Foundation for Information Policy Research
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The Foundation for Information Policy Research is an independent non-profit organisation that studies the interaction between information technology and society, with special reference to the Internet, from a broad public policy perspective; we do not represent the interests of any trade group. Our goal is to identify technical developments with significant social impact, commission research into public policy alternatives, and promote public understanding and dialogue between technologists and policy-makers in the UK and Europe.
We welcome the government's initiative in producing draft guidance on the use of smartcards in the public sector. The CCTA document may be a useful move towards weaning the public sector away from its often uncritical acceptance of the claims made by the smartcard industry. The recognition that smartcard security is not infallible, and the attention paid to management issues in section 2.2, are a most welcome first step towards sanity, and deserve greater emphasis.
However, the document continues to make an assumption which is not merely highly suspect but which the industry itself started to abandon some time ago, namely that the main benefit to be expected from smartcards will be a reduction in the number of identity and authorisation tokens which people carry, as a result of integrating multiple functions on a single card.
Following great enthusiasm for multifunction smartcards in the early 1990's, persons with experience of the industry now reckon that the only type of system in which multiple applications on one card have a serious future is where smartcards are used in consumer devices such as mobile phones and pay-TV set-top boxes, where there is only slot space for one card and the system operator's card must be there for the system to work at all. On such platforms, a bank (for example) wishing to offer its services in a way that leverages off the authentication functions in the card, has little choice but to rent card space from the operator.
However, multifunction cards have some critical vulnerabilities. Anyone who wants to provide services via the card is forced to delegate control of access to their information to the card designer or issuer. In addition, multifunction cards deprive the user of a fundamental control against abuse: the ability to decide which card she puts into which reader. These vulnerabilities lead to many complex issues of security, control and liability which we explore below.
Another source of confusion is to describe a card as multi-function when it is not; it may have the single function of saying what your name is, and perhaps your address, this name being used for many purposes which are not recorded in any way on the card itself. A good example is the California non-driving driver's license which is used solely to encourage people to believe a claimed name. Such cards can be useful although their introduction in the UK would be politically fraught: a number of attempts to introduce ID cards in English speaking countries have foundered on extreme public hostility.
Indeed, we suspect that much of the impetus behind the present document is the wish in some quarters in Whitehall to introduce an ID card - but have some third party (such as the banking industry) bear the cost and the political opprobrium. For reasons set out below, this is unlikely to be a good idea.
Government departments should not repeat the usual mistake that civil servants make with computer systems, of trying to kill two birds with one stone. This is a well-trodden road to systems that do not work well or at all, and end up costing a multiple of the original budget. It is far better to set departmental operational needs directly in the light of public opinion and other political and budgetary constraints, and contract for the construction of systems that meet them using tried and tested technology.
FIPR therefore strongly recommends that CCTA advice should:
The report's mission is set out in 1.4:
Government regards the deployment of multi-function smart cards as a key enabler to the development of electronic commerce and recognises that government applications can act as a key driver towards 'critical mass'.
The bias is implicit elsewhere in the text such as at 2, `Acquisition Issues':
Where a requirement for a smart card has been identified, there are in effect three acquisition options:
- make use of an existing or planned card scheme, without adding an application or data;
- 'rent space' on an existing card;
- issue cards oneself, and where possible offset the cost by making space or use available to others.
This prejudges the whole case for and against multifunction cards by making their use an underlying assumption of purchasing policy. This is most unwise, and for at least two reasons.
Firstly, the appropriate technology in many applications will not be the smartcard, or other specific user token, but the digital signature; how the user controls access to the digital signing apparatus is their problem. It has been argued by other government agencies that digital signatures will be the key enabler in electronic commerce; if this turns out to be the case then the details of whether the signing mechanism is implemented on a smartcard or a PDA or in general purpose software may turn out to be a peripheral irrelevance. Digital signatures may be most important on business to government and government to government transactions; the interaction is between organisations rather than between a government department and a specific cardholder. Yet in section 1.4 we read:
Government recognises that smart cards have an important role to play in many government-government and government-business transactions.
Secondly, the advocacy of multiple applications - which comes at a time when the industry is recovering from a costly and ineffective attachment to the idea - threatens to undermine good practice in the design and acquisition of systems.
For example, in 1.5 we see:
Multiple applications. Smart cards may carry multiple applications which may, in principle, be added or removed during the card's lifecycle. This can considerably aid the business case for the introduction of card technology, since a single card can be used for multiple functions by multiple organisations.
In other words, weak business cases may be bolstered by claims of possible synergy with other applications that have similarly weak cases and which may never even come into existence. This repeats a mistake commonly made in the 1960's and 1970's, when weak cases for computerisation of particular administrative functions were justified by saying `once we have a departmental mainframe we can computerise all sorts of other stuff'. This argument led to enough wasteful projects; but the current argument for multifunction smartcards is even flakier. Its analogy in 1960's terms would be: `OK, we can't justify computerising this system, but once we have a mainframe we can rent out time on it, or so we hear, so let's just go ahead anyway'.
