Almost since its inception in October 2016, the UK’s National Cyber Security Centre (NCSC) has been considering how to formalize its vulnerability disclosure process. While the agency has a wider role in strengthening the overall cyber security of UK business, it has a more specific responsibility towards government systems.
In March 2017 it announced the launch of a new vulnerability coordination pilot program. “UK Government is no different to any other organisation and should adopt a mature approach to vulnerability disclosures, wherever they come from,” it said in a blog post.
The intent was to work with an invited group of security practitioners, with advice from LutaSecurity and using a recognized vulnerability coordination platform, before launching the new process. This was quietly introduced on 15 November 2018 when a new Vulnerability Reporting page appeared on the NCSC website.
The full vulnerability reporting service was announced this week. Through the pilot program, the NCSC said it had learned “how to handle vulnerabilities within an organisation, and how to work together with the researcher community.”
The key points of the new process are that it uses HackerOne as the platform provider and the NCC Group as the assessment partner. LutaSecurity is involved “to ensure we are following industry best practice.”
“One of the key learning points,” writes the NCSC in its announcement, “was to understand that a vulnerability disclosure is not in itself an incident. However, when a vulnerability is used in an attack, it is an incident?. This means that if an unpatched vulnerability gets publicized, it could become an incident?. Therefore, having a mature and co-ordinated vulnerability disclosure process helps decrease the risk of an incident occurring.”
This is the basic argument for ‘responsible disclosure’. The argument for ‘full disclosure’ is that if the vulnerability is not rapidly fixed it could be discovered independently and used maliciously as a zero-day attack by bad actors. The success of responsible disclosure in preventing a vulnerability from becoming an incident thus depends on being able to hold the organization (website owner, vendor etcetera) to account.
This is the purpose of the HackerOne platform. It effectively holds the vulnerability in escrow giving the vulnerability finder and relevant security team enough time to resolve the issue — hopefully working together. Under normal circumstances the time allowed by HackerOne is 30 days. In some circumstances, it can in good faith take longer to fix a vulnerability — but HackerOne still imposes a time limit.
“Last resort,” explains the HackerOne guidelines: “If 180 days have elapsed with the Security Team being unable or unwilling to provide a vulnerability disclosure timeline, the contents of the Report may be publicly disclosed by the Finder. We believe transparency is in the public’s best interest in these extreme cases.”
By adopting the HackerOne platform, the NCSC is being open and transparent in the handling of vulnerabilities on government websites and systems. It still asks that vulnerabilities should first, if possible, be reported to the owner of the website or system. It is possible, then, that some vulnerabilities could bypass the HackerOne platform and its controls.
Interestingly, the NCSC stresses that any vulnerabilities reported to it (that is, via HackerOne) will remain outside of the recently published GCHQ vulnerabilities equities process. The equities process explains how a particular vulnerability could be retained for government use and not disclosed by GCHQ. NCSC makes clear, however, “it’s also important to highlight that anything reported to us is exempt from the equities process and will be disclosed.” HackerOne ensures this.
By being open and transparent, and using recognized good practices in its vulnerability coordination process, the NCSC demonstrates the fine line that exists between it and GCHQ (NCSC is part of GCHQ). Where GCHQ must, by the nature of its work, be very secretive, the NCSC attempts to be as open as possible in its own work.