… that the modern day packet networks, which at present have many security weaknesses, inter alia, camouflaging the identity of originator of the communication”.</p>
<p style="text-align: justify; "><a href="#_ftnref2">[2]</a> Pream. §(h), Draft Resolution: “recognizing… that IP addresses are distributed randomly, that makes the tracing of communication difficult”.</p>
<p style="text-align: justify; "><a href="#_ftnref3">[3]</a> Op. §1, Draft Resolution: “instructs the Secretary General… to collaborate with all stakeholders including International and intergovernmental organizations, involved in IP addresses management to develop an IP address plan from which IP addresses of different countries are easily discernible and coordinate to ensure distribution of IP addresses accordingly”.</p>
<p style="text-align: justify; "><a href="#_ftnref4">[4]</a> Pream. §(g), Draft Resolution: “recognizing… that communication traffic originating and terminating in a country also many times flows outside the boundary of a country making such communication costly and to some extent insecure from national security point of view”.</p>
<p style="text-align: justify; "><a href="#_ftnref5">[5]</a> Pream. §(f), Draft Resolution: “recognizing… that even for local address resolution at times, system has to use resources outside the country which makes such address resolution costly and to some extent insecure from national security perspective”.</p>
<p style="text-align: justify; "><a href="#_ftnref6">[6]</a> Op. §6, Draft Resolution: “instructs the Secretary General… to develop and recommend a routing plan of traffic for optimizing the network resources that could effectively ensure the traceability of communication”.</p>
<p style="text-align: justify; "><a href="#_ftnref7">[7]</a> Op. §1, Draft Resolution; <i>see</i> note 3.</p>
<p style="text-align: justify; "><a href="#_ftnref8">[8]</a> Op. §5, Draft Resolution: “instructs the Secretary General… to develop and recommend public telecom network architecture which ensures that effectively the traffic meant for the country, traffic originating and terminating in the country remains within the country”.</p>
<p style="text-align: justify; "><a href="#_ftnref9">[9]</a> Op. §4, Draft Resolution: “instructs the Secretary General… to develop and recommend public telecom network architecture which ensures effectively that address resolution for the traffic meant for the country, traffic originating and terminating in the country/region takes place within the country”.</p>
<p style="text-align: justify; "><a href="#_ftnref10">[10]</a> Context Note to Draft Resolution, ¶3: “Planning and distribution of numbering and naming resources in a systematic, equitable, fair and just manner amongst the Member States…”</p>
<p style="text-align: justify; "><a href="#_ftnref11">[11]</a> Context Note to Draft Resolution, ¶2: “…there are certain areas that require critical attention to move in the direction of building the necessary “Trust Framework” for the safe “Information Society”, where privacy, safety are ensured”.</p>
<p style="text-align: left; "><a href="#_ftnref12">[12]</a> <i>See, for instance</i>, Report of the Office of the High Commission for Human Rights (“OHCHR”), <i>Right to Privacy in the Digital Age</i>, A/HRC/27/37 (30 June 2014), ¶34-35, <a href="http://www.ohchr.org/EN/HRBodies/HRC/RegularSessions/Session27/Documents/A.HRC.27.37_en.pdf">http://www.ohchr.org/EN/HRBodies/HRC/RegularSessions/Session27/Documents/A.HRC.27.37_en.pdf</a>. <i>See esp. </i>note 30 of the Report, ¶35.</p>
<p style="text-align: justify; "><a href="#_ftnref13">[13]</a> Many thorny political differences exist between the US and many states (including India and Kenya, who I am told has expressed preliminary support for the Draft Resolution) with regard to Internet governance. Irrespective of this, the US Constitution’s First Amendment and judicial protections to freedom of expression remain a yardstick for many states, including India. India, for instance, has positively referred to the US Supreme Court’s free speech protections in many of its decisions; <i>ex. see</i> Kharak Singh v. State of Uttar Pradesh, 1963 Cri. L.J. 329; R. Rajagopal v. State of Tamil Nadu, AIR 1995 SC 264.</p>
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For more details visit <a href='https://cis-india.org/internet-governance/blog/good-intentions-going-awry-i-why-india2019s-proposal-at-the-itu-is-troubling-for-internet-freedoms'>https://cis-india.org/internet-governance/blog/good-intentions-going-awry-i-why-india2019s-proposal-at-the-itu-is-troubling-for-internet-freedoms</a>
</p>
No publishergeethaCryptographyPrivacyCybersecurityInternet GovernanceFreedom of Speech and ExpressionChilling EffectMulti-stakeholderAnonymityITU2014-11-02T15:13:45ZBlog EntryCIS Cybersecurity Series (Part 12) - Namita Malhotra
https://cis-india.org/internet-governance/blog/cis-cybersecurity-series-part-12-namita-malhotra
<b>CIS interviews Namita Malhotra, researcher and lawyer at Alternative Law Forum, Bangalore, as part of the Cybersecurity Series.</b>
<p><em>"In a strange mix of how both capitalism and state control work, what is happening is that more and more of these places that one could access, for various reasons, whether it is for ones own pleasure or for political conversations, are getting further and further away from us. And I think that that mix of both corporate interests and state control is particularly playing a role in this regard." - Namita Malhotra, researcher and lawyer, Alternative Law Forum</em></p>
<p>Centre for Internet and Society presents its twelfth installment of the CIS Cybersecurity Series. </p>
<p>The CIS Cybersecurity Series seeks to address hotly debated aspects of cybersecurity and hopes to encourage wider public discourse around the topic.</p>
<p>Namita Malhotra is a researcher and lawyer at Alternative Law Forum (ALF). She has a keen interest in working on law, technology and media through legal research, cultural studies, new media practices and film making.</p>
<p>ALF homepage: www.altlawforum.org</p>
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<p><strong><em>This work was carried out as part of the Cyber Stewards Network with aid of a grant from the International Development Research Centre, Ottawa, Canada.</em></strong></p>
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For more details visit <a href='https://cis-india.org/internet-governance/blog/cis-cybersecurity-series-part-12-namita-malhotra'>https://cis-india.org/internet-governance/blog/cis-cybersecurity-series-part-12-namita-malhotra</a>
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No publisherpurbaCybersecurityInternet GovernanceCyberculturesCyber SecurityCyber Security Interview2013-11-18T10:03:29ZBlog EntryFirst Look: CIS Cybersecurity documentary film
https://cis-india.org/internet-governance/blog/cis-cybersecurity-series-film-trailer
<b>CIS presents the trailer of its documentary film DesiSec: Cybersecurity & Civil Society in India</b>
<p>The Centre for Internet and Society is pleased to release the trailer of its first documentary film, on cybersecurity and civil society in India. </p>
<p>The documentary is part of the CIS Cybersecurity Series, a work in progress which may be found <a class="external-link" href="http://cismetamedia.tumblr.com">here</a>.</p>
<iframe src="//www.youtube.com/embed/3134xVvMmfc" frameborder="0" height="315" width="560"></iframe>
<p><strong>DesiSec: Cybersecurity and Civil Society in India</strong></p>
<p>The trailer of <em>DesiSec: Cybersecurity and Civil Society in India</em> was shown at the Internet Governance Forum in Bali on October 24. It was a featured presentation at the Citizen Lab workshop, <em>Internet Governance For The Next Billion Users.</em></p>
<p>The transcript of the workshop is available here: <a href="http://www.intgovforum.org/cms/component/content/article/121-preparatory-process/1476-ws-344-internet-governance-for-the-next-billion-users">http://www.intgovforum.org/cms/component/content/article/121-preparatory-process/1476-ws-344-internet-governance-for-the-next-billion-users</a> </p>
<p><strong><em>This work was carried out as part of the Cyber Stewards Network with aid of a grant from the International Development Research Centre, Ottawa, Canada.</em></strong></p>
<p>
For more details visit <a href='https://cis-india.org/internet-governance/blog/cis-cybersecurity-series-film-trailer'>https://cis-india.org/internet-governance/blog/cis-cybersecurity-series-film-trailer</a>
</p>
No publisherpurbaCybersecurityInternet Governance ForumInternet GovernanceCyber Security FilmCyberculturesCyber Security2013-12-17T08:16:42ZBlog EntryRegulating the Internet: The Government of India & Standards Development at the IETF
https://cis-india.org/internet-governance/blog/regulating-the-internet-the-government-of-india-standards-development-at-the-ietf
<b>The institution of open standards has been described as a formidable regulatory regime governing the Internet. Given the regulatory and domestic policy implications that technical standards can have, there is a need for Indian governmental agencies to focus adequate resources geared towards achieving favourable outcomes at standards development fora.</b>
<p>This brief was authored by Aayush Rathi, Gurshabad Grover and Sunil Abraham. Click <a class="external-link" href="http://cis-india.org/internet-governance/files/regulating-the-internet">here</a> to download the policy brief.</p>
<hr />
<h2>Executive Summary</h2>
<div> </div>
<p style="text-align: justify;">The institution of open standards has been described as a formidable regulatory regime governing the Internet. As the Internet has moved to facilitate commerce and communication, governments and corporations find greater incentives to participate and influence the decisions of independent standards development organisations.</p>
<p style="text-align: justify;">While most such bodies have attempted to systematise fair and transparent processes, this brief highlights how they may still be susceptible to compromise. Documented instances of large private companies like Microsoft, and governmental instrumentalities like the US National Security Agency (NSA) exerting disproportionate influence over certain technical standards further the case for increased Indian participation.</p>
<p style="text-align: justify;">The debate around Transport Layer Security (TLS) 1.3 at the Internet Engineering Task Force (IETF) forms an important case for studying how a standards body responded to political developments, and how the Government of India participated in the ensuing discussions. Lasting four years, the debate ended in favour of greater communications security. One of the security improvements in TLS 1.3 over its predecessor is that is makes less information available to networking middleboxes. Considering that Indian intelligence agencies and government departments have expressed fears of foreign-manufactured networking equipment being used by foreign intelligence to eavesdrop on Indian networks, the development is potentially favourable for the security of Indian communication in general, and the security of military and intelligence systems in particular. India has historically procured most networking equipment from foreign manufacturers. While there have been calls for indigenised production of such equipment, achieving these objectives will necessarily be a gradual process. Participating in technical standards can, then, be an effective interim method for intelligence agencies, defence wings and law enforcement for establishing trust in critical networking infrastructure sourced from foreign enterprises.</p>
<p style="text-align: justify;">Outlining some of the existing measures the Indian government has put in place to build capacity for and participate in standard setting, this brief highlights that while these are useful starting points, they need to be harmonised and strengthened to be more fruitful. Given the regulatory and domestic policy implications that technical standards can have, there is a need for Indian governmental agencies to focus adequate resources geared towards achieving favourable outcomes at standards development fora.</p>
