Food-writer and campaigner, Jack Monroe, has become the latest high-profile victim of a SIM-swap scam, losing over £5,000 from both her PayPal and bank accounts to a criminal who intercepted SMS authentication codes. The Payment Services Directive requires that fraud victims get their money back, but banks act slowly and sometimes push the blame onto the victims. When (as I hope it will) the money does eventually get reimbursed, she’s still unlikely to get compensation for any consequential losses, nor for the upset caused. It’s no surprise that this experience has been stressful for Jack, as it would be for most people in her situation.
I am, of course, very sympathetic to victims of SIM-swap fraud and recognise the substantial financial costs, as well as the sense of violation that results. Naturally, fingers are being pointed at the phone companies and followed up with calls for them to do better identity checks before transferring a phone number to a new SIM card. I think this isn’t entirely fair. The real problem is that banks and other payment service providers have outsourced authentication to phone companies, without ensuring that the level of security is appropriate for the sums of money at risk. Banks could have chosen to distribute authentication devices and find a secure way to re-issue ones that are lost. Instead, they have pushed this task to unwitting phone companies, and leave their customers to pick up the pieces when things go wrong, so don’t have an incentive to do better.
More secure SMS authentication
But what if phone companies did do a better job at handing out replacement SIM cards? Maybe the government could push them into doing so, or the phone companies might just get fed up with the bad press. Phone companies could, in principle, set up a process for re-issuing SIM cards which would meet the highest standards of the banking industry. Let’s put aside the issue that SMS was never designed to be secure, and that these processes would put up the cost of phone bills – would it fix the problem? I would argue that it does not. Processes good enough for banking authentication could lock people out of receiving phone calls, and disproportionately harm the most vulnerable members of society.
The Payment System Regulator (PSR) has just announced that the UK’s six largest banks must check whether the name of the recipient of a transfer matches what the sender thinks. This new feature should help address a security loophole in online payments: the name of the recipient of transfers is ignored, contrary to expectations and unlike cheques. This improved security should make some fraud more difficult, but banks must be prevented from exploiting the change to unfairly shift the liability of the remaining crime to the victims.
The PSR’s target is for checks to be fully implemented by March 2020, somewhat later than their initial promise to Parliament of September 2018 and subsequent target of July 2019. The new proposal, known as Confirmation of Payee, also only covers the six largest banking groups, but this should cover 90% of transfers. Its goal is to defend against criminals who trick victims into transferring funds under the false pretence that the money is going to the victim’s new account, whereas it is really going to the criminal. The losses from such fraud, known as push payment scams, are often life-changing, resulting in misery for the victims.
Checks on the recipient name will make this particular scam harder, so while unlikely to prevent all types of push payment scams they will hopefully force criminals to adopt strategies that are easier to prevent. The risk that consumer representatives and regulators will need to watch out for is that these new security measures could result in victims being unfairly held liable. This scenario is, unfortunately, likely because the voluntary consumer protection code for push payment scams excuses the bank from liability if they show the customer a Confirmation of Payee warning.
Warning fatigue and misaligned incentives
In my response to the consultation over this consumer protection code, I raised the issue of “warning fatigue” – that customers will be shown many irrelevant warnings while they do online banking and this reduces the likelihood that customers will notice important ones. Even Confirmation of Payee warnings will frequently be wrong, such as if the recipient’s bank account is under a different name to what the sender expects. If the two names are very dissimilar, the sender won’t be given more details but if the name entered is close to the name in bank records the sender should be told what the correct one is and asked to compare.
Facebook’s new cryptocurrency, Libra, has the ambitious goal of being the “financial infrastructure that empowers billions of people”. This aspiration will only be achievable if the user-experience (UX) of Libra and associated technologies is competitive with existing payment channels. Now, Facebook has an excellent track record of building high-quality websites and mobile applications, but good UX goes further than just having an aesthetically pleasing and fast user interface. We can already see aspects of Libra’s design that will have consequences on the experience of its users making payments.
For example, the basket of assets that underly the Libra currency should ensure that its value should not be too volatile in terms of the currencies represented within the reserve, so easing international payments. However, Libra’s value will fluctuate against every other currency, creating a challenge for domestic payments. People won’t be paid their salary in Libra any time soon, nor will rents be denominated in Libra. If the public is expected to hold significant value in Libra, fluctuations in the currency markets could make the difference between someone being able to pay their rent or not – a certainly unwelcome user experience.
