Having accidentally sent a journalist an ineptly redacted document, the Public Health Agency of Canada is - quite rightly - roasting uncomfortably in the glare of the media spotlight today:
"Raphael Satter, an Associated Press correspondent in Paris, was dumbfounded when he received files from the Public Health Agency of Canada that were censored using only Scotch tape and paper ... He was able to see the redacted confidential information simply by peeling back the paper."
There are at least 11 information
risks or types of incident associated with redaction:
- Making bad decisions about the data to
be redacted, the technical methods or process to be used and/or the
suitability (primarily competency and diligence) of those tasked to do it;
- Failing to identify correctly all the
sensitive data that must be redacted (both the individual data items and
the files);
- Failing to render the redacted data
totally unrecoverable, for example:
- Using inappropriate or ineffective
technical methods for redaction, such as crudely modifying rather than
permanently deleting the sensitive data using methods that can be
completely or partially reversed (for example simply reformatting or
overlayingredacted text to appear invisible, or applying readily-reversed mechanistic transformations or tokenization of textual identifiers); - Accidentally leaving one or more copies
of the sensitive data completely or partially unredacted (perhaps
releasing multiple, independently and differently redacted versions of a
sensitive document, enabling it to be reconstructed directly or by
inference);
- Partially deleting the sensitive data,
leaving data remnants or sufficient information (such as the editing
journal or cached copies) enabling the data to be restored from the
redacted file;
- Relying excessively on pixellation,
blurring or similar methods of obfuscation to obscure parts of images
(typically for personal privacy reasons), whereas deconvolution and other
more or less advanced image manipulation/transformation techniques may
restore enough of the original image to permit recognition;
- Neglecting to redact sensitive metadata
(e.g. in document properties or reviewer comments, GPS data on
digital images, or alternate data streams);
- Failing to distinguish all redacted from
non-redacted data, consistently and accurately, such that recipients know
unambiguously which parts are no longer original;
- Excessive or inappropriate redaction,
removing more than just the specific sensitive items that were supposed to
have been redacted or doing so clumsily (which raises the prospect of
having to justify redaction decisions and activities to a trustworthy
intermediary or authority);
- Inappropriately or inadvertently
altering the meaning of the remaining data as a result of contextual
issues (e.g. deleting selected data records may invalidate
statistical analysis of the remainder), or by causing collateral damage to
the file structure (such as file integrity issues and inappropriate
formatting changes) during the redaction process;
- Leaving sufficient data in the file to
enable recipients to infer sensitive information, perhaps
in conjunction with other available information sources (e.g. replacing
people’s names with anonymous labels in a redacted file but separately
disclosing the relationship between labels and names; disclosing anonymous
statistical data on known small populations; disclosing the number of
characters redacted, and perhaps even giving clues to the most likely
characters by dint of their printed size; applying data mining,
correlation and inference techniques to glean sensitive data from redacted
or anonymized content);
- Placing excessive reliance on redaction,
believing it sufficient to keep sensitive data totally confidential under
all circumstances whereas technical and process failures are possible and
incidents sometimes occur in practice; conversely, placing zero reliance
on redaction, believing it to be totally incapable of protecting sensitive
information (these are governance and assurance risks);
- Information security issues that are
incidental or peripheral to the redaction process itself such as:
- Sending the original files, redaction
instructions, redacted content or indeed the redacted files to the wrong
recipients;
- Failing to secure information relating
to the redaction process, such as the original files or detailed
redaction instructions, while in transit, during processing and in
storage (e.g. interception of sensitive content in clear on the
network);
- Accidentally disclosing unredacted
versions of the file, whether at the same time and through the same
disclosure mechanism or separately;
- Deliberate disclosure or ‘leakage’ of
unredacted versions of the file without permission or inappropriately (e.g. to
Wikileaks);
- Accidentally or deliberately disclosing
the redacted information by some means other than by releasing the
digital data (e.g. by releasing the redaction instructions,
or being overheard discussing sensitive matters);
- Damaging the integrity and/or
availability of the original unredacted files (e.g. overwriting
them with the redacted versions);
- Use of redaction to conceal illegal or
inappropriate activities (such as pedophilia - image redaction was
ineffective in that particular case!);
- Various other risks (the risk analysis implied here is generic and not comprehensive: it does not necessarily reflect any specific situation).
The Public Health Agency of Canada redactors appear to have experienced risks #9.1, 9.3 and 8 on the list ... and possibly others too (e.g. #3: even if they had photocopied
the paper-masked page and sent the photocopy, it’s quite possible the original
text would have been discernible through the mask).
Instead of merely being an intensely embarrassing privacy incident, this
could literally have been a killer if, say, a security services informant, undercover agent
or counter-terrorism operation had been accidentally unmasked. Let’s hope the relevant parties are more competent than the agency in this case.
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