<hr />
<p>Click <a class="external-link" href="http://cis-india.org/internet-governance/files/regulating-the-internet">here</a> to download the policy brief.</p>
<p style="text-align: justify;">Note: The recommendations in the brief were updated on 17 December 2018 to reflect the relevance of technical standard-setting in the recent discussions around Indian intelligence concerns about foreign-manufactured networking equipment.</p>
<p>
For more details visit <a href='https://cis-india.org/internet-governance/blog/regulating-the-internet-the-government-of-india-standards-development-at-the-ietf'>https://cis-india.org/internet-governance/blog/regulating-the-internet-the-government-of-india-standards-development-at-the-ietf</a>
</p>
No publisherAayush Rathi, Gurshabad Grover and Sunil AbrahamOpen StandardsCryptographyCybersecurityInternet GovernanceSurveillanceIETFEncryption Policy2019-01-22T07:29:39ZBlog EntryPre-Budget Consultation 2016 - Submission to the IT Group of the Ministry of Finance
https://cis-india.org/openness/pre-budget-consultation-2016-submission-to-the-ministry-of-finance
<b>The Ministry of Finance has recently held pre-budget consultations with different stakeholder groups in connection with the Union Budget 2016-17. We were invited to take part in the consultation for the IT (hardware and software) group organised on January 07, 2016, and submit a suggestion note. We are sharing the note below. It was prepared and presented by Sumandro Chattapadhyay, with contributions from Rohini Lakshané, Anubha Sinha, and other members of CIS.</b>
<p> </p>
<p>It is our distinct honour to be invited to submit this note for consideration by the IT Group of the Ministry of Finance, Government of India, as part of the pre-budget consultation for 2016-17.</p>
<p>The Centre for Internet and Society is (CIS) is a non-profit organisation that undertakes interdisciplinary research on internet and digital technologies from policy and academic perspectives. The areas of focus include digital accessibility for persons with diverse abilities, access to knowledge, intellectual property rights, openness (including open data, free and open source software, open standards, open access, open educational resources, and open video), internet governance, telecommunication reform, digital privacy, and cyber-security. We receive financial support from Kusuma Trust, Wikimedia Foundation, MacArthur Foundation, IDRC, and other donors.</p>
<p>We have divided our suggestions into the different topics that our organisation has been researching in the recent years.</p>
<p> </p>
<h3>Free/Libre and Open Source Software (FLOSS) is the Basis for Digital India</h3>
<p> </p>
<p>We congratulate the policies introduced by the government to promote use of free/libre and open source software and that of open APIs for all e-governance projects and systems. This is not only crucial for the government to avoid vendor lock-in when it comes to critical software systems for governance, but also to ensure that the source code of such systems is available for public scrutiny and do not contain any security flaws.</p>
<p>We request the government to empower the implementation of these policies by making open sharing of source code a necessity for all software vendors hired by government agencies a necessary condition for awarding of tenders. The 2016-17 budget should include special support to make all government agencies aware and capable of implementing these policies, as well as to build and operate agency-level software repositories (with version controlling system) to host the source codes. These repositories may function to manage the development and maintenance of software used in e-governance projects, as well as to seek comments from the public regarding the quality of the software.</p>
<p>Use of FLOSS is not only important from the security or the cost-saving perspectives, it is also crucial to develop a robust industry of software development firms that specialise in FLOSS-based solutions, as opposed to being restricted to doing local implementation of global software vendors. A holistic support for FLOSS, especially with the government functioning as the dominant client, will immensely help creation of domestic jobs in the software industry, as well as encouraging Indian programmers to contribute to development of FLOSS projects.</p>
<p>An effective compliance monitoring and enforcement system needs to be created to ensure that all government agencies are Strong enforcement of the 2011 policy to use open source software in governance, including an enforcement task force that checks whether government departments have complied with this or not.</p>
<p> </p>
<h3>Open Data is a Key Instrument for Transparent Decision Making</h3>
<p> </p>
<p>With a wider set of governance activities being carried out using information systems, the government is increasingly acquiring a substantial amount of data about governance processes and status of projects that needs to be effectively fed back into the decision making process for the same projects. Opening up such data not only allows for public transparency, but also for easier sharing of data across government agencies, which reduces process delays and possibilities of duplication of data collection efforts.</p>
<p>We request the 2016-17 budget to foreground the National Data Sharing and Accessibility Policy and the Open Government Data Platform of India as two key enablers of the Digital India agenda, and accordingly budget for modernisation and reconfiguration of data collection and management processes across government agencies, so that those processes are made automatic and open-by-default. Automatic data management processes minimise the possibility of data loss by directly archiving the collected data, which is increasingly becoming digital in nature. Open-by-default processes of data management means that all data collected by an agency, once pre-recognised as shareable data (that is non-sensitive and anonymised), will be proactively disclosed as a rule.</p>
<p>Implementation of the National Data Sharing and Accessibility Policy has been hindered, so far, by the lack of preparation of a public inventory of data assets, along with the information of their collection cycles, modes of collection and storage, etc., by each union government agency. Specific budgetary allocation to develop these inventories will be crucial not only for the implementation of the Policy, but also for the government to get an extensive sense of data collected and maintained currently by various government agencies. Decisions to proactively publish, or otherwise, such data can then be taken based on established rules.</p>
<p>Availability of such open data, as mentioned above, creates a wider possibility for the public to know, learn, and understand the activities of the government, and is a cornerstone of transparent governance in the digital era. But making this a reality requires a systemic implementation of open government data practices, and various agencies would require targeted budget to undertake the required capacity development and work process re-engineering. Expenditure of such kind should not be seen as producing government data as a product, but as producing data as an infrastructure, which will be of continuous value for the years to come.</p>
<p>As being discussed globally, open government data has the potential to kickstart a vast market of data derivatives, analytics companies, and data-driven innovation. Encouraging civic innovations, empowered by open government data - from climate data to transport data - can also be one of the unique initiatives of budget 2016-17.</p>
<p>For maximising impact of opened up government data, we request the government to publish data that either has a high demand already (such as, geospatial data, and transport data), or is related to high-net-worth activities of the government (such as, data related to monitoring of major programmes, and budget and expenditure data for union and state governments).</p>
<p> </p>
<h3>Promotion of Start-ups and MSMEs in Electronics and IT Hardware Manufacturing</h3>
<p> </p>
<p>In line with the Make in India and Digital India initiatives, to enable India to be one of the global hubs of design, manufacturing, and exporting of electronics and IT hardware, we request that the budget 2016-17 focus on increasing flow of fund to start-ups and Medium and Small-Scale Manufacturing Enterprises (MSMEs) in the form of research and development grants (ideally connected to government, especially defense-related, spending on IT hardware innovation), seed capital, and venture capital.</p>
<p>Generation of awareness and industry-specific strategies to develop intellectual property regimes and practices favourable for manufacturers of electronics and IT hardware in India is an absolutely crucial part of promotion of the same, especially in the current global scenario. Start-ups and MSMEs must be made thoroughly aware of intellectual property concerns and possibilities, including limitations and exceptions, flexibilities, and alternative models such as open innovation.</p>
<p>We request the budget 2016-17 to give special emphasis to facilitation of technology licensing and transfer, through voluntary mechanisms as well as government intervention, such as compulsory licensing and government enforced patent pools.</p>
<p> </p>
<h3>Applied Mathematics Research is Fundamental for Cybersecurity</h3>
<p> </p>
<p>Recent global reports have revealed that some national governments have been actively involved in sponsoring distortion in applied mathematics research so as to introduce weaknesses in encryption standards used in for online communication. Instead of trying to regulate key-length or mandating pre-registration of devices using encryption, as suggested by the withdrawn National Encryption Policy draft, would not be able to address this core emerging problem of weak cybersecurity standards.</p>
<p>For effective and sustainable cybersecurity strategy, we must develop significant expertise in applied mathematical research, which is the very basis of cybersecurity standards development. We request the budget 2016-17 to give this topic the much-needed focus, especially in the context of the Digital India initiative and the upcoming National Encryption Policy.</p>
<p>Along with developing domestic research capacity, a more immediately important step for the government is to ensure high quality Indian participation in global standard setting organisations, and hence to contribute to global standards making processes. We humbly suggest that categorical support for such participation and contribution is provided through the budget 2016-17, perhaps by partially channeling the revenues obtained from spectrum auctions.</p>
<p> </p>
<p>
For more details visit <a href='https://cis-india.org/openness/pre-budget-consultation-2016-submission-to-the-ministry-of-finance'>https://cis-india.org/openness/pre-budget-consultation-2016-submission-to-the-ministry-of-finance</a>
</p>
No publishersumandroOpen StandardsOpen SourceCybersecurityOpen DataIntellectual Property RightsOpen Government DataFeaturedPatentsOpennessOpen InnovationEncryption Policy2016-01-12T13:34:41ZBlog EntryGuest post: Before cyber norms, let’s talk about disanalogy and disintermediation
https://cis-india.org/internet-governance/blog/guest-post-before-cyber-norms-let2019s-talk-about-disanalogy-and-disintermediation
<b>In a guest post in relation to CIS’s recently held roundtable onIndia’s cyber defense strategy, Pukhraj Singh looks at the critical fissures – at the technical and policy levels – in global normative efforts to secure cyberspace. By charting out the key vectors and power asymmetries among key stakeholders – both leading state actors and private actors like Microsoft – Singh posits that there is much to be done before we circumscribe cyber operations within legal strictures.</b>