Whether the public will consider the advantages of Libra are worth the exposure to the foibles of market fluctuations is an open question, but in this post, I’m mostly going to discuss the consequences another design decision baked into the design of Libra: that transactions are irrevocable. Once a transaction is accepted by the validator network, the user may proceed “knowing that the transaction can never be changed or reversed“. This is a common design decision within cryptocurrencies because it ensures that companies, governments and regulators should be unable to revoke payments they dislike. When coupled with anonymity or decentralisation, to prevent blacklisted transactions being blocked beforehand, irrevocability creates a censorship-resistant payment system.
Mitigating the cost of irrevocable transactions
Libra isn’t decentralised, nor is it anonymous, so it is unlikely to be particularly resistant to censorship over matters when there is an international consensus. Irrevocability does, however, make fraud easier because once stolen funds are gone, they cannot be reinstated, even if the fraud is identified. Other cryptocurrencies share Libra’s irrevocability (at least in theory), but they are designed for technically sophisticated users, and their risk of theft can be balanced against the potentially substantial gains (and losses) that can be made from volatile cryptocurrencies. While irrevocability is common within cryptocurrencies, it is not within the broader payments industry. Exposing billions of people to the risk of their Libra holdings being stolen, without the potential for recourse, isn’t good UX. I’ve argued that irrevocable transactions protect the interests of financial institutions over those of the public, and are the wrong default for payments. Eventually, public pressure and regulatory intervention forced UK banks to revoke fraudulent transactions, and they take on the risk that they are unable to do so, rather than pass it onto the victims. The same argument applies to Libra, and if fraud becomes common, they will see the same pressures as UK banks.
Today, the Which? consumer rights organisation released the results from its study of how people are excluded from financial services as a result of banks changing their rules to mandate that customers use new technology. The research particularly focuses on banks now requiring that customers register a mobile phone number and be able to receive security codes in SMS messages while doing online banking or shopping. Not only does this change result in digital exclusion – customers without mobile phones or good network coverage will struggle to make payments – but as I discuss in this post, it’s also bad for security.
SMS-based security codes are being introduced to help banks meet their September 2019 deadline to comply with the Strong Customer Authentication requirements of the EU Payment Services Directive 2. These rules state that before making a payment from a customer’s account, the bank must independently verify that the customer really intended to make this payment. UK banks almost universally have decided to meet their obligation by sending a security code in an SMS message to the customer’s mobile phone and asking the customer to type this code into their web browser.
The problem that Which? identified is that some customers don’t have mobile phones, some that do have mobile phones don’t trust their bank with the number, and even those who are willing to share their mobile phone number with the bank might not have network coverage when they need to make a payment. A survey of Which? members found that nearly 1 in 5 said they would struggle to receive the security code they need to perform online banking transactions or online card payments. Remote locations have poorer network coverage than average and it is these areas that are likely to be disproportionately affected by the ongoing bank branch closure programmes.
Outsourcing security
The aspect of this scenario that I’m particularly interested in is why banks chose SMS messages as a security technology in the first place, rather than say sending out dedicated authentication devices to their customers or making a smartphone app. SMS has the advantage that customers don’t need to install an app or have the inconvenience of having to carry around an extra authentication device. The bank also saves the cost of setting up new infrastructure, other than hooking up their payment systems to the phone network. However, SMS has disadvantages – not only does it exclude customers in areas of poor network coverage, but it also effectively outsources security from the bank to the phone networks.
Banking transactions are rapidly moving online, offering convenience to customers and allowing banks to close branches and re-focus on marketing more profitable financial products. At the same time, new payment methods, like the UK’s Faster Payment System, make transactions irrevocable within hours, not days, and so let recipients make use of funds immediately.
However, these changes have also created a new opportunity for fraud schemes that trick victims into performing a transaction under false pretences. For example, a criminal might call a bank customer, tell them that their account has been compromised, and help them to transfer money to a supposedly safe account that is actually under the criminal’s control. Losses in the UK from this type of fraud were £145.4 million during the first half of 2018 but importantly for the public, such frauds fall outside of existing consumer protection rules, leaving the customer liable for sometimes life-changing amounts.
