Archive for the ‘BBFC Internet Censor’ Category

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dogital policy alliance logo The AV industry is not yet ready The Digital Policy Alliance (DPA) is a private lobby group connecting digital industries with Parliament. Its industry members include both Age Verification (AV) providers, eg OCL, and adult entertainment, eg Portland TV.

Just before the Government announcement that the commencement of adult verification requirements for porn websites would be delayed, the DPA wrote a letter explaining that the industry was not yet ready to implement AV, and had asked for a 3 month delay.

The letter is unpublished but fragments of it have been reported in news reports about AV.

The Telegraph reported:

The Digital Policy Alliance called for the scheme to be delayed or risk nefarious companies using this opportunity to harvest and manipulate user data.

The strongly-worded document complains that the timing is very tight, a fact that has put some AVPs [age verification providers] and adult entertainment providers in a very difficult situation.

It warns that unless the scheme is delayed there will be less protection for public data, as it appears that there is an intention for uncertified providers to use this opportunity to harvest and manipulate user data.

The AV industry is  unimpressed by a 6 month delay

See article from news.sky.com

Rowland Manthorpe from Sky News contributed a few interesting snippets too. He noted that the AVPs were unsurprisingly not pleased by the government delay:

Serge Acker, chief executive of OCL, which provides privacy-protecting porn passes for purchase at newsagents, told Sky News: As a business, we have been gearing up to get our solution ready for July 15th and we, alongside many other businesses, could potentially now be being endangered if the government continues with its attitude towards these delays.

Not only does it make the government look foolish, but it’s starting to make companies like ours look it too, as we all wait expectantly for plans that are only being kicked further down the road.

There are still issues with how the AV providers can make money

And interestingly Manthorpe revealed in the accompanying video news report that the AV providers were also distinctly unimpressed by the BBFC stipulating that certified AV providers must not use Identity Data provided by porn users for any other purpose than verifying age. The sensible idea being that the data should not be made available for the the likes of targeted advertising. And one particular example of prohibited data re-use has caused particular problems, namely that ID data should not be used to sign people up for digital wallets.

Now AV providers have got to be able to generate their revenue somehow. Some have proposed selling AV cards in newsagents for about £10, but others had been planning on using AV to generate a customer base for their digital wallet schemes.

So it seems that there are still quite a few fundamental issues that have not yet been resolved in how the AV providers get their cut.
Some AV providers would rather not sign up to BBFC accreditation

See article from adultwebmasters.org

Maybe these issues with BBFC AV accreditation requirements are behind a move to use an alternative standard. An AV provider called VeriMe has announced that it has the first AV company to receive a PAS1296 certification.

The PAS1296 was developed between the British Standards Institution and the Age Check Certification Scheme (ACCS). It stands for Public Accessible Specification and is designed to define good practice standards for a product, service or process. The standard was also championed by the Digital Policy Alliance.

Rudd Apsey, the director of VeriMe said:

The PAS1296 certification augments the voluntary standards outlined by the BBFC, which don’t address how third-party websites handle consumer data, Apsey added. We believe it fills those gaps and is confirmation that VeriMe is indeed leading the world in the development and implementation of age verification technology and setting best practice standards for the industry.

We are incredibly proud to be the first company to receive the standard and want consumers and service providers to know that come the July 15 roll out date, they can trust VeriMe’s systems to provide the most robust solution for age verification.

This is not a very convincing argument as PAS1296 is not available for customers to read, (unless they pay about 120 quid for the privilege). At least the BBFC standard can be read by anyone for free, and they can then make up their own minds as to whether their porn browsing history and ID data is safe.

However it does seem that some companies at least are planning to give the BBFC accreditation scheme a miss.
The BBFC standard fails to provide safety for porn users data anyway.

See article from medium.com

The AV company 18+ takes issue with the BBFC accreditation standard, noting that it allows AV providers to dangerously log people’s porn browsing history:

Here’s the problem with the design of most age verification systems: when a UK user visits an adult website, most solutions will present the user with an inline frame displaying the age verifier’s website or the user will be redirected to the age verifier’s website. Once on the age verifier’s website, the user will enter his or her credentials. In most cases, the user must create an account with the age verifier, and on subsequent visits to the adult website, the user will enter his account details on the age verifier’s website (i.e., username and password). At this point in the process, the age verifier will validate the user and, if the age verifier has a record the user being at least age 18, will redirect the user back to the adult website. The age verification system will transmit to the adult website whether the user is at least age 18 but will not transmit the identity of the user.