<p> </p>
<p>By: <strong>Pukhraj Singh</strong><br />Reviewed and Edited by: <strong>Elonnai Hickok, Arindrajit Basu, </strong>and<strong> Karan Saini</strong></p>
<h3 id="docs-internal-guid-91bbb0b3-7fff-f86d-2f0c-43dae1a21a49" dir="ltr">The ongoing decoupling of norms </h3>
<p style="text-align: justify;" dir="ltr">In September 2019, the French ministry of defense <a href="https://www.defense.gouv.fr/content/download/565895/9750877/file/Droit+internat+appliqu%C3%A9+aux+op%C3%A9rations+Cyberespace.pdf">published</a> a document stating its views on the applicability of international law to cyber operations. While it makes an unequivocal espousal of the rules-based order in cyberspace, some of the distinctions made by the paper within the ambit of international law could be of interest to technical experts. </p>
<p style="text-align: justify;" dir="ltr">The document makes two key contributions. First, it <a href="https://www.justsecurity.org/66318/an-overview-of-international-humanitarian-law-in-frances-new-cyber-document/">addresses</a> two modes of power projection within cyberspace: cyber operations acting as a force multiplier in a hot war that is strictly delineated by kinetic and geographical redlines; and below-threshold, single-domain “dematerialized” operations leveraging cyber intrusions. Secondly, the document has made an attempt to gently <a href="https://blog.lukaszolejnik.com/french-application-of-international-rules-to-cyberwarfare/">decouple</a> itself from the Tallinn Manual on some aspects.</p>
<p style="text-align: justify;" dir="ltr">In an unrelated development, Microsoft joined hands with a group of peers within the technology industry, civil society and government to set up the <a href="https://blogs.microsoft.com/on-the-issues/2019/09/26/cyberpeace-institute-fills-a-critical-need-for-cyberattack-victims/">CyberPeace Institute</a> – a private sector initiative to strengthen the rules-based order. </p>
<p style="text-align: justify;" dir="ltr">It is an outcome of the sustained, unrelenting effort of Microsoft in thwarting what it believes to be the unchecked weaponization of cyberspace. Suffering a major reputational loss after the Snowden leaks, the company has <a href="https://www.wired.com/story/us-vs-microsoft-supreme-court-case-data/">gradually cultivated</a> fiercely <a href="https://www.irishtimes.com/business/technology/microsoft-s-brad-smith-talks-privacy-snowden-and-international-law-1.2816460">contrarian</a> <a href="https://www.cyberscoop.com/microsoft-cyber-peace-institute-hewlitt-foundation-brad-smith/">positions</a> on issues like state-enabled surveillance. </p>
<p style="text-align: justify;" dir="ltr">Microsoft’s daring contests and cases against the US government have been intimately recorded in the recently released book <a href="https://news.microsoft.com/on-the-issues/tools-and-weapons/">Tools and Weapons</a>, authored by its chief legal officer Brad Smith.</p>
<p style="text-align: justify;" dir="ltr">Seen through the lens of the future, the aforementioned developments highlight the ongoing readjustment of the legal discourse on cyber operations to account for its incongruous technical dynamics. </p>
<p style="text-align: justify;" dir="ltr">As the structures of cyber power are peeled layer-by-layer, the need to address this technical divergence in the overly legal interpretations of cyber norms would only increase.</p>
<h3 style="text-align: justify;" dir="ltr">Disanalogy & disintermediation</h3>
<p style="text-align: justify;" dir="ltr">Take the case of two fundamental dimensions – disanalogy and disintermediation – which have the potential to alter our understanding of how power is wedded with cyberspace.</p>
<p style="text-align: justify;" dir="ltr">Disanalogy is a logical postulation that challenges the primacy of “reasoning by analogy” using which international law is mapped to cyber conflict. Disintermediation highlights how the power dynamics of cyberspace have disrupted statism. </p>
<p style="text-align: justify;" dir="ltr">Understanding when and how the realization that international law is reasonably applicable to cyber operations dawned upon the international community leads one to an unending maze. It becomes a cyclical process where one set of initiatives only cross-reference the others, in a self-fulfilling sort of way. </p>
<p style="text-align: justify;" dir="ltr">The <a href="https://www.unidir.org/files/medias/pdfs/developments-in-the-field-of-information-and-telecommunications-in-the-context-of-international-security-2012-2013-a-68-98-eng-0-518.pdf">notes</a> of the 2013 session of the United Nations’ Governmental Group of Experts, affirming the sanctity of international law in cyberspace, look like an exercise in teleology. </p>
<p style="text-align: justify;" dir="ltr">Not to be distracted by the deeply philosophical nature of war, Kubo Mačák of the University of Exeter did <a href="https://ccdcoe.org/uploads/2018/10/Art-09-The-Impact-of-the-Development-of-the-Cyber-Law-of-War-on-General-International-Law.pdf">point out</a> that “the unique teleological underpinning of the law of war” should be considered before it is exported to new normative frameworks.</p>
<p style="text-align: justify;" dir="ltr">The deductive process inspired by reasoning by analogy that lies at the heart of the cyber norms discourse has not undergone much scrutiny. </p>
<p style="text-align: justify;" dir="ltr">In his 2013 <a href="https://www.youtube.com/watch?v=NdhhZcDk6aw">talk</a> at NATO’s CCDCOE, Selmer Bringsjord, cognitive sciences professor at the Rensselaer Polytechnic Institute, introduced the idea of disanalogy. Citing the <a href="https://plato.stanford.edu/entries/reasoning-analogy/">general schema of an analogical argument</a>, Bringsjord arrived at a disproof divorcing the source domain (the just war theory for conventional war) and target domain (just war theory for cyberwar). </p>
<p style="text-align: justify;" dir="ltr">He mapped jus in bello in a conventional war across the dimensions of Control, Proportionality, Accessibility, and Discrimination. </p>
<p style="text-align: justify;" dir="ltr">Bringsjord further added that these source attributes would not be evident in the target domain for two reasons: the inevitable digitization of every analog object and its interfaces; and the inherent propensity of artificial intelligence to wage attacks on its own.</p>
<p style="text-align: justify;" dir="ltr">In a supporting <a href="http://kryten.mm.rpi.edu/SB_JL_cyberwarfare_disanalogy_112113IT.pdf">paper</a>, he exhorts that while “Augustine and Aquinas (and their predecessors) had a stunningly long run…today’s world, based as it is on digital information and increasingly intelligent information-processing, points the way to a beast so big and so radically different, that the core of this duo’s insights needs to be radically extended.”</p>
<p style="text-align: justify;" dir="ltr">Celebrated malware reverse engineer Thomas Dullien, too, is of the <a href="https://www.youtube.com/watch?v=BWFdxAG_TGk">opinion</a> that machine learning and artificial intelligence are more suited for cyber offence as it has remained a “stable-in-time distribution.”</p>
<p style="text-align: justify;" dir="ltr">Brandon Valeriano of the Marine Corps University has drawn upon the case of incendiary balloons to <a href="https://www.cfr.org/blog/reasoning-analogy-cyberspace-deadly-balloons-and-avoiding-digital-doom">question</a> the overreliance on reasoning by analogy. Sadly, such viewpoints remain outliers.</p>
<p style="text-align: justify;" dir="ltr">Senior computer scientist David Aucsmith wrote in <a href="https://www.brookings.edu/book/bytes-bombs-and-spies/">Bytes, Bombs and Spies</a> that “one of the major challenges in cyberspace is the disintermediation of government.” He adds that while cyberspace has become the “global center of gravity for all aspects of national power,” it further removes the government from the “traditional functions of safety and security.”</p>
<p style="text-align: justify;" dir="ltr">The commercialized nature of the Internet is obvious to many. But steadily over the years, the private sector has also acquired vast swathes of cyber power in a manner that strangely mirrors the military concepts of counterintelligence, defense and deterrence. </p>
<p style="text-align: justify;" dir="ltr">In Tools and Weapons, Brad Smith recalls a meeting of top technology executives at the White House. As the executives pushed for surveillance reform after the Snowden leaks, Obama defensively retorted that “the companies at the table collectively had far more data than the government.” The “<a href="https://cybersecpolitics.blogspot.com/2016/06/can-google-do-cyber-deterrence.html">signals intelligence</a>” capabilities of <a href="https://www.wsj.com/articles/inside-googles-team-battling-hackers-11548264655">Google</a> and <a href="https://www.youtube.com/watch?v=OpTGFcJXL8g">Microsoft</a> rival that of a nation state. </p>
<p style="text-align: justify;" dir="ltr">Former deputy director of the NSA Chris Inglis writes in Bytes, Bombs and Spies: </p>
<p style="text-align: justify;" dir="ltr">In cyberspace, a small change in configuration of the target machine, system, or network can often negate the effectiveness of a cyber weapon against it. This is not true with weapons in other physical domains…The nature of target-weapon interaction with kinetic weapons can usually be estimated on the basis of physics experimentation and calculation. Not so with cyber weapons. For offensive cyber operations, this extreme “target dependence” means that intelligence information on target characteristics must be precise, high-volume, high-quality, current, and available at the time of the weapon’s use.</p>
<p style="text-align: justify;" dir="ltr">Inglis argues that fielding “ubiquitous, real-time and persistent” intelligence, surveillance and reconnaissance (ISR) frameworks is crucial for mustering the ability to produce cyber effects at a place and time of choosing. </p>
<p style="text-align: justify;" dir="ltr">Daniel Moore of King’s College London broadly <a href="https://ccdcoe.org/uploads/2018/10/Art-05-Targeting-Technology.-Mapping-Military-Offensive-Network-Operations.pdf">categorizes</a> cyber operations into event-based and presence-based.</p>
<p style="text-align: justify;" dir="ltr">The ISR framework envisioned by Inglis pre-positions implants with presence-based operations to make sure that the adversarial infrastructure -- perpetually in a state of flux -- remains primed for event-based operations. Falling prey to an analogy, this is as challenging as a group of river-rafters trying to keep their raft still at one position in a raging torrent of water.</p>
<p style="text-align: justify;" dir="ltr">However, it is worthy to note that a major component of such an ISR framework would manifest over privately-owned infrastructure. </p>
<p style="text-align: justify;" dir="ltr">It is exactly why the commercial threat intelligence industry lead by the likes of Fireeye, Kaspersky and Crowdstrike has flourished the way it has. </p>
<p style="text-align: justify;" dir="ltr">Joe Slowik, principal adversary hunter at Dragos, Inc., <a href="https://pylos.co/2019/09/28/cyber-leviathan/">corroborates</a> it: “An entire ecosystem of defense and security developed within the private space…essentially, private (defensive) ‘armies’ grew up and proliferated in the cyber security space over the course of many years.”</p>
<p style="text-align: justify;" dir="ltr">Jason Healey of Columbia’s School of International and Public Affairs has <a href="https://twitter.com/Jason_Healey/status/1181961759155994624">another way</a> of looking at it: “In counterinsurgency, host nation must take lead & U.S. role is to provide aid & support. USG not seen as legitimate, may lack the local & cultural knowledge, & lack sufficient resources. In cyberspace, the private sector, esp tech & security companies, are the host nation (sic)”.</p>