The human cost behind this epidemic has persuaded regulators to do more to protect customers and create incentives for banks to do a better job at preventing the fraud. These measures are coming sooner than UK Finance – the trade association for UK based banking payments and cards businesses – would like, but during questioning by the House of Commons Treasury Committee, their Chief Executive conceded that change is coming. They now focus on who will reimburse customers who have been defrauded through no fault of their own. Who picks up the bill will depend not just on how good fraud prevention measures are, but how effectively banks can demonstrate this fact.
UK Faster Payment Creates an Opportunity for Social Engineering Attacks
One factor that contributed to the new type of fraud is that online interactions lack the usual cues that help customers tell whether a bank is genuine. Criminals use sophisticated social engineering attacks that create a sense of urgency, combined with information gathered about the customer through illicit means, to convince even diligent victims that it could only be their own bank calling. These techniques, combined with the newly irrevocable payment system, create an ideal situation for criminals.
On Friday’s Rip off Britain I’ll be talking about new attempts by UK banks to prevent fraud, and the upcoming scheme for reimbursing the victims. While these developments have the potential to better protect customers, the changes could equally leave customers in a more vulnerable situation than before. What will decide between these two extremes is how well designed will be the rules surrounding these new schemes.
The beginning of this story is September 2016, when the consumer association – Which? – submitted a super-complaint to the UK Payment System Regulator (PSR) regarding push payment fraud – where a customer is tricked into transferring money into a criminal’s account. Such bank transfers are known as push payments because they are initiated by the bank sending the money, as opposed to pull payments, like credit and debit cards, where it is the receiving bank that starts the process. Banks claim that since the customer was involved in the process, they “authorised” the transaction, and so under UK and EU law, the customer is not entitled to a refund. I’ve argued that this interpretation doesn’t match any reasonable definition of the word “authorised” but nevertheless the term “authorised push payment scams” seems to have stuck as the commonly used terminology for this type of fraud, I’m sure much to the banks’ delight.
The Which? super-complaint asked for banks to be held liable for such frauds, and so reimburse the victims unless the bank can demonstrate the customer has acted with gross negligence. Which? argued that this approach would protect the customers from a fraud that exists as a consequence of bank design decisions, and provides banks with both a short-term incentive to prevent frauds that they can stop, as well as a medium-to-long term incentive for the banks to enhance payment systems to be resistant to fraud. The response from the PSR was disappointing, recognising that banks should do more, but rejecting the recommendation to hold banks liable for this fraud and requesting only that the banks collect more data. Nevertheless, the data collected proved useful in understanding the scale of the problem – £236 million stolen from over 42,000 victims in 2017, with banks only being able to recover 26% of the losses. This revelation led to Parliament asking difficult questions of the PSR.
The PSR’s alternative to holding banks liable for push payment fraud is for victims to be reimbursed if they can demonstrate they have acted with an appropriate level of care and that the bank has not. The precise definition of each level of care was a subject of consultation, and will now be decided by a steering group consisting of representatives of the banking industry and consumers. In my response to this consultation, I explained my reasons for recommending that banks be liable for fraud, including that fairly deciding whether customers met a level of care is a process fraught with difficulties. This is particularly the case due to the inequality in power between a bank and its customer, and that taking a banking dispute to court is ruinously expensive for most people since the option of customers spreading the cost through collective actions was removed from the Financial Services Act. More generally, banks – as the designers of payment systems and having real-world understanding of their use – have the greatest capacity to mitigate the risks these systems introduce.
Nevertheless, if the rules for the reimbursement scheme are set up well, it would be a substantial improvement over the current situation. On the other hand, if the process is bad then it could entrench the worst of current practices. Because the PSR has decided that reimbursement should depend on compliance to a level of care, my response also included what should be the process for defining these levels, and for adjudicating disputes.
One common theme at this year’s workshop is that of threat models and incentives, which is covered by the majority of accepted papers. One of these is our (Sarah Azouvi, Alexander Hicks and Steven Murdoch) submission – Incentives in Security Protocols. The aim of the paper is to discuss how incentives can be considered and incorporated in the security of systems. In line with the given theme, the focus is on fail-safe and fail-deadly cases which we look at for the cases of the EMV protocol, consensus in cryptocurrencies, and non-economic systems such as Tor. This post will summarise the main ideas laid out in the paper.
