https://regmedia.co.uk/2021/10/14/key_risks_paper.pdf


Bugs in our Pockets:
The Risks of Client-Side Scanning 

Embargoed until 0200 CET Oct 15

Ross Anderson Steven M. Bellovin
Matt Blaze Jon Callas Peter G. Neumann Jeffrey I. Schiller Bruce Schneier
Carmela Troncoso October 14, 2021
Executive Summary
Whitfield Diffie Ronald L. Rivest
Vanessa Teague
Susan Landau
Our increasing reliance on digital technology for personal, economic, and 
government affairs has made it essential to secure the communications and 
devices of private citizens, businesses, and governments. This has led to 
pervasive use of cryptography across society. Despite its evident advantages, 
law enforcement and national security agencies have argued that the spread of 
cryptography has hindered access to evidence and intelligence. Some in industry 
and government now advocate a new technology to access targeted data: 
client-side scanning (CSS). Instead of weakening encryption or providing law 
enforcement with backdoor keys to decrypt communications, CSS would enable 
on-device analysis of data in the clear. If targeted information were detected, 
its existence and, potentially, its source, would be revealed to the agencies; 
otherwise, little or no information would leave the client device. Its 
proponents claim that CSS is a solution to the encryption versus public safety 
debate: it offers privacy—in the sense of unimpeded end-to-end encryption—and 
the ability to successfully investigate serious crime.
In this report, we argue that CSS neither guarantees efficacious crime 
prevention nor prevents surveillance. Indeed, the effect is the opposite. CSS 
by its nature creates serious security and privacy risks for all society while 
the assistance it can provide for law enforcement is at best problematic. There 
are multiple ways in which client-side scanning can fail, can be evaded, and 
can be abused.
Its proponents want CSS to be installed on all devices, rather than installed 
covertly on the devices of suspects, or by court order on those of 
ex-offenders. But
1

universal deployment threatens the security of law-abiding citizens as well as 
law- breakers. Technically, CSS allows end-to-end encryption, but this is moot 
if the message has already been scanned for targeted content. In reality, CSS 
is bulk in- tercept, albeit automated and distributed. As CSS gives government 
agencies access to private content, it must be treated like wiretapping. In 
jurisdictions where bulk intercept is prohibited, bulk CSS must be prohibited 
as well.
Although CSS is represented as protecting the security of communications, the 
technology can be repurposed as a general mass-surveillance tool. The fact that 
CSS is at least partly done on the client device is not, as its proponents 
claim, a security feature. Rather, it is a source of weakness. As most user 
devices have vulnerabilities, the surveillance and control capabilities 
provided by CSS can potentially be abused by many adversaries, from hostile 
state actors through criminals to users’ intimate partners. Moreover, the 
opacity of mobile operating systems makes it difficult to verify that CSS 
policies target only material whose illegality is uncontested.
The introduction of CSS would be much more privacy invasive than previous 
proposals to weaken encryption. Rather than reading the content of encrypted 
com- munications, CSS gives law enforcement the ability to remotely search not 
just com- munications, but information stored on user devices.
Introducing this powerful scanning technology on all user devices without fully 
understanding its vulnerabilities and thinking through the technical and policy 
con- sequences would be an extremely dangerous societal experiment. Given 
recent expe- rience in multiple countries of hostile-state interference in 
elections and referenda, it should be a national-security priority to resist 
attempts to spy on and influence law- abiding citizens. CSS makes law-abiding 
citizens more vulnerable with their personal devices searchable on an 
industrial scale. Plainly put, it is a dangerous technology. Even if deployed 
initially to scan for child sex-abuse material, content that is clearly 
illegal, there would be enormous pressure to expand its scope. We would then be 
hard-pressed to find any way to resist its expansion or to control abuse of the 
system.
The ability of citizens to freely use digital devices, to create and store 
content, and to communicate with others depends strongly on our ability to feel 
safe in doing so. The introduction of scanning on our personal devices—devices 
that keep information from to-do notes to texts and photos from loved 
ones—tears at the heart of privacy of individual citizens. Such bulk 
surveillance can result in a significant chilling effect on freedom of speech 
and, indeed, on democracy itsel


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