<p style="text-align: justify;" dir="ltr">Initiatives like the CyberPeace Institute and Cybersecurity Tech Accord are to be seen as emerging geopolitical formations pivoted around the power vacuum created by growing disintermediation.</p>
<p style="text-align: justify;" dir="ltr">While Microsoft avows the applicability of international law, the decreasing technological dependence on it to enforce the rules-based order may herald data-driven normative frameworks solely originating from the private sector.</p>
<p style="text-align: justify;" dir="ltr">Take the specific case of fashionable “black-letter rules” – like barring cyber actors from hacking into adversary’s election infrastructure – variedly promulgated by the <a href="https://www.wired.com/2013/03/the-tallinn-manual-on-the-international-law-applicable-to-cyber-warfare/">Tallinn Manual</a>, <a href="https://www.microsoft.com/en-us/cybersecurity/content-hub/a-digital-geneva-convention-to-protect-cyberspace">Microsoft</a> and <a href="https://cyberstability.org/news/global-commission-introduces-six-critical-norms-towards-cyber-stability/">Global Commission on the Stability of Cyberspace</a>. They could very well act as impediments to the success of the norms process.</p>
<p style="text-align: justify;" dir="ltr">Cyber actors can be variedly be divided into various <a href="https://cybersecpolitics.blogspot.com/2016/09/the-chinese-get-real.html">capability tiers</a>: A, B, C or D Teams, etc. Such categorizations could be derived from multiple <a href="https://cybersecpolitics.blogspot.com/2017/08/strategic-plateaus-in-cyber-domain.html">variables</a> like operational structure, concept of operations, capabilities and toolchains, and operating budget, etc. </p>
<p style="text-align: justify;" dir="ltr">In what may sound paradoxical, mindless enforcement of such rules creates an inherently inequitable environment where actors would be compelled to flout them. Targeting and target discrimination are possibly the most expensive components of the cyber offensive toolchain. As intelligence analyst Grugq <a href="https://www.youtube.com/watch?v=wP2J9aYM6Oo">said</a>, “You need a lot of people to have a small numbers of hackers hacking.”</p>
<p style="text-align: justify;" dir="ltr">The ability to avoid a vulnerable target or an attack surface without sacrificing the initiative is a luxury that only an A-team could afford, further disincentivizing smaller players from participating in confidence-building measures.</p>
<p style="text-align: justify;" dir="ltr">In such cases, the private sector could lead the way in the neutral and transparent interpretation of the dynamics and thresholds of power projection in cyberspace. Companies, not countries, have the vantage point and commercial interest to create a level playing field. </p>
<p style="text-align: justify;" dir="ltr">Taking the original case of France’s new dossier on cyber operations, its gradual rollback from the strictly black-and-white world of, say, the Tallinn Manual hints at a larger devolution of legally interpreted cyber operations, influenced by technical incongruities like disanalogy and disintermediation. </p>
<p style="text-align: justify;" dir="ltr">While the said document answers many questions relating to the applicability of international law to cyber operations with uncanny confidence, the devil still lies in the details. </p>
<p style="text-align: justify;" dir="ltr">For example, it talks about creating militaristic cyber effects by altering the confidentiality and availability of data on adversarial systems, but skirts around integrity – as if the three dimensions of data security are not symbiotic. Such picket-fencing may be trying to carefully avoid the legal ambiguity on information operations, post-ICJ US vs Nicaragua. </p>
<p style="text-align: justify;" dir="ltr">Ask any cyber operator, can a cyber operation proceed <a href="https://grugq.github.io/presentations/short%20course.pdf">without sabotaging</a> the integrity of log artifacts or other such stealthy or deceptive maneuvering?</p>
<p style="text-align: justify;" dir="ltr">It also postulates the export of “non-international armed conflict” to the territory of consenting nation states, as if such factors are completely controllable. </p>
<p style="text-align: justify;" dir="ltr">Discussed earlier, a majority of the cyber-ISR frameworks manifest over globally scattered private infrastructure. And almost every layer of the computing architecture is now network-enabled. </p>
<p style="text-align: justify;" dir="ltr">In cyberspace, the ‘territory’ of a nation state expands and contracts in real time. It may exist online as the sum of all the global information flows, across the many millions of interfaces, associated with it at any given moment. The sheer <a href="http://geer.tinho.net/geer.secot.7v14.txt">emergent complexity</a> of this organism has baffled many.</p>
<p style="text-align: justify;" dir="ltr">The adversarial environment fluxes at such a rapid pace that taking “territorial” sanctity into account during an ongoing operation is nigh impossible. This, in fact, is the <a href="https://www.justsecurity.org/67079/top-dod-lawyer-stresses-u-s-compliance-with-the-rule-of-law-in-military-operations/">very premise</a> of Defend Forward.</p>
<p style="text-align: justify;" dir="ltr">The French document is a good attempt at decoupling cyber operations from legal strictures, but it should be seen as the mere beginning of that process.</p>
<h3 style="text-align: justify;" dir="ltr">Cognitive cyber offence</h3>
<p style="text-align: justify;" dir="ltr">Lastly, the complete absence of the cognitive dimension in the norms process is something that should be outrightly addressed. </p>
<p style="text-align: justify;" dir="ltr">Keith Dear, a research fellow at Oxford’s Changing Character of War Program, <a href="https://www.youtube.com/watch?v=Nl_shMx8Yrs">feels</a> that war – as “a continuation of politics by other means” – is essentially persuasive and has predominantly psychological effects. They get aggravated more so by the scale and speed of cyber-enabled behavioral modelling.</p>
<p style="text-align: justify;" dir="ltr">The threat landscape is at a stage where we are going to see the increasing exploitation of <a href="https://www.teachthought.com/critical-thinking/the-cognitive-bias-codex-a-visual-of-180-cognitive-biases/">cyber-cognitive attack surfaces</a> – the cost-benefits are now heavily tilted towards their side. It is like what conventional cyber operations used to be 20 years ago: cheap and easy over scale and speed.</p>
<p style="text-align: justify;" dir="ltr">The cyber norms community only considers the first or second order effects of cyberattacks. The reality is that causation could be separated by many, many degrees – also missing out on the fact that a cyberattack is generally an indiscernible mixture of not just effects, but also perceptions. Every cyber operation could be <a href="https://dl.acm.org/citation.cfm?id=3316742&dl=ACM&coll=DL">deemed</a> as an information operation even after full denouement. </p>
<p style="text-align: justify;" dir="ltr">We have only begun to understand the significance of the cognitive dimension. Leading thinkers like former Secretary of the Navy Richard Danzig had for long proposed perceptive instead of spatial redlines for cyber conflict, aptly capturing its emergent properties.</p>
<p style="text-align: justify;" dir="ltr">His <a href="https://s3.amazonaws.com/files.cnas.org/documents/CNAS_PoisonedFruit_Danzig.pdf?mtime=20161010215746">suggested</a> baseline was: “The United States cannot allow the insecurity of our cyber systems to reach a point where weaknesses in those systems would likely render the United States unwilling to make a decision or unable to act on a decision fundamental to our national security.”</p>
<p style="text-align: justify;" dir="ltr">Danzig’s paradigm neatly fits into the Defend Forward philosophy of the US Cyber Command. Former director of the NSA Michael Hayden once <a href="https://www.usnews.com/news/articles/2013/02/20/former-cia-director-cyber-attack-game-changers-comparable-to-hiroshima">said</a> that Stuxnet had the “whiff of August 1945,” while former NSA exploitation engineer Dave Aitel <a href="https://cybersecpolitics.blogspot.com/2016/09/the-stern-stewart-summit-germany-and.html">labelled</a> it as the “announcement of a team.” The theatres of war, <a href="https://www.cfr.org/blog/not-cyber-deterrence-united-states-wants">frameworks</a> for deterrence and <a href="https://www.cfr.org/blog/sony-hack-north-koreas-toughest-counteraction-obamas-proportional-response">parameters</a> for proportional response may turn out to be purely perceptive in nature.</p>
<p style="text-align: justify;" dir="ltr">As the cyber option gets increasingly expended by militaries, we have <a href="https://www.washingtonpost.com/gdpr-consent/?destination=%2fpolitics%2f2019%2f10%2f01%2fare-cyber-operations-us-retaliatory-option-september-oilfield-strikes-would-this-deter-iran%2f%3f">come to understand</a> that the esoteric cognitive parameters of digital conflict could be crucial enough to decide victory or defeat.</p>
<h3 style="text-align: justify;" dir="ltr">Conclusion</h3>
<p style="text-align: justify;" dir="ltr">As the United Nations’ Governmental Group of Experts’ dialogue came to a grinding halt in 2016, Michelle Markoff, former deputy coordinator for Cyber Issues in the US State Department, gave a <a href="https://www.youtube.com/watch?v=nAuehrVCBBU&feature=youtu.be&t=4m10shttps://www.youtube.com/watch?v=nAuehrVCBBU&feature=youtu.be&t=4m10s">candid account</a> of what went wrong. </p>
<p style="text-align: justify;" dir="ltr">She also went on to recommend “interleaving strategies” like defence, declaratory policies, alliance activities, and norms of behaviour. It is interesting to note all the four dimensions proffered by her neatly fit into the remit of the private sector when it comes to fostering cyber stability. </p>
<p style="text-align: justify;" dir="ltr">The threat intelligence industry, by its indirect participation in the great power play, is already carving a rudimentary framework for declaratory signaling. Private sector alliances – by being more open and neutral about attack attribution, adversarial intent and capabilities, and targeting criteria – may lower the incentives while increasing the costs of cyber actions. That may force various actors to the negotiating table.</p>
<p style="text-align: justify;" dir="ltr">The emergence of customary international law in cyberspace, as a precursor to effective normative frameworks, is a necessity that may squarely fall on the shoulders of corporations. In that sense, diplomatic initiatives and alliance activities by Microsoft and others must be keenly observed.</p>
<p style="text-align: justify;" dir="ltr"> </p>
<hr />
<p> </p>
<p><em><strong>Pukhraj Singh is a cyber threat intelligence analyst who has worked with the Indian government and security response teams of global companies. He blogs at www.pukhraj.me. Views posited are the author’s alone.</strong></em></p>
<p>
For more details visit <a href='https://cis-india.org/internet-governance/blog/guest-post-before-cyber-norms-let2019s-talk-about-disanalogy-and-disintermediation'>https://cis-india.org/internet-governance/blog/guest-post-before-cyber-norms-let2019s-talk-about-disanalogy-and-disintermediation</a>
</p>
No publisherPukhraj SinghCybersecurityNorms Formulation2019-11-18T10:14:07ZBlog EntryCIS Cybersecurity Series (Part 9) - Saikat Datta
https://cis-india.org/internet-governance/blog/cis-cybersecurity-series-part-9-saikat-datta
<b>CIS interviews Saikat Datta, Resident Editor of DNA, Delhi, as part of the Cybersecurity Series.