Fail safe, fail deadly and people
Systems can fail, which requires some thought by system designers to account for these failures. From this setting comes the idea behind fail safe protocols which are such that even if the protocol fails, the failure can be dealt with or the protocol can be aborted to limit damage. The idea of a fail deadly setting is an extension of this where failure is defended against through deterrence, as in the case of nuclear deterrence (sometimes a realistic case).
Human input often plays a role in the use of the system, particularly when decisions are required as in fail safe and fail deadly instances. These decisions are then made according to incentives which can aligned to make the system robust to failure. For a fail deadly alignment, this means that a person in position to prevent system failure will be harmed by the failure. In the fail safe case, the innocent parties should be protected from the consequences of system failure. The two concepts are really two sides of the same coin that assigns liability.
It is often said that people are the weakest link in security, but that is an easy excuse for broken protocols. If security incentives are aligned properly, then humans are the strongest link.
The EMV protocol, adding incentives after the fact
As a first example, we consider the case of the EMV protocol, which is used for the majority of smart card payments worldwide, as well as smartphone and card-based contactless payment. Over the years, many vulnerabilities have been identified and removed. Fraud still exists however, due not to unexpected protocol vulnerabilities but to decisions made by banks (e.g., omitting the ability for cards to produce digital signatures), merchants (e.g., omitting PIN verification) and payment networks not sending transactions details back to banks. These are intentional choices, aiming to saves costs and cut transaction times but make fraud harder to detect.
In Tristan and David’s Philosophy, Politics and Economics of Security and Privacy class, Jono gave a little information about incident response. As a result, we have been thinking about the recent furor over fake news. There are some big questions circling this topic, and we’re going to try to focus on a part we have some competence in: what an understanding of fake news as a security incident can contribute to the wider debate. Our goal here is mostly to highlight some lessons from security research that should be applicable, so we can help constrain the solution space. Ultimately, any solution will need to engage with wider civil society.
The lessons we will argue for in the following are:
Solutions need to support the elector’s primary task. Education to avoid cognitive biases is not a short- or medium-term solution.
Focus on aligning the incentives of the media companies and the voters. Reduce the return on investment for the adversary.
Any blocking should be strategically useful, and not merely reactionary.
First, we want a more specific term, as well as a less charged one. Fake news includes politically or financially motivated stories presented as factual reports on the world that are fictional in material ways, and usually are intended to stir strong feelings. This definition is hardly complete. Furthermore, similar to the term “post-truth” as discussed by Jasanoff and Simmet, the term “fake news” makes several value judgement we’d like to avoid. “Fake news” carries a strong suggestion that we, the speakers, know what is true and what isn’t, and it also indicates some condescension by the speaker for anyone who believes an item of fake news. We want to avoid such insults. Instead, let’s say we want to focus on the following hypothetical security policy: democratic elections should be free from foreign interference.
Grounding out this policy definition hangs on the term “interference.” This is hard. Ultimately, the will of an elector in a free and fair election needs to be respected. This makes it particularly challenging to agree on constraints to what information an elector has access to. In practice, no elector is omniscient, so some constraints de facto exist. But weighing in on this issue is outside our competence. Let’s assume for now that public policy will provide an assessment of “interference” eventually. The UK recently announced a “dedicated national security communications unit” would be charged with “combating disinformation by state actors and others.” In France, Emmanuel Macron plans legislation to fight interference from foreign sources during elections. Various social media platforms have likewise announced attempted fixes, which means they have some functional definition of what “interference” they’re seeking to remove. Unfortunately, “none of the tech giants claim to be ready” for the November 2018 elections in the US.
Interference in elections is a type of information warfare. An appropriate security policy needs to assess the threat environment and the capabilities of the adversaries. In particular, the Russian Federation has been assessed as a highly motivated and well-resourced actor in this space. We should note that Russia, in turn, assesses the intent and capability of the USA similarly. Tools and tactics within information warfare, particularly disinformation campaigns, help define “interference” within our security policy.
In this context, what can the security research community recommend? Well, the main target of the disinformation campaign are usual citizens. They are targetable largely due to inherent cognitive biases in the way humans process and reason about information. In security terms, we could see these biases as vulnerabilities in the system. Classically, we have two options to secure the system: patch the vulnerability, or prevent the adversary from exploiting it by controlling or filtering the attack before it reaches the target.
