Fintech South 2020 – Maintaining trust and safety in a digital world

At the (sadly, virtual) Fintech South event the year, I was asked to chair a discussion on identity and privacy with three extremely well-qualified experts who had informed perspectives on the state of, and trends in, those important pillars of a digital society. These were Adam Gunther (SVP, Digital Identity for Equifax), Andrew Gowasack (Co-Founder and President at TrustStamp) and Megan Heinze (President, Financial Institutions, North America for IDEMIA). It was great to talk to a group of people who were not only well-informed on these topics but had some passion for them too.

I won’t go over everything that was discussed, but I do want to pick up on a comment that was made in passing when I was chatting to the panelists: someone said that a guiding principle should be “no scary systems”. Hear hear! But what is a scary system? It is, in my opinion, a system that privileges security over privacy. This is not how we should be designing the identity systems for the 21st century!

Malware Wolves in Developer Sheep’s Clothing

internet screen security protection

When consumers install software on their devices, they often perform some sort of risk evaluation, even if they don’t consciously realise it.  They might consider who provides the software, whether it is from an app-store, what social media says, and whether they have seen any reviews.  But what if once a piece of software had been installed, the goalposts moved, and something that was a genuine software tool at the time of installation turned into a piece of malware overnight.

This is what happened to approximately 300,000 active users of Chrome ad blocking extension Nano Adblocker.  You see, at the beginning of October, the developer of Nano Adblocker sold it to another developer who promptly deployed malware into it that issued likes to hundreds of Instagram posts without user interaction.  There is some suspicion that it may have also been uploading session cookies.

Internet voting – challenging but necessary

i voted sticker lot

What did you think of the US election? I don’t mean the candidates and the outcome. What did you think of the election process? Should it be possible for national elections of this type to be done online? Last week the IET published a paper on internet voting in the UK, led by our good friend at the University of Surrey, Professor Steve Schneider. It’s well worth a read. As the paper explains, internet voting for statutory political elections is a uniquely challenging problem. Firstly voting systems have exacting requirements and secondly, the stakes are high with the threat of state level interference.

The tension in facial recognition

Facial recognition camera

The rise of facial recognition technology and the erosion of privacy

In the 2002 movie Minority Report, Tom Cruise’s character has his eyes surgically replaced so he can avoid being identified by the all-pervasive retina scanning system that the state uses to track people… and of course, uses to show targeted ads to people. This is a rather dystopian view of the broad application of biometrics technology.  However, judging by a lawsuit targeting Macy’s for their use of Clearview AI’s facial recognition technology in their stores, it seems that staying anonymous in the bricks and mortar world is becoming a little more like the movie. Whilst you may not require surgery, you may soon require something akin to glasses and a fake beard to avoid being tracked. The issue here is that Clearview AI has been scraping images from publicly viewable sources on the web for a while, enabling them to create a database of facial biometrics against which to match captured facial images. Amongst the sources of this data are Facebook, Twitter, LinkedIn, YouTube and Vimeo, with some of these companies having sent cease and desist letters to Clearview AI for breach of their terms of service.  The aim it seems is for Clearview AI to create a one-to-many facial recognition solution that can identify an individual from only an image of their face from anyone who is in a photo or video on the web.  Based on a report on Buzzfeed, they were working with over 2000 companies as of February 2020, and they are probably not alone, so perhaps we should be concerned.

Is your mobile banking app exposed by someone else’s software?

This post was written in collaboration with Neal Michie, Director, Product Management, Verimatrix.

Banks are facing massive disruption and change from many directions. The rise of app-only banks has made the need for traditional banks to have compelling app services an imperative. Banks have of course been building mobile apps for several years. If not already, they will soon be the most important channel for engaging with and serving customers. However, mobile banking apps will also become the primary focus of hackers, intent on getting access to other people’s information and money.

No Delay to SCA

Since the FCA announced a further 6 month delay in the UK’s deadline for Strong Customer Authentication there’s been a general expectation that the EBA would follow suit and relax the date for the EEA. However, it now appears that won’t happen – the 31st December 2020 remains the key date and there won’t be any further relaxation in the rules.

This hasn’t been officially announced but appears to have been the gist of a letter by the European Commission’s Executive Vice President Valdis Dombrovskis which makes clear that there’s no consideration in place for a delay and that, in the Commission’s view, the Coronavirus pandemic and the subsequent rise in e-commerce makes it more urgent to implement rather than less. It looks like the Commission is not for turning and with only a little over six months left to be prepared any merchant or payment service provider than hasn’t been planning for this is likely to be in full panic mode.

