Sometimes you just know you are going to be flamed for an opinion, and today is one of those days.
This is based on this post at the Register.
In principle I think this is a great idea. In reading the whole report there are some steps that I find lacking but then it is understandable. I think the chances of this specific report being accepted and implemented is rather remote. This is a shame, but I think it is a step in the right direction.
Let us look at their recommendations:
1. We recommend that the EU introduce a comprehensive security-breach notification law.
Great idea. It does open a can of worms that most companies would prefer to keep closed, but without this awareness any larger plan is bound to fail.
2. We recommend that the Commission (or the European Central Bank) regulate to ensure the publication of robust loss statistics for electronic crime.
Same issues as with 1.
3. We recommend that ENISA collect and publish data about the quantity of spam and other bad traffic emitted by European ISPs.
Great idea, but does not go far enough. I would prefer to introduce some teeth into this to target ISP’s that actively support organized crime. Maybe this will happen anyway as this may be a good indicator for where the police should start looking.
4. We recommend that the European Union introduce a statutory scale of damages against ISPs that do not respond promptly to requests for the removal of compromised machines, coupled with a right for users to have disconnected machines reconnected if they assume full liability.
I love this one. For the first time there will be money associated with infecting a machine with a bot. There will also be a price to not running a safe network. This is a great idea, it automatically enables the use a large body of existing law to claim damages
5. We recommend that the EU develop and enforce standards for network connected equipment to be secure by default.
Personally I love this one. As a company that take security and exploits very seriously I think this is very good. I think there will be significant resistance against this as taking security seriously is expensive.
6. We recommend that the EU adopt a combination of early responsible vulnerability disclosure and vendor liability for unpatched software to speed the patch-development cycle.
And the crowd goes wild… I think this is a another good recommendation.
7. We recommend security patches be offered for free, and that patches be kept separate from feature updates.
Obvious, but then the cost discussion I had under 5 is very relevant here.
8. The European Union should harmonise procedures for the resolution of disputes between customers and payment service providers over electronic transactions.
Obvious
9. We recommend that the European Commission prepare a proposal for a Directive establishing coherent regime of proportionate and effective sanctions against abusive online marketers.
And the crowd goes wild…
10. ENISA should conduct research, coordinated with other affected stakeholders and the European Commission, to study what changes are needed to consumer-protection law as commerce moves online.
Good idea
11. We recommend that ENISA should advise the competition authorities whenever diversity has security implications.
And the crowd goes wild… A diverse environment is much harder to attack.
12. We recommend that ENISA sponsor research to better understand the effects of Internet exchange point (IXP) failures. We also recommend they work with telecomms regulators to insist on best practice in IXP peering resilience.
Good idea
13. We recommend that the European Commission put immediate pressure on the 15 EU Member States that have yet to ratify the Council of Europe Convention on Cybercrime.
I would think this would be obvious. This is a huge issue. Not only in the EU but also in the rest of the world. Even in the US the cybercrime laws are inconsistent.
14. We recommend the establishment of an EU-wide body charged with facilitating international co-operation on cyber crime, using NATO as a model.
Very obvious and great idea. This is one of the largest issues preventing us from containing malware. I think a world-wide network of inter-connected laws and co-operation to manage cybercrime is what is really needed. This is very unlikely to happen but this is a good start. The good guys need to be able to go anywhere the bad guys are. At this stage we can’t. I am happy to see that this is acknowledged and something done about it.
15. We recommend that ENISA champion the interests of the information security sector within the European Commission to ensure that regulations introduced for other purposes do not inadvertently harm security researchers and firms.
Good idea. But then I also think that this is going to be interesting. There are too many “security” companies that do not really do security. They do hacking and probably do more to assist the criminals than in protecting society.