</b>
<p><em>"Anonymous speech, in countries which have extremely severe systems of governments, which do not have freedom, etcetera, is welcome. But in a democracy like India, I do not see the need for anonymous speech because it is anyways guaranteed by the Constitution of India. So, no, I do not see the need for anonymity in an open and democratic state like India and I would be seriously worried if such a requirement comes up. Shouldn't I strive to be ideal? The ideal suggests that the constitution has guaranteed freedom of speech. Anonymity, for a time being may be acceptable to some people but I would like a situation where a person, without having to seek anonymity, can speak about anything and not be prosecuted by the state, or persecuted by society. And that is the ideal situation that I would like to strive for." - Saikat Datta, Resident Editor, DNA, Delhi.</em></p>
<p>Centre for Internet and Society presents its ninth installment of the CIS Cybersecurity Series. </p>
<p>The CIS Cybersecurity Series seeks to address hotly debated aspects of cybersecurity and hopes to encourage wider public discourse around the topic.</p>
<p>Saikat Datta is a journalist who began his career in December 1996 and has worked with several publications like The Indian Express, the Outlook magazine and the DNA newspaper. He is currently the Resident Editor of DNA, Delhi. Saikat has authored a book on India's Special Forces and presented papers at seminars organized by the Centre for Land Warfare Studies, the Centre for Air Power Studies and the National Security Guards. He has also been awarded the International Press Institute Award for investigative journalism, the National RTI award in the journalism category and the Jagan Phadnis Memorial Award for investigative journalism.</p>
<p> </p>
<iframe src="//www.youtube.com/embed/Fn2tqVU5mGg" frameborder="0" height="315" width="560"></iframe>
<div> </div>
<div><strong><em>This work was carried out as part of the Cyber Stewards Network with aid of a grant from the International Development Research Centre, Ottawa, Canada.</em></strong></div>
<p>
For more details visit <a href='https://cis-india.org/internet-governance/blog/cis-cybersecurity-series-part-9-saikat-datta'>https://cis-india.org/internet-governance/blog/cis-cybersecurity-series-part-9-saikat-datta</a>
</p>
No publisherpurbaCybersecurityCyberspaceCyberculturesCyber Security Interview2013-08-05T05:24:35ZBlog EntryCIS Cybersecurity Series (Part 10) - Lawrence Liang
https://cis-india.org/internet-governance/blog/cis-cybersecurity-series-part-10-lawrence-liang
<b>CIS interviews Lawrence Liang, researcher and lawyer, and co-founder of Alternative Law Forum, Bangalore, as part of the Cybersecurity Series.</b>
<p><em>"The right to privacy and the right to free speech have often been understood as distinct rights. But I think in the ecology of online communication, it becomes crucial for us to look at the two as being inseparable. And this is not entirely new in India. But, interestingly, a lot of the cases that have had to deal with this question in the Indian context, have pitted one against the other. Now, India doesn't have a law for the protection of whistle-blowers. So how do we now think of the idea of whistle-blowers being one of the subjects of speech and privacy coming together? How do we use the strong pillars that have been established, in terms of a very rich tradition that Indian law has, on the recognition of free speech issues but slowly start incorporating questions of privacy?" - Lawrence Liang, researcher and lawyer, Alternative Law Forum. </em></p>
<p>Centre for Internet and Society presents its tenth installment of the CIS Cybersecurity Series. </p>
<p>The CIS Cybersecurity Series seeks to address hotly debated aspects of cybersecurity and hopes to encourage wider public discourse around the topic.</p>
<p>Lawrence Liang is one of the co-founders of the Alternative Law Forum where he works on issues of intellectual property, censorship, and the intersection of law and culture. He is also a fellow with the Centre for Internet and Society and serves on its board. </p>
<iframe src="//www.youtube.com/embed/odQajlxcLLA" frameborder="0" height="315" width="420"></iframe>
<div> </div>
<div><strong><em>This work was carried out as part of the Cyber Stewards Network with aid of a grant from the International Development Research Centre, Ottawa, Canada.</em></strong></div>
<p>
For more details visit <a href='https://cis-india.org/internet-governance/blog/cis-cybersecurity-series-part-10-lawrence-liang'>https://cis-india.org/internet-governance/blog/cis-cybersecurity-series-part-10-lawrence-liang</a>
</p>
No publisherpurbaCybersecurityCyber SecurityCyberculturesCyber Security Interview2013-09-10T08:31:31ZBlog EntryNASSCOM-DSCI Annual Information Security Summit 2015 - Notes
https://cis-india.org/internet-governance/blog/nasscom-dsci-annual-information-security-summit-2015-notes
<b>NASSCOM-DSCI organised the 10th Annual Information Security Summit (AISS) 2015 in Delhi during December 16-17. Sumandro Chattapadhyay participated in this engaging Summit. He shares a collection of his notes and various tweets from the event.</b>
<p> </p>
<h2>Details about the Summit</h2>
<p>Event page: <a href="https://www.dsci.in/events/about/2261">https://www.dsci.in/events/about/2261</a>.</p>
<p>Agenda: <a href="https://www.dsci.in/sites/default/files/Agenda-AISS-2015.pdf">https://www.dsci.in/sites/default/files/Agenda-AISS-2015.pdf</a>.</p>
<p> </p>
<h2>Notes from the Summit</h2>
<blockquote class="twitter-tweet">
<p dir="ltr">Mr.G.K.Pillai ,Chairman DSCI addressing the audience @ 10th Annual Information Security Summit '15 <a href="https://twitter.com/hashtag/AISS15?src=hash">#AISS15</a> <a href="https://t.co/JVcwct3HSF">pic.twitter.com/JVcwct3HSF</a></p>
— DSCI (@DSCI_Connect) <a href="https://twitter.com/DSCI_Connect/status/676979952277987328">December 16, 2015</a></blockquote>
<p>Mr. G. K. Pillai, Chairman of Data Security Council of India (DSCI), set the tone of the Summit at the very first hour by noting that 1) state and private industries in India are working in silos when it comes to preventing cybercrimes, 2) there is a lot of skill among young technologists and entrepreneurs, and the state and the private sectors are often unaware of this, and 3) there is serious lack of (cyber-)capacity among law enforcement agencies.</p>
<p>In his Inaugural Address, Dr. Arvind Gupta (Deputy National Security Advisor and Secretary, NSCS), provided a detailed overview of the emerging challenges and framework of cybersecurity in India. He focused on the following points:</p>
<blockquote class="twitter-tweet">
<p dir="ltr"><a href="https://twitter.com/hashtag/India?src=hash">#India</a> Dy NSA Dr Arvind Gupta calls 4 <a href="https://twitter.com/hashtag/cybersecurity?src=hash">#cybersecurity</a> by <a href="https://twitter.com/hashtag/design?src=hash">#design</a> in <a href="https://twitter.com/hashtag/ICT?src=hash">#ICT</a> <a href="https://twitter.com/hashtag/AISS15?src=hash">#AISS15</a> <a href="https://t.co/79kq9lWGtk">pic.twitter.com/79kq9lWGtk</a></p>
— Deepak Maheshwari (@dmcorpaffair) <a href="https://twitter.com/dmcorpaffair/status/676980799347023872">December 16, 2015</a></blockquote>
<ul>
<li>Security is a key problem in the present era of ICTs as it is not in-built. In the upcoming IoT era, security must be built into ICT systems.</li>
<li>In the next billion addition to internet population, 50% will be from India. Hence cybersecurity is a big concern for India.</li>
<li>ICTs will play a catalytic role in achieving SDGs. Growth of internet is part of the sustainable development agenda.</li>
<li>We need a broad range of critical security services - big data analytics, identity management, etc.</li>
<li>The e-governance initiatives launched by the Indian government are critically dependent on a safe and secure internet.</li>
<li>Darkweb is a key facilitator of cybercrime. Globally there is a growing concern regarding the security of cyberspace.