Patch in this case would mean teaching people to avoid cognitive biases in their day-to-day reasoning. Psychology tells us this is hard. Intelligence analysts train for months or years for this. And the research in usable security has affirmed time and time again that the users are not the enemy. That is, the system must alleviate the burden on the user’s attention and not interfere with their primary task, or else the user will subvert or avoid the protections put in place. Any changes in user culture are slow. This leads us to lesson 1 on preventing disinformation campaigns for election interference: solutions need to support the elector’s primary task. Education to avoid cognitive biases is not a short-term or medium-term solution.
Controlling the attack vectors is more promising, although filtering them is not. A key aspect of any information security policy is aligning the economic incentives of the actors. Economics is a main reason why infosec is hard. It may not be easy to reorganize the incentives in the advertising and news distribution media space. However, as long as organizations profit from more clicks on an article no matter the content, there will be an incentive to drive viewers that is ultimately at cross-purposes with our security goal. Such misaligned incentives often swamp any technical security solutions. And any adversary with an economic incentive to attack usually will. Thus our second lesson: focus on aligning the incentives of the media companies and the voters; reduce the return on investment for the adversary. Exactly how to do these things will require future work.
There are huge issues about human rights and free speech for blocking access to information. However, the technical aspects of blacklisting are worth understanding before even attempting such human-rights debates. Blacklists of internet resources, such as domain names, IP addresses, or web pages, are useful. But they’re not a final solution. Whether blacklists move at the speed of national legislatures or are updated every five minutes, their main impact is to cause the adversary to move around. Blacklists alone are not enough. We would need to look for suspiciously mobile resources (i.e. fast-flux), and eventually whitelist resources. Blacklists such as implemented by Facebook in response to Congress are helpful. But we should carefully consider how they drive the disinformation campaigns into a place we are better able to counteract them, and be sure we don’t make such campaigns harder to find instead. Lesson 3 is therefore that any blocking should be strategically useful, and not merely reactionary.
We’d be happy for further comments on fake news, disinformation campaigns that interfere with elections, lessons we’ve missed, disagreements about the value of security research to this topic, and other comments you might have! This is a wide open topic, and we’re still sounding it all out.
This morning, BBC Rip Off Britain focused on push payment fraud, featuring an interview with me (starts at 34:20). The distinction between push and pull payments should be a matter for payment system geeks, and certainly isn’t at the front of customers’ minds when they make a payment. However, there’s a big difference when there’s fraud – for online pull payments (credit and debit card) the bank will give the victim the money back in many situations; for online push payments (Faster Payment System and Standing Orders) the full liability falls on the party least able to protect themselves – the customer.
The banking industry doesn’t keep good statistics about push payment fraud, but it appears to be increasing, with Which receiving reports from over 650 victims in the first two weeks of November 2016, with losses totalling over £5.5 million. Today’s programme puts a human face to these statistics, by presenting the case of Jane and Steven Caldwell who were defrauded of over £100,000 from their Nationwide and NatWest accounts.
They were called up at the weekend by someone who said he was working for NatWest. To verify that this was the case, Jane used three methods. Firstly, she checked caller-ID to confirm that the number was indeed the bank’s own customer helpline – it was. Secondly, she confirmed that the caller had access to Jane’s transaction history – he did. Thirdly, she called the bank’s customer helpline, and the caller knew this was happening despite the original call being muted.
Convinced by these checks, Jane transferred funds from her own accounts to another in her own name, having been told by the caller that this was necessary to protect against fraud. Unfortunately, the caller was a scammer. Experts featured on the programme suspect that caller-ID was spoofed (quite easy, due to lack of end-to-end security for phone calls), and that malware on Jane’s laptop allowed the scammer to see transaction history on her screen, as well as to listen to and see her call to the genuine customer helpline through the computer’s microphone and webcam. The bank didn’t check that the name Jane gave (her own) matched that of the recipient account, so the scammer had full access to the transferred funds, which he quickly moved to other accounts. Only Nationwide was able to recover any money – £24,000 – leaving Jane and Steven over £75,000 out of pocket.
Neither bank offered Jane and Steven a refund, because they classed the transaction as “authorised” and so falling into one of the exceptions to the EU Payment Services Directive requirement to refund victims of fraud (the other exception being if the bank believed the customer acted either with gross negligence or fraudulently). The banks argued that their records showed that the customer’s authentication device was used and hence the transaction was “authorised”. In the original draft of the Payment Services Directive this argument would not be sufficient, but as a result of concerted lobbying by Barclays and other UK banks for their records to be considered conclusive, the word “necessarily” was inserted into Article 72, and so removing this important consumer protection.