At one level it’s hard to disagree with the Commission’s position – the deadline has been shifted already from last September in order to accommodate the industry’s inability to implement in time. Although, in fairness, it ought to be noted that original requirements require a degree in semiotics to fully understand and clarifications have been fitful and, on occasion, too late. However, there’s a degree of real-world pragmatism missing from the decision – the last thing the European economy needs right now is an e-commerce cliff edge right in the middle of the busiest shopping period of the year.

The divergence between the UK and Europe also starts to raise some interesting questions. PSD2 applies to countries within the EEA and not to transactions starting or finishing outside – and as of January 1st 2021 the UK will be fully outside. PSD2 will apply within the EEA ex-UK and within the UK ex-Europe but, barring some kind of passporting agreement, not between them. One option for desperate European e-tailers may be to shift operations to the UK where the SCA deadline is a further 9 months away. Of course, the same applies in reverse: logically there ought to be a compromise, but those seem thin on the ground.

Overall, then, the message to all organisations involved in electronic payments is to assume that SCA will be  enforced from January 1st next year and any firm that can’t support it should expect to see transactions declined. Merchants and PSPs may choose or may not be able to handle SCA but issuers will be ready and won’t want to be upsetting the regulators. For any companies out there that don’t know what to do come and talk to us, we can help guide you through the process – first by helping ensure you’re compliant and then by addressing the additional friction that SCA will introduce.

It isn’t too late to do something about SCA but it does very much look like we are at the eleventh hour.

Identity – Customer Centric Design

The team put on an excellent webinar this Thursday (May 21st, 2020) in the Tomorrow’s Transactions series. The focus was on Trust over IP, although digital identity and privacy were covered in the round.

The panellists were Joni Brennan of the DIACC (Digital ID & Authentication Council of Canada—full disclosure: a valued customer), long-time collaborator Andy Tobin of Evernym and our own Steve Pannifer and Justin Gage. Each of the panellists is steeped in expertise on the subject, gained from hard-won experience.

Joni and Andy presented, respectively, the DIACC and ToIP layered architectural models (largely congruent) for implementing digital identification services. The panellists agreed that no service could work without fully defined technical, business and governance structures. Another key point was that the problems of identification and privacy merge into one another. People need to make themselves known, but are reserved about making available a slew of personal information to organisations with whom they may seek no persistent relationship or do not fully trust.

At one point, it was mentioned that practical progress has been slow, even though the basic problem (to put one aspect crudely, why do I need so many passwords?) of establishing trust over digital networks has been defined for 20 years at least. It could be argued that Consult Hyperion has earned its living by designing, developing and deploying point solutions to the problem. I began to wonder why a general solution has been slow to arise, and speculated (to myself) that it was because the end-user has been ill-served. In particular, the user sign-up and sign-in experiences are inconsistent and usually horrible.

Therefore, I posed the question “What is the panel’s vision for how people will gain access to personalised digital services in 2030?” The responses were interesting (after momentary intakes of breath!) but time was short and no conclusions were reached.

I slept on the problem and came up with some tentative ideas. Firstly, when we are transacting with an organisation (from getting past a registration barrier to download some info, through buying things, to filing tax returns), everything on our screens is about the organisation (much of it irrelevant for our purposes) and nothing is about us. Why can’t our platforms present a prominent avatar representing us, clickable to view and edit information we’ve recorded, and dragable onto register, sign-in or authorise fields in apps or browsers?

Now, there could be infinite variations of ‘me’ depending on how much personal information I want to give away; and the degree of assurance the organisation needs to conduct business with me (of course, it’s entirely possible there could be no overlap). I reckon I could get by with three variations, represented by three personas:

  • A pseudonym (I get tired of typing flintstone@bedrock.com just to access a café’s wifi; there are some guilty parties registering for our webinars too!)
  • Basic personal information (name, age, sex, address) for organisations I trust, with a need-to-know
  • All of the above, maybe more, but (at least, partly) attested by some trusted third party.

Obsessives could be given the ability to define as many options, with as many nuances, as they like; but complexity should be easily ignorable to avoid clutter for the average user.

I think it’s the major operating system providers that need to make this happen: essentially, Apple, Android and Microsoft, preferably in a standard and portable way. For each we would set up an ordered list of our preferred authentication methods (PIN, facial recognition, etc) and organisations would declare what is acceptable to them. The system would work out what works for both of us. If the organisation wants anything extra, say some kind of challenge/response, that would be up to them. Hopefully, that would be rare.

The Apple Pay and Google Pay wallets are some way to providing a solution. But sitting above the payment cards and boarding passes there needs to be the concept of persona. At the moment, Apple and Google may be too invested in promulgating their own single customer views to see the need to take this extra step.

I sensed frustration from the panellists that everything was solvable, certainly technically. Governance (e.g. who is liable for what when it all goes wrong?) was taken to be a sticking point. True, but I think we need to put the average user front and centre. Focus groups with mocked-up user experiences would be a good start; we’d be happy to help with that!