</li><li>On the other hand, there exists deep divide in access to ICTs, and also in availability of content in local languages.</li>
<li>The Indian government has initiated bilateral cybersecurity dialogues with various countries.</li>
<li>Indian government is contemplating setting up of centres of excellence in cryptography. It has already partnered with NASSCOM to develop cybersecurity guidelines for smart cities.</li>
<li>While India is a large global market for security technology, it also needs to be self-reliant. Indian private sector should make use of government policies and bilateral trust enjoyed by India with various developing countries in Africa and south America to develop security technology solutions, create meaningful jobs in India, and export services and software to other developing countries.</li>
<li>Strong research and development, and manufacturing base are absolutely necessary for India to be self-reliant in cybersecurity. DSCI should work with private sector, academia, and government to coordinate and realise this agenda.</li>
<li>In the line of the Climate Change Fund, we should create a cybersecurity fund, since it is a global problem.</li>
<li>Silos are our bane in general. Bringing government agencies together is crucial. Trust issues (between government, private sector, and users) remain, and can only be resolved over time.</li>
<li>The demand for cybersecurity solutions in India is so large, that there is space for everyone.</li>
<li>The national cybersecurity centre is being set up.</li>
<li>Thinktanks can play a crucial role in helping the government to develop strategies for global cybersecurity negotiations. Indian negotiators are often capacity constrained.</li></ul>
<p>Rajendra Pawar, Chair of the NASSCOM Cyber Security Task Force, NASSCOM Cybersecurity Initiative, provided glimpses of the emerging business opportunity around cybersecurity in India:</p>
<ul>
<li>In next 10 years, the IT economy in India will be USD 350 bn, and <a href="https://blogs.dsci.in/building-usd-35-billion-cyber-security-industry-how-do-we-do-it/">10% of that will be the cybersecurity pie</a>. This means a million job only in the cybersecurity space.</li>
<li>Academic institutes are key to creation of new ideas and hence entrepreneurs. Government and private sectors should work closely with academic institutes.
<blockquote class="twitter-tweet">
<p dir="ltr">'Companies+Govt+Academia= High growth of the cybersecurity industry' - Rajendra Pawar at <a href="https://twitter.com/hashtag/AISS15?src=hash">#AISS15</a> <a href="https://twitter.com/DSCI_Connect">@DSCI_Connect</a></p>
— Shivangi Nadkarni (@shivanginadkarn) <a href="https://twitter.com/shivanginadkarn/status/676995090955530246">December 16, 2015</a></blockquote>
</li>
<li>Globally, cybersecurity innovation and industries happen in clusters. Cities and states must come forward to create such clusters.</li>
<li>2/3rd of the cybersecurity market is provision of services. This is where India has a great advantage, and should build on that to become a global brand in cybersecurity services.</li>
<li>Everyday digital security literacy and cultures need to be created.</li>
<li>Publication of cybersecurity best practices among private companies is a necessity.
<blockquote class="twitter-tweet">
<p dir="ltr">Corporate disclosures of breaches being considered with Nasscom under cybersec task force: Rajendra Pawar <a href="https://twitter.com/hashtag/AISS15?src=hash">#AISS15</a> <a href="https://twitter.com/DSCI_Connect">@DSCI_Connect</a> <a href="https://twitter.com/ETtech">@ETtech</a></p>
— Neha Alawadhi (@NehaAlawadhiET) <a href="https://twitter.com/NehaAlawadhiET/status/676994553799417856">December 16, 2015</a></blockquote>
</li>
<li>Dedicated cybersecurity spending should be made part of the e-governance budget of central and state governments.</li>
<li>DSCI should function as a clearing house of cybersecurity case studies. At present, thought leadership in cybersecurity comes from the criminals. By serving as a use case clearing house, DSCI will inform interested researchers about potential challenges for which solution needs to be created.</li></ul>
<p>Manish Tiwary of Microsoft informed the audience that India is in the top 3 positions globally in terms of malware proliferation, and this ensures that India is a big focus for Microsoft in its global war against malware. Microsoft India looks forward to work closely with CERT-In and other government agencies.</p>
<blockquote class="twitter-tweet">
<p dir="ltr">RSA's Kartik Shahani <a href="https://twitter.com/DSCI_Connect">@DSCI_Connect</a> <a href="https://twitter.com/hashtag/AISS15?src=hash">#AISS15</a> Adopt a Deep & Pervasive Level of True Visibility Everywhere <a href="https://t.co/2U8J8WkWsI">pic.twitter.com/2U8J8WkWsI</a></p>
— Debjani Gupta (@DebjaniGupta1) <a href="https://twitter.com/DebjaniGupta1/status/676999786722156544">December 16, 2015</a></blockquote>
<blockquote class="twitter-tweet">
<p dir="ltr">Data localization; one of the stumbling blocks that undermine investments in <a href="https://twitter.com/hashtag/cybersecurity?src=hash">#cybersecurity</a>. <a href="https://twitter.com/hashtag/AISS15?src=hash">#AISS15</a> <a href="https://t.co/vrff3Amcv0">pic.twitter.com/vrff3Amcv0</a></p>
— Appvigil (@appvigil_co) <a href="https://twitter.com/appvigil_co/status/677043180731301888">December 16, 2015</a></blockquote>
<blockquote class="twitter-tweet">
<p dir="ltr">Trust verification 4 embedded devices isnt complex bt much desired as people lives r dependent on that-cld cause physical damage <a href="https://twitter.com/hashtag/AISS15?src=hash">#AISS15</a></p>
— Lokesh Mehra (@lokesh_mehra) <a href="https://twitter.com/lokesh_mehra/status/677057992831860736">December 16, 2015</a></blockquote>
<blockquote class="twitter-tweet">
<p dir="ltr">"Most compromised OS in 2k15: iOS"-Riyaz Tambe, Palo Alto Networks <a href="https://twitter.com/hashtag/AISS15?src=hash">#AISS15</a></p>
— Indira Sen (@drealcharbar) <a href="https://twitter.com/drealcharbar/status/677015382356533249">December 16, 2015</a></blockquote>
<blockquote class="twitter-tweet">
<p dir="ltr">Security by default in IOS architecture tho' can't verify code as noṭ open - is it security by obscurity? <a href="https://twitter.com/hashtag/AISS15?src=hash">#AISS15</a> <a href="https://t.co/kbPZgH8oA0">pic.twitter.com/kbPZgH8oA0</a></p>
— Lokesh Mehra (@lokesh_mehra) <a href="https://twitter.com/lokesh_mehra/status/677055086611173376">December 16, 2015</a></blockquote>
<p>The session on <strong>Catching Fraudsters</strong> had two insightful presentations from Dr. Triveni Singh, Additional SP of Special Task Force of UP Police, and Mr. Manoj Kaushik, IAS, Additional Director of FIU.</p>
<p>Dr. Singh noted that a key challenge faced by police today is that nobody comes to them with a case of online fraud. Most fraud businesses are run by young groups operating BPOs that steal details from individuals. There exists a huge black market of financial and personal data - often collected from financial institutions and job search sites. Almost any personal data can be bought in such markets. Further, SIM cards under fake names are very easy to buy. The fraudsters are effective using all fake identity, and is using operational infrastructures outsourced from legitimate vendors under fake names. Without a central database of all bank customers, it is very difficult for the police to track people across the financial sector. It becomes even more difficult for Indian police to get access to personal data of potential fraudsters when it is stored in a foreign server. which is often the case with usual web services and apps. Many Indian ISPs do not keep IP history data systematically, or do not have the technical expertise to share it in a structured and time-sensitive way.</p>
<blockquote class="twitter-tweet">
<p dir="ltr">Mr. Triveni Singh talks about raiding fake call centres in Delhi NCR that scam millions every year <a href="https://twitter.com/hashtag/AISS15?src=hash">#AISS15</a> <a href="https://t.co/EmE4y3jux2">pic.twitter.com/EmE4y3jux2</a></p>
— pradyumn nand (@PradyumnNand) <a href="https://twitter.com/PradyumnNand/status/677063276442738689">December 16, 2015</a></blockquote>
<p>Mr. Kaushik explained that no financial fraud is uniquely committed via internet. Many fraud begin with internet but eventually involve physical fraudulent money transaction. Credit/debit card frauds all involve card data theft via various internet-based and physical methods. However, cybercrime is continued to be mistakenly seen as frauds undertaken completely online. Further, mobile-based frauds are yet another category. Almost all apps we use are compromised, or store transaction history in an insecure way, which reveals such data to hackers. FIU is targeting bank accounts to which fraud money is going, and closing them down. Catching the people behind these bank accounts is much more difficult, as account loaning has become a common practice - where valid accounts are loaned out for a small amount of money to fraudsters who return the account after taking out the fraudulent money. Better information sharing between private sector and government will make catching fraudsters easier.</p>
<blockquote class="twitter-tweet">
<p dir="ltr"><a href="https://twitter.com/AkhileshTuteja">@AkhileshTuteja</a> With data overload and big data being prevalent are we considering privacy elements <a href="https://twitter.com/hashtag/AISS15?src=hash">#AISS15</a> <a href="https://twitter.com/hashtag/KpmgIndiaCyber?src=hash">#KpmgIndiaCyber</a></p>
— Atul Gupta (@AtulGup15843145) <a href="https://twitter.com/AtulGup15843145/status/677082045701488640">December 16, 2015</a></blockquote>
<blockquote class="twitter-tweet">
