In my original document, I’d waved my hands a little bit about how the system worked if people had blocked cookies for specific domains, and so I swapped some more email with Phorm to better understand, and then published a revised version on 23rd April — so that the correct information would be available to accompany FIPR’s press release and paper on the various laws that the Phorm system breaks. However, there was one final thing that wasn’t dealt with by press time, and that’s now been explained to me….

The Phorm system does some of its tracking magic by redirecting browser requests using HTTP 307 responses. When this was first explained to me at the meeting with Phorm there were two redirections (a scan of my notes is here), but having thought about this for a while, I asked for it to be explained to me again later on, and it turned out that I had previously been misled, and that there were in fact three redirections (here’s my notes of this part of the meeting).

It now turns out, following my further emails with Phorm, that there are in fact FOUR redirections occurring! This is not because my notes are rubbish — but because Phorm have managed to recall more of the detail of their own system!

For full details of how I understand the system works (at least until some more detail comes to light), see the latest version of my explanatory document, but to give you a flavour of it, consider an example visit to www.cnn.com:

• The user wants to visit www.cnn.com, but their request does not contain a cookie (for www.cnn.com) with a Phorm unique identifier within it. They are redirected (ONE) by the Phorm system to www.webwise.net.
• The user visits webwise.net by following the redirection. If they do not have a Phorm identifier cookie, then they will be issued with a new identifier and redirected (TWO) elsewhere on webwise.net.
• The user visits webwise.net for the second time. If they still don’t have a Phorm identifier cookie then their IP address is marked as wishing to opt-out and they will be redirected to www.cnn.com and they won’t be redirected again for at least 30 minutes. If they do have a cookie (or if they had one at the previous stage) they are redirected (THREE) to a special URL within www.cnn.com.
• The user visits the special URL, which the Phorm system redirects to a fake version of www.cnn.com that sets a www.cnn.com cookie with their Phorm identifier in it, and redirects (FOUR) them to the URL they wanted to visit all along.

For the moment, this appears to be the grand total; there can be up to four redirections, and it is deducible from this description what happens if you refuse (or delete) cookies in the webwise.net and www.cnn.com domains. It is also apparent that if you resolve webwise.net to 127.0.0.1 that you’ll never get past the first redirection; and you will need to rely on the Phorm system spotting these repeated failures and turning off redirection for your IP address.

direct adjective: Straightforward in manner or conduct; upright, honest.

indirect adjective: Mechanism by which Phorm fools your system into accepting tracking cookies from third-party websites, even when those websites promise never to track you!

Quite clearly, web browsing from within these ISPs now depends on the correct functioning of the “Layer 7 switch” and Phorm’s “Anonymiser” machine. This should not be too much of a concern. Network engineers are used to designing out “single points of failure“. Thus, for example, the BT schematics obtained by The Register show parallel systems and cross-coupling of components, so that a single failure will not take out the system. Add in the fact that what are apparently single machines will almost certainly be clusters fronted by intelligent load-balancing devices, and the system is expensive, but extremely resilient.

However, there’s another rather less obvious issue that needs to be addressed.

The bouncing of all web requests back and forth with HTTP 307 redirections means that the system is critically dependent upon the correct resolving of the webwise.net domain. If, for whatever reason, the domain name system (DNS) didn’t return the correct answer when asked for the IP address of webwise.net, then everyone at that ISP would find that their browsing was seriously affected.

If the incorrect address came back as 127.0.0.1 then the customers wouldn’t be able to reach any websites at all — if it came back as the IP address of a machine in downtown St Petersburg, then that site could redirect their web sessions at will — and there’s likely some criminals in that city with some innovative ideas of what could happen next.

So the webwise.net domain has suddenly been promoted to become part of the Critical National Infrastructure (CNI).

The domain is currently hosted at GoDaddy, an american registrar. Last summer the rock-phish gang spent a week running phishing attacks not just against banks, as they usually do, but also against GoDaddy. The immediate reaction was that the criminals wanted to use captured credentials to purchase domain names for free — but wiser heads pointed out that with the login details for a GoDaddy account you were in full control of any domain names that had already been bought : the security of the websites of thousands of major companies (and a great many banks) was resting on the security of eight-character registrar login passwords.

However, firms that have considered the risk don’t buy $10 domain names, but spend rather more, and their registrar will insist on rigorous security checks before altering any details. We must obviously assume that webwise.net is not at risk from registrar phishing in this simplistic way.