Casting the analogy in these terms should make the problem clearer. Many government departments would not dream of selling time-sharing services on their mainframes, for perfectly valid security reasons. Why should they sell space on their smartcards? And even if a project can only be justified by cost-sharing with the private sector, a clear business plan - with realistic marketing targets and revenue models - should be an absolute requirement.
Smartcards, like videoconferencing and wearable computers, have for at least a generation been marketed as the `coming revolution'. Their advocates constantly assure us that the exponential take-off in sales is just around the corner, and that generous government funding - in all forms from research grants to preferential purchasing - is the magic catalyst required to open up a cornucopia of technological, political, social and economic delights.
In fact, smartcard technology is so old that the fundamental patents of Moreno and others have now long since expired.
Smartcards have carved out some interesting and valuable niches, most notably in the subscriber identity module (SIM) cards used to personalise GSM digital mobile phones, and in the subscriber cards similarly used to control subscription to pay-per-view TV set-top boxes. Simple memory cards are used in pay phones, and smartcard chips repackaged as physical keys are used in prepayment electricity meters.
However, over the quarter century in which the smartcard has been the subject of intense marketing activity, it has signally failed to gain global acceptance in many markets for which an engineer might think it suited - such as including car and burglar alarms, building access control, transport ticketing, automatic teller machines and computer logon. It has had mixed success in a number of standalone applications ranging from store loyalty cards through membership cards for leisure activities to internal corporate applications such as catering and the control of photocopiers. A prudent civil servant will ask why this technology keeps falling short of its advertised potential.
In one country where the government has subsidised the smartcard deeply and pushed it vigorously - France - it has achieved slightly higher penetration. For example, all ATMs and point-of-sale devices accept smartcards. But the commercial benefits have been questionable as magnetic stripe cards must still be supported to cater for overseas tourists, and the hoped for reduction in fraud has been disappointing. Spain achieved a better result by the simpler strategy of imposing a zero floor limit, so absolutely all credit card transactions must be verified online. (Indeed, as `always-on' DSL Internet connections become the norm and as new-generation mobile networks come on stream, the benefits of offline authentication will disappear in many sectors and for many applications.)
Yet for about the last twelve years, the smartcard industry has kept on pushing the line that `multifunction' or `multiapplication' smartcards are the future. Rather than having twenty cards in his pocket - bank cards, store cards, work ID cards, photocopier cards, an AA card, a phone card, ... the citizen will have one card on which all these applications can be loaded.
It is extraordinary that such a sustained marketing effort should have been made, firstly in the absence of any notable success and secondly as one would expect it to be in the card industry's interests for each citizen to have twenty cards in their pocket rather than two. But at the technical end it has been used as a justification for developing ever faster, more complex and more expensive smartcard chips while the marketing people have been following the argument found in the CCTA report - namely that even if you cannot make a business case for adopting smartcards, you can always hope to make the sale by pointing to a future revenue stream from `renting space' on the card to the next victim.
In the experience of the industry, there are many good reasons why these supposed gains will turn out to be illusory. Some of these are highlighted by implication in section 2.2 of the CCTA's report, such as:
To these must be added a large number of other issues such as:
There are probably two minimum requirements for multiple applications to be considered. A proposed system which does not meet them should be scrapped as being too poorly thought out:
For a single application on which multiple systems rely, such as the non-driving driver's licence example, there is a further requirement:
Of course, if the issuer cannot be sued, then this may raise doubts about the quality of the token and about the motivation of the card issuer to ensure that it is difficult to tamper with.
Consideration of these minimum criteria suggests that there will be few circumstances in which sharing a public sector card with a private sector application will be viable.
There are many reasons why multifunction smartcards are a bad idea, except in limited applications such as GSM SIM cards where the lack of an alternative forces them to be considered, and where user control of the terminal removes many of the technical threats. (Even here the commercial success of the concept has been notable by its absence.)
If multifunction tokens lie in our future, then the lack of a user interface alone means that the smartcard is not the right choice for the job. We already have two functioning multifunction tokens - the mobile phone and the PC - soon to be joined by the TV set-top box. Some of these devices may have smartcards in them. However, focussing on the smartcard is the wrong level of abstraction. Firstly, the real driver is the Internet, not a particular component technology; and secondly, the next user token might be the palm pilot, or the e-book, and might not have a card at all. In the medium term, tamper-resistance might come to be provided by the Intel main processor line, or by an embedded microcontroller (as in Firewire), or by software. This is the sort of thing government can't control and is foolish to try to anticipate.
Indeed, the government's track record in `picking winners' among the plethora of available information technologies and standards lends support to the contarian view. The proposed endorsement of the multifunction smartcard may be taken by the digerati as welcome and timely proof that it has finally breathed its last.
Finally, we wish to register a strong complaint about the procedural aspects of this consultation. We were made aware of this exercise by CCTA on the 12th November, the business day preceding the 15th November which is the deadline for submissions, and even this notification was the result of a chance meeting. It is said that the consultation has been open since the 1st November. In any case, for consultation to be limited to two weeks (even when well advertised) contravenes Cabinet Office guidelines. Furthermore, the web site allegedly containing the definitive version of the document was defective on the 12th November when the consultation was brought to our notice.
`Framework for Smart Card Use in Government', Alan Collier, CCTA, 1/11/99
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