<p dir="ltr">'Tech solns today designed to protect security - solns for privacy need to evolve'- <a href="https://twitter.com/Mayurakshi_Ray">@Mayurakshi_Ray</a> <a href="https://twitter.com/hashtag/AISS15?src=hash">#AISS15</a> <a href="https://twitter.com/DSCI_Connect">@DSCI_Connect</a></p>
— Shivangi Nadkarni (@shivanginadkarn) <a href="https://twitter.com/shivanginadkarn/status/677066470325534721">December 16, 2015</a></blockquote>
<blockquote class="twitter-tweet">
<p dir="ltr">In-house tools important but community collaboration critical to fight security threats <a href="https://twitter.com/tata_comm">@tata_comm</a> <a href="https://twitter.com/hashtag/AISS15?src=hash">#AISS15</a> <a href="https://t.co/ZjbCnaROXC">pic.twitter.com/ZjbCnaROXC</a></p>
— aparna (@aparnag14) <a href="https://twitter.com/aparnag14/status/677067260268187648">December 16, 2015</a></blockquote>
<blockquote class="twitter-tweet">
<p dir="ltr">'Orgns in India have a long way to go b4 they internalise privacy principles' Subhash S, CISO ICICI <a href="https://twitter.com/hashtag/AISS15?src=hash">#AISS15</a> <a href="https://twitter.com/DSCI_Connect">@DSCI_Connect</a></p>
— Shivangi Nadkarni (@shivanginadkarn) <a href="https://twitter.com/shivanginadkarn/status/677066928880410624">December 16, 2015</a></blockquote>
<blockquote class="twitter-tweet">
<p dir="ltr">Prof PK giving an interesting brief on Academia role in Cyber Security. <a href="https://twitter.com/ponguru">@ponguru</a> <a href="https://twitter.com/DSCI_Connect">@DSCI_Connect</a> at <a href="https://twitter.com/hashtag/AISS15?src=hash">#AISS15</a> <a href="https://t.co/MEiO6sCJwu">pic.twitter.com/MEiO6sCJwu</a></p>
— Vikas Yadav (@VikasSYadav) <a href="https://twitter.com/VikasSYadav/status/677088566871101440">December 16, 2015</a></blockquote>
<blockquote class="twitter-tweet">
<p dir="ltr">Potential for interaction between Academia, Government and Industry but not an established reality yet. <a href="https://twitter.com/hashtag/AISS15?src=hash">#AISS15</a> <a href="https://twitter.com/hashtag/MappingCyberEducation?src=hash">#MappingCyberEducation</a></p>
— Indira Sen (@drealcharbar) <a href="https://twitter.com/drealcharbar/status/677089590717517824">December 16, 2015</a></blockquote>
<blockquote class="twitter-tweet">
<p dir="ltr">I have figured out why information security is not in any boardroom discussions. Cause there are no good speakers / orators . <a href="https://twitter.com/hashtag/AISS15?src=hash">#AISS15</a></p>
— Virag Thakkar (@viragthakkar) <a href="https://twitter.com/viragthakkar/status/677078491699871745">December 16, 2015</a></blockquote>
<p>The session on <strong>Smart Cities</strong> focused on discussing the actual cities coming up India, and the security challenges highlighted by them. There was a presentation on Mahindra World City being built near Jaipur. Presenters talked about the need to stabilise, standardise, and securitise the unique identities of machines and sensors in a smart city context, so as to enable secured machine-to-machine communication. Since 'smartness' comes from connecting various applications and data silos together, the governance of proprietary technology and ensuring inter-operable data standards are crucial in the smart city.</p>
<p>As Special Purposed Vehicles are being planned to realise the smart cities, the presenters warned that finding the right CEOs for these entities will be critical for their success. Legacy processes and infrastructures (and labour unions) are a big challenge when realising smart cities. Hence, the first step towards the smart cities must be taken through connected enforcement of law, order, and social norms.</p>
<p>Privacy-by-design and security-by-design are necessary criteria for smart cities technologies. Along with that regular and automatic software/middleware updating of distributed systems and devices should be ensured, as well as the physical security of the actual devices and cables.</p>
<p>In terms of standards, security service compliance standards and those for protocols need to be established for the internet-of-things sector in India. On the other hand, there is significant interest of international vendors to serve the Indian market. All global data and cloud storage players, including Microsoft Azure cloud, are moving into India, and are working on substantial and complete data localisation efforts.</p>
<blockquote class="twitter-tweet">
<p dir="ltr">Session - Why should you hire Women Security Professionals?... Balancing gender diversity
<a href="https://twitter.com/hashtag/AISS15?src=hash">#AISS15</a> <a href="https://twitter.com/hashtag/DSCI_Connect?src=hash">#DSCI_Connect</a> <a href="https://t.co/uIMfG9PvAb">pic.twitter.com/uIMfG9PvAb</a></p>
— Jagan Suri (@jsuri90) <a href="https://twitter.com/jsuri90/status/677109792679157760">December 16, 2015</a></blockquote>
<blockquote class="twitter-tweet">
<p dir="ltr">gender Diversity in cybersecurity critical 4 India's future. <a href="https://twitter.com/symantec">@symantec</a> partnered with <a href="https://twitter.com/nasscom">@nasscom</a> via 1000 women scholarships <a href="https://twitter.com/hashtag/AISS15?src=hash">#AISS15</a></p>
— Lokesh Mehra (@lokesh_mehra) <a href="https://twitter.com/lokesh_mehra/status/677118674197602304">December 16, 2015</a></blockquote>
<blockquote class="twitter-tweet">
<p dir="ltr">Dialogue with CERT-In
.. Starting 2nd Day of <a href="https://twitter.com/hashtag/AISS15?src=hash">#AISS15</a>
.. B J Srinath, DG, CERT
<a href="https://twitter.com/DSCI_Connect">@DSCI_Connect</a> <a href="https://twitter.com/hashtag/security?src=hash">#security</a> <a href="https://twitter.com/hashtag/privacy?src=hash">#privacy</a> <a href="https://t.co/cvDcrgkein">pic.twitter.com/cvDcrgkein</a></p>
— Vinayak Godse (@godvinayak) <a href="https://twitter.com/godvinayak/status/677342972170493952">December 17, 2015</a></blockquote>
<blockquote class="twitter-tweet">
<p dir="ltr">New <a href="https://twitter.com/hashtag/problems?src=hash">#problems</a> can't b solved w old <a href="https://twitter.com/hashtag/solutions?src=hash">#solutions</a>: <a href="https://twitter.com/hashtag/India?src=hash">#India</a> CERT DG BJ Srinath <a href="https://twitter.com/hashtag/AISS15?src=hash">#AISS15</a></p>
— Deepak Maheshwari (@dmcorpaffair) <a href="https://twitter.com/dmcorpaffair/status/677341246281539585">December 17, 2015</a></blockquote>
<blockquote class="twitter-tweet">
<p dir="ltr">17 entities within <a href="https://twitter.com/hashtag/Indian?src=hash">#Indian</a> <a href="https://twitter.com/hashtag/government?src=hash">#government</a> engaged in <a href="https://twitter.com/hashtag/cybersecurity?src=hash">#cybersecurity</a>: <a href="https://twitter.com/hashtag/India?src=hash">#India</a> CERT head <a href="https://twitter.com/hashtag/AISS15?src=hash">#AISS15</a></p>
— Deepak Maheshwari (@dmcorpaffair) <a href="https://twitter.com/dmcorpaffair/status/677341728282533888">December 17, 2015</a></blockquote>
<blockquote class="twitter-tweet">
<p dir="ltr">Scope of activities by CERT in <a href="https://twitter.com/hashtag/India?src=hash">#India</a> way more than its counterparts elsewhere <a href="https://twitter.com/hashtag/AISS15?src=hash">#AISS15</a></p>
— Deepak Maheshwari (@dmcorpaffair) <a href="https://twitter.com/dmcorpaffair/status/677342193854451712">December 17, 2015</a></blockquote>
<blockquote class="twitter-tweet">
<p dir="ltr"><a href="https://twitter.com/hashtag/India?src=hash">#India</a> CERT looks 8 prediction & <a href="https://twitter.com/hashtag/prevention?src=hash">#prevention</a> <a href="https://twitter.com/hashtag/cybersecurity?src=hash">#cybersecurity</a> <a href="https://twitter.com/hashtag/emergency?src=hash">#emergency</a> not just <a href="https://twitter.com/hashtag/response?src=hash">#response</a> <a href="https://twitter.com/hashtag/AISS15?src=hash">#AISS15</a></p>
— Deepak Maheshwari (@dmcorpaffair) <a href="https://twitter.com/dmcorpaffair/status/677343140630540288">December 17, 2015</a></blockquote>
<blockquote class="twitter-tweet">
<p dir="ltr"><a href="https://twitter.com/hashtag/India?src=hash">#India</a> CERT willing to <a href="https://twitter.com/hashtag/share?src=hash">#share</a> <a href="https://twitter.com/hashtag/information?src=hash">#information</a> rather than just receiving <a href="https://twitter.com/hashtag/AISS15?src=hash">#AISS15</a></p>
— Deepak Maheshwari (@dmcorpaffair) <a href="https://twitter.com/dmcorpaffair/status/677343512833101824">December 17, 2015</a></blockquote>
<blockquote class="twitter-tweet">
<p dir="ltr">Savita CERTin outlines drill initiatives taken 4 preparedness-detect (protect), defend attacks wth response <a href="https://twitter.com/hashtag/AISS15?src=hash">#AISS15</a> <a href="https://t.co/wXrkgoLzr2">pic.twitter.com/wXrkgoLzr2</a></p>
— Lokesh Mehra (@lokesh_mehra) <a href="https://twitter.com/lokesh_mehra/status/677346822449303553">December 17, 2015</a></blockquote>
<blockquote class="twitter-tweet">
<p dir="ltr">CERTin also offers incident predicatibility,Crisis mgmt plans, <a href="https://twitter.com/hashtag/cybersecurity?src=hash">#cybersecurity</a> assurance ladder (7 levels) besides 24 x 7 prevention <a href="https://twitter.com/hashtag/AISS15?src=hash">#AISS15</a></p>
— Lokesh Mehra (@lokesh_mehra) <a href="https://twitter.com/lokesh_mehra/status/677348506869239809">December 17, 2015</a></blockquote>
<blockquote class="twitter-tweet">
<p dir="ltr"><a href="https://twitter.com/hashtag/India?src=hash">#India</a> has 7.2 million bot infected <a href="https://twitter.com/hashtag/machines?src=hash">#machines</a>: <a href="https://twitter.com/hashtag/India?src=hash">#India</a> CERT DG Srinath <a href="https://twitter.com/hashtag/AISS15?src=hash">#AISS15</a></p>
— Deepak Maheshwari (@dmcorpaffair) <a href="https://twitter.com/dmcorpaffair/status/677355051308871680">December 17, 2015</a></blockquote>
<blockquote class="twitter-tweet">
<p dir="ltr">Seizure & protection of electronic devices as admissible evidence (certificate u Sec 65B) imperative under Forensics investigation <a href="https://twitter.com/hashtag/AISS15?src=hash">#AISS15</a></p>