The more likely way of subverting what webwise.net resolves to is called “DNS cache poisoning”. There are several ways of doing this (this Wikipedia article provides a helpful summary), most of which shouldn’t work if the ISP has configured their DNS server correctly.

However fundamental weaknesses in the DNS protocol (relying on 16bit values matching to show authenticity) means that DNS forgery attacks can only be made harder, not prevented altogether. Making it harder may currently be sufficient to make phishing attackers use simpler methods — but if the prize is the disruption of web browsing for millions of people…?

There are things that the ISPs can do to improve security — such as each of them making themselves authoritative for webwise.net, which should address the DNS forgery issue. Let’s hope that they haven’t overlooked this.

[[with acknowledgments to Matt Johnson and others involved in understanding this particular design risk]]

The idea is that advertisers can be more picky in who they serve adverts to… you’ll get travel ads if you’ve been looking to go to Pamplona for the running of the bulls, car adverts if you’ve been checking out the prices of Fords (the intent is that Phorm’s method of distilling down the ten most common words on the page will allow them to distinguish between a Fiesta and a Fiesta!)

I’ve now written up the extensive technical details that they provided (10 pages worth) which you can now download from my website.

Much of the information was already known, albeit perhaps not all minutiae. However, there were a number of new things that were disclosed.

Phorm explained the process by which an initial web request is redirected three times (using HTTP 307 responses) within their system so that they can inspect cookies to determine if the user has opted out of their system, so that they can set a unique identifier for the user (or collect it if it already exists), and finally to add a cookie that they forge to appear to come from someone else’s website. A number of very well-informed people on the UKCrypto mailing list have suggested that the last of these actions may be illegal under the Fraud Act 2006 and/or the Computer Misuse Act 1990.

Phorm also explained that they inspect a website’s “robots.txt” file to determine whether the website owner has specified that search engine “spiders” and other automated processing systems should not examine the site. This goes a little way towards obtaining the permission of the website owner for intercepting their traffic — however, in my view, failing to prohibit the GoogleBot from indexing your page is rather different from permitting your page contents to be snooped upon, so that Phorm can turn a profit from profiling your visitors.

Overall, I learnt nothing about the Phorm system that caused me to change my view that the system performs illegal interception as defined by s1 of the Regulation of Investigatory Powers Act 2000.

Phorm argue, with some justification, that their system does not permit them to identify individuals and that they meet and exceed all necessary Data Protection regulations — producing a system that is superior to other advertising platforms that profile Internet users.

Mayhap, but this is to mix up data protection and privacy.

The latter to me includes the important notion that other people, even people I’ll never meet and who will never meet me, don’t get to know what I do, they don’t get to learn what I’m interested in, and they don’t get to assume that targeting their advertisements will be welcomed.

If I spend my time checking out the details of a surprise visit to Spain, I don’t want the person I’m taking with me to glance at my laptop screen and see that its covered with travel adverts, mix up cause and effect, and think — even just for a moment — that it wasn’t my idea first!

Phorm says that of course I can opt out — and I will — but just because nothing bad happens to me doesn’t mean that the deploying the system is acceptable.

Phorm assumes that their system “anonymises” and therefore cannot possibly do anyone any harm; they assume that their processing is generic and so it cannot be interception; they assume that their business processes gives them the right to impersonate trusted websites and add tracking cookies under an assumed name; and they assume that if only people understood all the technical details they’d be happy.

Well now’s your chance to see all these technical details for yourself — I have, and I’m still not happy at all.

The BT spokesman said Phorm offered consumers two benefits. "Customers will receive more relevant advertising and will get warnings if any of the websites they visits are known to be phishing sites."

While Phorm and the ISPs signing up say users will be able to opt out, but they don’t say whether everyone will be opted out or in automatically by default, I strongly suspect everyone will be opted in as a matter of course, here’s why. If you were to ask the users to opt in with this form advertising, I’m pretty sure just about everyone would say no thank you! Which for me answers the question to whether this is a good idea or not, in fact I’ve seen one Virgin forum (cableforum.co.uk) poll that stated 95% of users would want to opt out. I’ve also heard that if Phorm don’t have millions of users signing up, the whole system would not be viable, so we can be pretty sure everyone will be signed up by default.

The thing that puzzles me most about Phorm is their description of the Webwise system, which presents it primarily as an anti-fraud technology. This leaves an impression that its real purpose is somewhat hidden. I suppose this is because nobody really like adverts, especially not the ones intruding with the content of the page we wanted to see.