Would you use the NHSX app?

I listened with interest to yesterday’s parliamentary committee on the proposed NHSX contact tracing app, which is being trialled on the Isle of Wight from today. You can see the recording here.

Much of the discussion concerned the decision to follow a centralised approach, in contrast to several other countries such as Germany, Switzerland and Ireland. Two key concerns were raised:

1. Can a centralised system be privacy respecting?
Of course the answer to this question is yes, but it depends on how data is collected and stored. Cryptographic techniques such as differential privacy are designed to allow data to be de-indentified so that is can be analysed anonymously (e.g. for medical research) for example, although there was no suggestion that NHSX is actually doing this.

The precise details of the NHSX app are not clear at this stage but it seems that the approach will involve identifiers being shared between mobile devices when they come into close proximity. These identifiers will then be uploaded to a central service to support studying the epidemiology of COVID-19 and to facilitate notifying people who may be at risk, having been in close proximity to an infected person. Whilst the stated intention is for those identifiers to be anonymous, the parliamentary debate clearly showed there a number of ways that the identifiers could become more identifiable over time. Because the identifiers are persistent they are likely to only be pseudonymous at best.

By way of contrast, a large team of academics has developed an approach called DP-3T, which apparently has influenced designs in Germany and elsewhere. It uses ephemeral (short-lived) identifiers. The approach is not fully decentralised however. When a user reports that they have COVID-19 symptoms, the list of ephemeral identifiers that user’s device has received, when coming into close proximity to other devices, is shared via a centralised service. In fact, they are broadcast to every device in the system so that risk decisioning is made at the edges not in the middle. This means that no central database of identifiers is needed (but presumably there will be database of registered devices).

It also means there will be less scope for epidemiological research.

All of this is way beyond the understanding of most people, including those tasked with providing parliamentary scrutiny. So how can the average person on the street or the average peer in Westminster be confident in the NHSX app? Well apparently the NHSX app is going to be open sourced and that probably is going to be our greatest protection. That will mean you won’t need to rely on what NHSX says but inevitably there will be universities, hackers, enthusiasts and others lining up to pick it apart.

2. Can a centralised system interoperate with the decentralised systems in other countries to allow cross border contact tracing?
It seems to us that whether a system is centralised or not is a gross simplification of the potential interoperability issues. True, the primary issue does seem to be the way that identifiers are generated, shared and used in risk decisioning. For cross border contact tracing to be possible there will need to be alignment on a whole range of other things including technical standards, legal requirements and perhaps even, dare I say it, liability. Of course, if the DP-3T model is adopted by many countries then it could become the de facto standard, in which case that could leave the NHSX app isolated.

Will the NHSX app be an effective tool to help us get back to normal? This will depend entirely on how widely it is adopted, which in turn will require people to see that the benefits outweigh the costs. That’s a value exchange calculation that most people will not be able to make. How can they make a value judgment on the potential risks to their civil liberties of such a system? The average user is probably more likely to notice the impact on their phone’s battery life or when their Bluetooth headphones stop working.

There’s a lot more that could be said and I’ll be discussing the topic further with Edgar WhitleyNicky Hickman and Justin Gage on Thursday during our weekly webinar.

KYC at a distance

We live in interesting times. Whatever you think about the Coronavirus situation, social distancing will test our ability to rely on digital services. And one place where digital services continue to struggle is onboarding – establishing who your customer is in the first place.  

One of the main reasons for this, is that regulated industries such as financial services are required to perform strict “know your customer” checks when onboarding customers and risk substantial fines in the event of compliance failings. Understandably then, financial service providers need to be cautious in adopting new technology, especially where the risks are not well understood or where regulators are yet to give clear guidance.

Fortunately, a lot of work is being done. This includes the development of new identification solutions and an increasing recognition that this is a problem that needs to be solved.

The Paypers has recently published its “Digital Onboarding and KYC Report 2020”. It is packed full of insights into developments in this space, features several Consult Hyperion friends and is well worth a look.

You can download the report here: https://thepaypers.com/reports/digital-onboarding-and-kyc-report-2020

Fraudsters target loyalty schemes for easier gains

It has become practically impossible to keep up with the number of loyalty-related security breaches. In today’s edition of “Who Got Hit?”, we read that Tesco is sending security warnings to 600,000 Tesco Clubcard loyalty members following fraudulent activities[1]. The breach is suspected to be attackers trying to ‘brute-force’ their way into the loyalty system, using stolen credentials, potentially from a different breach. In recent years, fraud associated with loyalty has been on the rise. According to a 2019 report by Forter was an 89% increase in loyalty related fraud, from the previous year.


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