“Where a payment service user denies having authorised an executed payment transaction, the use of a payment instrument recorded by the payment service provider, including the payment initiation service provider as appropriate, shall in itself not necessarily be sufficient to prove either that the payment transaction was authorised by the payer or that the payer acted fraudulently or failed with intent or gross negligence to fulfil one or more of the obligations under Article 69.”
Clearly the fraudulent transactions do not meet any reasonable definition of “authorised” because Jane did not give her permission for funds to be transferred to the scammer. She carried out the transfer because the way that banks commonly authenticate themselves to customers they call (proving that they know your account details) was unreliable, because the recipient bank didn’t check the account name, because bank fraud-detection mechanisms didn’t catch the suspicious nature of the transactions, and because the bank’s authentication device is too confusing to use safely. When the security of the payment system is fully under control of the banks, why is the customer held liable when a person acting with reasonable care could easily do the same as Jane?
Another question is whether banks do enough to recover funds lost through scams such as this. The programme featured an interview with barrister Gideon Roseman who quickly obtained court orders allowing him to recover most of his funds lost through a similar scam. Interestingly a side-effect of the court orders was that he discovered that his bank, Barclays, waited more than 24 hours after learning about the fraud before they acted to stop the stolen money being transferred out. After being caught out, Barclays refunded Gideon the affected funds, but in cases where the victim isn’t a barrister specialising in exactly these sorts of disputes, do the banks do all they could to recover stolen money?
In order to give banks proper incentives to prevent push payment fraud where possible and to recover stolen funds in the remainder of cases, Which called for the Payment Systems Regulator to make banks liable for push payment fraud, just as they are for pull payments. I agree, and expect that if this were the case banks would implement innovative fraud prevention mechanisms against push payment fraud that we currently only see for credit and debit transactions. I also argued that in implementing the revised Payment Service Directive, the European Banking Authority should require banks provide evidence that a customer was aware of the nature of the transaction and gave informed consent before they can hold the customer liable. Unfortunately, both the Payment Systems Regulator, and the European Banking Authority conceded to the banking industry’s request to maintain the current poor state of consumer protection.
The programme concluded with security advice, as usual. Some was actively misleading, such as the claim by NatWest that banks will never ask customers to transfer money between their accounts for security reasons. My bank called me to transfer money from my current account to savings account, for precisely this reason (I called them back to confirm it really was them). Some advice was vague and not actionable (e.g. “be vigilant” – in response to a case where the victim was extremely cautious and still got caught out). Probably the most helpful recommendation is that if a bank supposedly calls you, wait 5 minutes and call them back using the number on a printed statement or card, preferably from a different phone. Alternatively stick to using cheques – they are slow and banks discourage their use (because they are expensive for them to process), but are much safer for the customer. However, such advice should not be considered an alternative to pushing liability back where it belongs – the banks – which will not only reduce fraud but also protect vulnerable customers.
This week, the Wall Street Journal published an article by Robert McMillan containing an apology from Bill Burr, a man whose name is unknown to most but whose work has caused daily frustration and wasted time for probably hundreds of millions of people for nearly 15 years. Burr is the author of the 2003 Special Publication 800-63. Appendix A from the US National Institute of Standards and Technology: eight pages that advised security administrators to require complex passwords including special characters, capital letters, and numbers, and dictate that they should be frequently changed.
“Much of what I did I now regret,” Burr told the Journal. In June, when NIST issued a completely rewritten document, it largely followed the same lines as the NCSCs password guidance, published in 2015 and based on prior research and collaboration with the UK Research Institute in Science of Cyber Security (RISCS), led from UCL by Professor Angela Sasse. Yet even in 2003 there was evidence that Burr’s approach was the wrong one: in 1999, Sasse did the first work pointing out the user-unfriendliness of standard password policies in the paper Users Are Not the Enemy, written with Anne Adams.
How much did that error cost in lost productivity and user frustration? Why did it take the security industry and research community 15 years to listen to users and admit that the password policies they were pushing were not only wrong but actively harmful, inflicting pain on millions of users and costing organisations huge sums in lost productivity and administration? How many other badly designed security measures are still out there, the cyber equivalent of traffic congestion and causing the same scale of damage?