The flaw with this design from a user privacy perspective is obvious: the age verification website will know the websites the user visits. In fact, the age verification provider obtains quite a nice log of the digital habits of each user. To be fair, most age verifiers claim they will delete this data. However, a truly privacy first design would ensure the data never gets generated in the first place because logs can inadvertently be kept, hacked, leaked, or policies might change in the future. We viewed this risk to be unacceptable, so we set about building a better system.

Almost all age verification solutions set to roll out in July 2019 do not provide two-way anonymity for both the age verifier and the adult website, meaning, there remains some log of?204?or potential to log — which adult websites a UK based user visits.

In fact one AV provider revealed that up until recently the government demanded that AV providers keep a log of people’s porn browsing history and it was a bit of a late concession to practicality that companies were able to opt out if they wanted.

Note that the logging capability is kindly hidden by the BBFC by passing it off as being used for only as long as is necessary for fraud prevention. Of course that is just smoke and mirrors, fraud, presumably meaning that passcodes could be given or sold to others, could happen anytime that an age verification scheme is in use, and the time restriction specified by the BBFC may as well be forever.

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av security standard analysis 2 Executive Summary

The BBFC’s Age-verification Certificate Standard (“the Standard”) for providers of age verification services, published in April 2019, fails to meet adequate standards of cyber security and data protection and is of little use for consumers reliant on these providers to access adult content online.

This document analyses the Standard and certification scheme and makes recommendations for improvement and remediation. It sub-divides generally into two types of concern: operational issues (the need for a statutory basis, problems caused by the short implementation time and the lack of value the scheme provides to consumers), and substantive issues (seven problems with the content as presently drafted).

The fact that the scheme is voluntary leaves the BBFC powerless to fine or otherwise discipline providers that fail to protect people’s data, and makes it tricky for consumers to distinguish between trustworthy and untrustworthy providers. In our view, the government must legislate without delay to place a statutory requirement on the BBFC to implement a mandatory certification scheme and to grant the BBFC powers to require reports and penalise non-compliant providers.

The Standard’s existence shows that the BBFC considers robust protection of age verification data to be of critical importance. However, in both substance and operation the Standard fails to deliver this protection. The scheme allows commercial age verification providers to write their own privacy and security frameworks, reducing the BBFC’s role to checking whether commercial entities follow their own rules rather than requiring them to work to a mandated set of common standards. The result is uncertainty for Internet users, who are inconsistently protected and have no way to tell which companies they can trust.

Even within its voluntary approach, the BBFC gives providers little guidance to providers as to what their privacy and security frameworks should contain. Guidance on security, encryption, pseudonymisation, and data retention is vague and imprecise, and often refers to generic “industry standards” without explanation. The supplementary Programme Guide, to which the Standard refers readers, remains unpublished, critically undermining the scheme’s transparency and accountability.

Recommendations

  • Grant the BBFC statutory powers:

  • The BBFC Standard should be substantively revised to set out comprehensive and concrete standards for handling highly sensitive age verification data.

  • The government should legislate to grant the BBFC statutory power to mandate compliance.

  • The government should enable the BBFC to require remedial action or apply financial penalties for non-compliance.

  • The BBFC should be given statutory powers to require annual compliance reports from providers and fine those who sign up to the certification scheme but later violate its requirements.

  • The Information Commissioner should oversee the BBFC’s age verification certification scheme

Delay implementation and enforcement:

Delay implementation and enforcement of age verification until both (a) a statutory standard of data privacy and security is in place, and (b) that standard has been implemented by providers.

Improve the scheme content:

Even if the BBFC certification scheme remains voluntary, the Standard should at least contain a definitive set of precisely delineated objectives that age verification providers must meet in order to say that they process identity data securely.

Improve communication with the public:

Where a provider’s certification is revoked, the BBFC should issue press releases and ensure consumers are individually notified at login.

The results of all penetration tests should be provided to the BBFC, which must publish details of the framework it uses to evaluate test results, and publish annual trends in results.

Strengthen data protection requirements:

Data minimisation should be an enforceable statutory requirement for all registered age verification providers.

The Standard should outline specific and very limited circumstances under which it’s acceptable to retain logs for fraud prevention purposes. It should also specify a hard limit on the length of time logs may be kept.

The Standard should set out a clear, strict and enforceable set of policies to describe exactly how providers should “pseudonymise” or “deidentify” data.

Providers that no longer meet the Standard should be required to provide the BBFC with evidence that they have destroyed all the user data they collected while supposedly compliant.

