[2514] in cryptography@c2.net mail archive
draft of my letter to Canada's Crypto Policy
daemon@ATHENA.MIT.EDU (M Taylor)
Wed Apr 15 14:45:52 1998
Date: Wed, 15 Apr 1998 11:25:29 -0300
To: efc-talk@efc.ca, cryptography@c2.net
From: M Taylor <mctaylor@glyphmetrics.ca>
This is an early draft of my response to Industry Canada's discussion of
possible changes to <http://strategis.ic.gc.ca/SSG/cy00005e.html> "A
Cryptography Policy Framework for Electronic Commerce: Building Canada's
Information Economy and Society"
I do not manufactor or sell anything, but I do export freely available
cryptography software and libraries. <ftp://fractal.mta.ca/pub/crypto/>
Please send any feedback to me, <mctaylor@glyphmetrics.ca>, I'd like to
consider them before submitting this to Industry Canada's Task Force on
E-Commerce.
-M Taylor
------------
I think that the first we have to do is realise that we are dealing with
software and hardware intended for regular everyday people and their
business. We do not always noticed that we are already using encryption
everyday. It is integrated into the services and software we use daily
at the Interact's POS device or your bank's ATM, or the online bookstore.
Industry Canada has ask how this can be speeded up. The government of
Canada has already taken a bold first step in the correct direction with
its Public Key Infrastructure (PKI) which is being put into place this
year. I would like to see the PKI also cross-certify private industry
Certificate Authorities (CAs) to increase the level of trust in Canadian
operated CAs.
A third-party CAs should absolutely not have access to the signature
private-key, this nullifies the expectation that only the authorized
users of the private have access to it. This would weaken the increase
the possibility that a forgery took place in the event of a dispute.
Within a company, a correctly implemented infrastructure would include
means for data recovery of encrypted information, but a signature key
should be disposable and revokable, not recoverable.
Next the government should work with the US NIST towards successor
to DES, called Advanced Encryption Standard (AES) which is a suppose to
be a 128-bit block symmetric cipher which accepts keys of 128, 192, and
256-bits. This standard should be strongly recommended to be used for
non-classified government encryption. If this encryption standard is
going to be accepted by developers it also needs to be easily exportable
to customers in USA and abroad.
Legal issues within need to be clarified, such as the validity of the
digital signature usage in relation to contracts and liability.
The export process needs to be streamlined to prevent impairing the smaller
Canadian companies in a global marketplace. Clarification on the
regulations, such as prior approval on a variety of algorithms and keys
sizes to simplify the application process. Expansion of what meets the
the designation of mass-market software may reduce the delays of other
export permit approvals. Software and hardware that uses 56-bit key DES
in any mode, Triple DES in any mode, 128-bit key IDEA, up to 128-bit
key CAST, 2048-bit RSA, 128-bit ECC should be readily approvalable for
export to much of the world. Perhaps an list of "fast-track"
countries which make up the majority of Canada's export markets and the
government has very good relations with (members of the Wassenaar, etc).
The escrow or "recovery" of real-time communication is prohibitively
complex, expensive, impossible to implement without reducing the
security of the encryption, and carries the stigma and threat of a
infrastructure which could be abused by the government and law
enforcement agencies, and little ability to detect such abuses.
The free export of software via the General Software Notice must be
preserved to ensure the freedom of research within Canada's excellent
and world-class cryptography research community. It provides a
valuable means of allowing cryptography to be freely supported amongst
the free software community which has been cornerstone in the
development of Internet software and standards. Finally it allows
small companies to easily deploy mass-market cryptography software for the
end-user's own needs without using valuable resources of DFAIT.
Funding for advancing the cryptanalysis abilities of the CSE would be
cheaper and may be far more productive while maintaining a secure
infrastructure for e-commerce and the citizens of Canada.
M Taylor <mctaylor@glyphmetrics.ca>