For decades, every password breach has led to the same response, which Einstein would readily have recognised as insanity: ridiculing users for using weak passwords, creating policies that were even more difficult to follow, and calling users “stupid” for devising coping strategies to manage the burden. As Sasse, Brostoff, and Weirich wrote in 2001 in their paper Transforming the ‘Weakest Link’, “…simply blaming users will not lead to more effective security systems”. In his 2009 paper So Long, and No Thanks for the Externalities, Cormac Herley (Microsoft Research) pointed out that it’s often quite rational for users to reject security advice that ignores the indirect costs of the effort required to implement it: “It makes little sense to burden all users with a daily task to spare 0.01% of them a modest annual pain,” he wrote.
When GCHQ introduced the new password guidance, NCSC head Ciaran Martin noted the cognitive impossibility of following older policies, which he compared to trying to memorise a new 600-digit number every month. Part of the basis for Martin’s comments is found in more of Herley’s research. In Password Portfolios and the Finite-Effort User, Herley, Dinei Florencio, and Paul C. van Oorschot found that the cognitive load of managing 100 passwords while following the standard advice to use a unique random string for every password is equivalent to memorising 1,361 places of pi or the ordering of 17 packs of cards – a cognitive impossibility. “No one does this”, Herley said in presenting his research at a RISCS meeting in 2014.
The first of the three questions we started with may be the easiest to answer. Sasse’s research has found that in numerous organisations each staff member may spend as much as 30 minutes a day on entering, creating, and recovering passwords, all of it lost productivity. The US company Imprivata claims its system can save clinicians up to 45 minutes per day just in authentication; in that use case, the wasted time represents not just lost profit but potentially lost lives.
Add the cost of disruption. In a 2014 NIST diary study, Sasse, with Michelle Steves, Dana Chisnell, Kat Krol, Mary Theofanos, and Hannah Wald, found that up to 40% of the time leading up to the “friction point” – that is, the interruption for authentication – is spent redoing the primary task before users can find their place and resume work. The study’s participants recorded on average 23 authentication events over the 24-hour period covered by the study, and in interviews they indicated their frustration with the number, frequency, and cognitive load of these tasks, which the study’s authors dubbed “authentication fatigue”. Dana Chisnell has summarised this study in a video clip.
The NIST study identified a more subtle, hidden opportunity cost of this disruption: staff reorganise their primary tasks to minimise exposure to authentication, typically by batching the tasks that require it. This is a similar strategy to deciding to confine dealing with phone calls to certain times of day, and it has similar consequences. While it optimises that particular staff member’s time, it delays any dependent business process that is designed in the expectation of a continuous flow from primary tasks. Batching delays result not only in extra costs, but may lose customers, since slow responses may cause them to go elsewhere. In addition, staff reported not pursuing ideas for improvement or innovation because they couldn’t face the necessary discussions with security staff.
Unworkable security induces staff to circumvent it and make errors – which in turn lead to breaches, which have their own financial and reputational costs. Less obvious is the cost of lost staff goodwill for organisations that rely on free overtime – such as US government departments and agencies. The NIST study showed that this goodwill is dropping: staff log in less frequently from home, and some had even returned their agency-approved laptops and were refusing to log in from home or while travelling.
It could all have been so different as the web grew up over the last 20 years or so, because the problems and costs of password policies are not new or newly discovered. Sasse’s original 1999 research study was not requested by security administrators but by BT’s accountants, who balked when the help desk costs of password problems were tripling every year with no end in sight. Yet security people have continued to insist that users must adapt to their requirements instead of the other way around, even when the basis for their ideas is shown to be long out of date. For example, in a 2006 blog posting Purdue University professor Gene Spafford explained that the “best practice” (which he calls “infosec folk wisdom”) of regular password changes came from non-networked military mainframes in the 1970s – a far cry from today’s conditions.
Herley lists numerous other security technologies that are as much of a plague as old-style password practices: certificate error warnings, all of which are false positives; security warnings generally; and ambiguous and non-actionable advice, such as advising users not to click on “suspicious” links or attachments or “never” reusing passwords across accounts.
All of these are either not actionable, or just too difficult to put into practice, and the struggle to eliminate them has yet to bear fruit. Must this same story continue for another 20 years?