The BBFC should prepare a standardised data protection risk assessment framework against which all age verification providers will test their systems. Providers should limit bespoke risk assessments to their specific technological implementation.

Strengthen security, testing, and encryption requirements:

Providers should be required to undertake regular internal and external vulnerability scanning and a penetration test at least every six months, followed by a supervised remediation programme to correct any discovered vulnerabilities.

Providers should be required to conduct penetration tests after any significant application or infrastructure change.

Providers should be required to use a comprehensive and specific testing standard. CBEST or GBEST could serve as guides for the BBFC to develop an industry-specific framework.

The BBFC should build on already-established strong security frameworks, such as the Center for Internet Security Cyber Controls and Resources, the NIST Cyber Security Framework, or Cyber Essentials Plus.

At a bare minimum, the Standard should specify a list of cryptographic protocols which are not adequate for certification.

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bbfc age verification standard Starting with a little background into the authorship of the document under review. AVSecure CMO Steve Winyard told XBIZ:

The accreditation plan appears to have very strict rules and was crafted with significant input from various governmental bodies, including the DCMS (Department for Culture, Media & Sport), NCC Group plc (an expert security and audit firm), GCHQ (U.K. Intelligence and Security Agency), ICO (Information Commissioner’s Office) and of course the BBFC.

But computer security expert Alec Muffett writes:

This is the document which is being proffered to protect the facts & details of _YOUR_ online #Porn viewing. Let’s read it together!

What could possibly go wrong?

….

This document’s approach to data protection is fundamentally flawed.

The (considerably) safer approach – one easier to certificate/validate/police – would be to say everything is forbidden except for upon for ; you would then allow vendors to appeal for exceptions under review.

It makes a few passes at pretending that this is what it’s doing, but with subjective holes (green) that you can drive a truck through:

Data unprotected in the name of fraud detection

What we have here is a rehash of quite a lot of reasonable physical/operational security, business continuity & personnel security management thinking — with digital stuff almost entirely punted.

It’s better than #PAS1296 , but it’s still not fit for purpose.

Read the full thread

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VPNCompare is reporting that internet users in Britain are responding to the upcoming porn censorship regime by investigating the option to get a VPN so as to workaround most age verification requirements without handing over dangerous identity details.VPNCompare says that the number of UK visitors to its website has increased by 55% since the start date of the censorship scheme was announced. The website also sated that Google searches for VPNs had trippled. Website editor, Christopher Seward told the Independent:

We saw a 55 per cent increase in UK visitors alone compared to the same period the previous day. As the start date for the new regime draws closer, we can expect this number to rise even further and the number of VPN users in the UK is likely to go through the roof.

The UK Government has completely failed to consider the fact that VPNs can be easily used to get around blocks such as these.

Whilst the immediate assumption is that porn viewers will reach for a VPN to avoid handing over dangerous identity information, there may be another reason to take out a VPN, a lack of choice of appropriate options for age validation.

3 companies run the 6 biggest adult websites. Mindgeek owns Pornhub, RedTube and Youporn. Then there is Xhamster and finally Xvideos and xnxx are connected.

Now Mindgeek has announced that it will partner with Portes Card for age verification, which has options for identity verification, giving a age verified mobile phone number, or else buying  a voucher in a shop and showing age ID to the shop keeper (which is hopefully not copied or recorded).

Meanwhile Xhamster has announced that it is partnering with 1Account which accepts a verified mobile phone, credit card, debit card, or UK drivers licence. It does not seem to have an option for anonymous verification beyond a phone being age verified without having to show ID.

Perhaps most interestingly is that both of these age verifiers are smart phone based apps. Perhaps the only option for people without a phone is to get a VPN. I also spotted that most age verification providers that I have looked at seem to be only interested in UK cards, drivers licences or passports. I’d have thought there may be legal issues in not accepting EU equivalents. But foreigners may also be in the situation of not being able to age verify and so need a VPN.

And of course the very fact that is no age verification option common to the major porn website then it may just turn out to be an awful lot simpler just to get a VPN.

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is it safe The Interrogator :

Is it safe?

The BBFC (on its Age Verification website)…err…no!…:

An assessment and accreditation under the AVC is not a guarantee that the age-verification provider and its solution (including its third party companies) comply with the relevant legislation and standards, or that all data is safe from malicious or criminal interference.