— Lokesh Mehra (@lokesh_mehra) <a href="https://twitter.com/lokesh_mehra/status/677364713005576192">December 17, 2015</a></blockquote>
<blockquote class="twitter-tweet">
<p dir="ltr">'Law enforcement agency&corporate world must collaborate to fight cybercrime'-Atul Gupta,Partner-Risk Adv. @ <a href="https://twitter.com/hashtag/AISS15?src=hash">#AISS15</a> <a href="https://t.co/GwAQWhYMmK">pic.twitter.com/GwAQWhYMmK</a></p>
— KPMG India (@KPMGIndia) <a href="https://twitter.com/KPMGIndia/status/677373217711919104">December 17, 2015</a></blockquote>
<p>Mr. R. Chandrasekhar, President of NASSCOM, foregrounded the recommendations made by the Cybersecurity Special Task Force of NASSCOM, in his Special Address on the second day. He noted:</p>
<ul>
<li>There is a great opportunity to brand India as a global security R&D and services hub. Other countries are also quite interested in India becoming such a hub.</li>
<li>The government should set up a cybersecurity startup and innovation fund, in coordination with and working in parallel with the centres of excellence in internet-of-things (being led by DeitY) and the data science/analytics initiative (being led by DST).</li>
<li>There is an immediate need to create a capable workforce for the cybersecurity industry.</li>
<li>Cybersecurity affects everyone but there is almost no public disclosure. This leads to low public awareness and valuation of costs of cybersecurity failures. The government should instruct the Ministry of Corporate Affairs to get corporates to disclose (publicly or directly to the Ministry) security breeches.</li>
<li>With digital India and everyone going online, cyberspace will increasingly be prone to attacks of various kinds, and increasing scale of potential loss. Cybersecurity, hence, must be part of the core national development agenda.</li>
<li>The cybersecurity market in India is big enough and under-served enough for everyone to come and contribute to it.</li></ul>
<p>The Keynote Address by Mr. Rajiv Singh, MD – South Asia of Entrust Datacard, and Mr. Saurabh Airi, Technical Sales Consultant of Entrust Datacard, focused on trustworthiness and security of online identities for financial transactions. They argued that all kinds of transactions require a common form factor, which can be a card or a mobile phone. The key challenge is to make the form factor unique, verified, and secure. While no programme is completely secure, it is necessary to build security into the form factor - security of both the physical and digital kind, from the substrates of the card to the encryption algorithms. Entrust and Datacard have merged in recent past to align their identity management and security transaction workflows, from physical cards to software systems for transactions. The advantages of this joint expertise have allowed them to successfully develop the National Population Register cards of India. Now, with the mobile phone emerging as a key financial transaction form factor, the challenge across the cybersecurity industry is to offer the same level of physical, digital, and network security for the mobile phone, as are provided for ATM cards and cash machines.</p>
<p>The following Keynote Address by Dr. Jared Ragland, Director - Policy of BSA, focused on the cybersecurity investment landscape in India and the neighbouring region. BSA, he explained, is a global trade body of software companies. All major global software companies are members of BSA. Recently, BSA has produced a study on the cybersecurity industry across 10 markets in the Asia Pacific region, titled <a href="http://cybersecurity.bsa.org/2015/apac/">Asia Pacific Cybersecurity Dashboard</a>. The study provides an overview of cybersecurity policy developments in these countries, and sector-specific opportunities in the region. Dr. Ragland mentioned the following as the key building blocks of cybersecurity policy: legal foundation, establishment of operational entities, building trust and partnerships (PPP), addressing sector-specific requirements, and education and awareness. As for India, he argued that while steady steps have been taken in the cybersecurity policy space by the government, a lot remains to be done. Operationalisation of the policy is especially lacking. PPPs are happening but there is a general lack of persistent formal engagement with the private sector, especially with global software companies. There is almost no sector-specific strategy. Further, the requirement for India-specific testing of technologies, according to domestic and not global standards, is leading to entry barrier for global companies and export barrier for Indian companies. Having said that, Dr. Ragland pointed out that India's cybersecurity experience is quite representative of that of the Asia Pacific region. He noted the following as major stumbling blocks from an international industry perspective: unnecessary and unreasonable testing requirements, setting of domestic standards, and data localisations rules.</p>
<blockquote class="twitter-tweet">
<p dir="ltr">The Policy Makers' panel in <a href="https://twitter.com/hashtag/AISS15?src=hash">#AISS15</a> in progress. Arvind Gupta, Head, BJP IT cell (<a href="https://twitter.com/buzzindelhi">@buzzindelhi</a>) speaks. <a href="https://t.co/9yWR0gMwf5">pic.twitter.com/9yWR0gMwf5</a></p>
— Nandkumar Saravadé (@saravade) <a href="https://twitter.com/saravade/status/677437443356798977">December 17, 2015</a></blockquote>
<p>One of the final sessions of the Summit was the Public Policy Dialogue between <a href="https://twitter.com/rajeevgowda">Prof. M.V. Rajeev Gowda</a>, Member of Parliament, Rajya Sabha, and <a href="https://twitter.com/buzzindelhi">Mr. Arvind Gupta</a>, Head of IT Cell, BJP.</p>
<p>Prof. Gowda focused on the following concerns:</p>
<ul>
<li>We often freely give up our information and rights over to owners of websites and applications on the web. We need to ask questions regarding the ownership, storage, and usage of such data.</li>
<li>While Section 66A of Information Technology Act started as a anti-spam rule, it has actually been used to harass people, instead of protecting them from online harassment.</li>
<li>The bill on DNA profiling has raised crucial privacy concerns related to this most personal data. The complexity around the issue is created by the possibility of data leakage and usage for various commercial interests.</li>
<li>We need to ask if western notions of privacy will work in the Indian context.</li>
<li>We need to move towards a cashless economy, which will not only formalise the existing informal economy but also speed up transactions nationally. We need to keep in mind that this will put a substantial demand burden on the communication infrastructure, as all transactions will happen through these.</li></ul>
<p> Mr. Gupta shared his keen insights about the key public policy issues in <em>digital India</em>:</p>
<ul>
<li>The journey to establish <em>the digital</em> as a key political agenda and strategy within BJP took him more than 6 years. He has been an entrepreneur, and will always remain one. His approached his political journey as an entrepreneur.
</li><li>While we are producing numerous digitally literate citizens, the companies offering services on the internet often unknowingly acquire data about these citizens, store them, and sometimes even expose them. India perhaps produces the greatest volume of digital exhaust globally.</li>
<li>BJP inherited the Aadhaar national identity management platform from UPA, and has decided to integrate it deeply into its digital India architecture.</li>
<li>Financial and administrative transactions, especially ones undertake by and with governments, are all becoming digital and mostly Aadhaar-linked. We are not sure where all such data is going, and who all has access to such data.</li>
<li>Right now there is an ongoing debate about using biometric system for identification. The debate on privacy is much needed, and a privacy policy is essential to strengthen Aadhaar. We must remember that the benefits of Aadhaar clearly outweigh the risks. Greatest privacy threats today come from many other places, including simple mobile torch apps.</li>
<li>India is rethinking its cybersecurity capacities in a serious manner. After Paris attack it has become obvious that the state should be allowed to look into electronic communication under reasonable guidelines. The challenge is identifying the fine balance between consumers' interest on one hand, and national interest and security concerns on the other. Unfortunately, the concerns of a few is often getting amplified in popular media.</li>
<li>MyGov platform should be used much more effectively for public policy debates. Social media networks, like Twitter, are not the correct platforms for such debates.</li></ul>
<p> </p>
<blockquote class="twitter-tweet">
<p dir="ltr"><a href="https://twitter.com/hashtag/AISS15?src=hash">#AISS15</a>: <a href="https://twitter.com/rajivgowda">@rajivgowda</a> & <a href="https://twitter.com/buzzindelhi">@buzzindelhi</a> are talking abt proactive disclosure as a key part of <a href="https://twitter.com/hashtag/cybersecurity?src=hash">#cybersecurity</a> strategy <a href="https://twitter.com/hashtag/openData?src=hash">#openData</a> <a href="https://twitter.com/DataPortalIndia">@DataPortalIndia</a></p>
— sumandro (@ajantriks) <a href="https://twitter.com/ajantriks/status/677447609502445568">December 17, 2015</a></blockquote>
<p> </p>
<p>
For more details visit <a href='https://cis-india.org/internet-governance/blog/nasscom-dsci-annual-information-security-summit-2015-notes'>https://cis-india.org/internet-governance/blog/nasscom-dsci-annual-information-security-summit-2015-notes</a>
</p>
No publishersumandroCybersecurityNASSCOMDSCIInformation SecurityCyber Security2016-01-19T07:58:56ZBlog Entry