Accordingly the BBFC shall not be responsible for any losses, damages, liabilities or claims of whatever nature, direct or indirect, suffered by any age-verification provider, pornography services or consumers/ users of age-verification provider’s services or pornography services or any other person as a result of their reliance on the fact that an age-verification provider has been assessed under the scheme and has obtained an Age-verification Certificate or otherwise in connection with the scheme.

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open rights group 2016 logo We met to discuss BBFC’s voluntary age verification privacy scheme, but BBFC did not attend. Open Rights Group met a number of age verification providers to discuss the privacy standards that they will be meeting when the scheme launches, slated for April. Up to 20 million UK adults are expected to sign up to these products.

We invited all the AV providers we know about, and most importantly, the BBFC, at the start of February. BBFC are about to launch a voluntary privacy standard which some of the providers will sign up to. Unfortunately, BBFC have not committed to any public consultation about the scheme, relying instead on a commercial provider to draft the contents with providers, but without wider feedback from privacy experts and people who are concerned about users.

We held the offices close to the BBFC’s offices in order that it would be convenient for them to send someone that might be able to discuss this with us. We have been asking for meetings with BBFC about the privacy issues in the new code since October 2018: but have not received any reply or acknowledgement of our requests, until this morning, when BBFC said they would be unable to attend today’s roundtable. This is very disappointing.

BBFC’s failure to consult the public about this standard, or even to meet us to discuss our concerns, is alarming. We can understand that BBFC is cautious and does not wish to overstep its relationship with its new masters at DCMS. BBFC may be worried about ORG’s attitude towards the scheme: and we certainly are critical. However, it is not responsible for a regulator to fail to talk to its potential critics.

We are very clear about our objectives. We are acting to do our best to ensure the risk to adult users of age verification technologies are minimised. We do not pose a threat to the scheme as a whole: listening to us can only result in making the pornographic age verification scheme more likely to succeed, and for instance, to avoid catastrophic failures.

Privacy concerns appear to have been recognised by BBFC and DCMS as a result of consultation responses from ORG supporters and others, which resulted in the voluntary privacy standard. These concerns have also been highlighted by Parliament, whose regulatory committee expressed surprise that the Digital Economy Act 2017 had contained no provision to deal with the privacy implications of pornographic age verification.

Today’s meeting was held to discuss:

  • What the scheme is likely to cover; and what it ideally should cover;

  • Whether there is any prospect of making the scheme compulsory;

  • What should be done about non-compliant services;

  • What the governance of the scheme should be in the long tern, for instance whether it might be suitable to become an ICO backed code, or complement such as code

As we communicated to BBFC in December 2018, we have considerable worries about the lack of consultation over the standard they are writing, which appears to be truncated in order to meet the artificial deadline of April this year. This is what we explained to BBFC in our email:

  • Security requires as many perspectives to be considered as possible.

  • The best security standards eg PCI DSS are developed in the open and iterated

  • The standards will be best if those with most to lose are involved in the design.

    • For PCI DSS, the banks and their customers have more to lose than the processors

    • For Age Verification, site users have more to lose than the processors, however only the processors seem likely to be involved in setting the standard

We look forward to BBFC agreeing to meet us to discuss the outcome of the roundtable we held about their scheme, and to discuss our concerns about the new voluntary privacy standard. Meanwhile, we will produce a note from the meeting, which we believe was useful. It covered the concerns above, and issues around timing, as well as strategies for getting government to adjust their view of the absence of compulsory standards, which many of the providers want. In this, BBFC are a critical actor. ORG also intends as a result of the meeting to start to produce a note explaining what an effective privacy scheme would cover, in terms of scope, risks to mitigate, governance and enforcement for participants.

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internet matters logo InternetMatters.org is group funded by UK internet and telecoms companies with the aim of promoting their role in internet safety.The group has now published a survey supporting the government’s upcoming introduction of age verification requirements for porn websites. The results reveal:

  • 83% feel that commercial porn sites should demand users verify their age before they’re able to access content.
  • 76% of UK parents feel there should be greater restrictions online to stop kids seeing adult content.
  • 69% of parents of children aged four to 16 say they’re confident the government’s new ID restrictions will make a difference.

However 17% disagreed with commercial porn sites requiring ID from their users. And the use of data was the biggest obstacle for those parents opposed to the plans. Of those parents who are anti-age verification, 30% said they wouldn’t trust age-verification companies with their personal data.

While 18% of parents claim they expect kids would find a way to get around age-verification and a further 13% claim they’re unsure that it would actually reduce the number of children accessing pornography. Age-verification supported by experts