Certificates, compliances and Security in VoIP

This article describes various Certificates and compliances, Bill and Acts on data privacy, Security and prevention of Robocalls as adopted by countries around the world pertaining to Interconnected VoIP providers, telecommunications services, wireless telephone companies etc

Compliance certificates by Industry types

HIPAA (Health Insurance Portability and Accountability Act)

Deals with privacy and security of personal medical records and electronic health care transaction

Applicability  : If voip company handles medical information

Includes : 

  • Not allowed Voice mail transcription
  • Should have End-to-End Encryption
  • Restrict  using unsecured WiFi networks to prevent Snooping
  • User security , strong password rules  and mandatory monthly change
  • Secure Firmware on VoIP phones
  • Maintaining Call and Access Logs

SOX( Sarbanes Oxley Act of 2002)

Also known as SOX, SarbOX or Public Company Accounting Reform and Investor Protection Act

Applicability : if managing the communications operations of a regulated, publicly traded company 

Includes : 

  • Retain records which include financial and other sensitive data
  • ways employees are provided or denied access to records or data based on their roles and responsibilities
  • do information audit by a trusted third party. 
  • Retention and deletion of files such as audio files like voicemails, text messages, video clips, declared paper records, storage, and logs of communications activities
  • Physical and digital security controls around cloud-based VoIP applications and the networks

Privacy Related Compliance certificates

COPPA (Children’s Online Privacy Protection Act ) of 1998 

prohibits deceptive marketing to children under the age of 13, or collecting personal information without disclosure to their parents. 

any information is to be passed on to a third party, must be easy for the child’s guardian to review and/or protect

2011 amendment  requires that the data collected was erased after a period of time,

2014 FTC issued guidelines that apps and app stores require “verifiable parental consent.”

CPNI (Customer Proprietary Network Information) 2007

CPNI (Customer Proprietary Network Information) in united states is the information that communication providers  acquire about their subscribers. This Individually identifiable information that is created by a customer’s relationship with a provider, such as data about the frequency, duration, and timing of calls, the information on a customer’s bill, and call identifying information. This processing information is governed strictly by FCC and certification should be renewed on an annual basis

Provider can pass along that information to marketers to sell other services, as long as the customer is notified

In 2007, the FCC explicitly extended the application of the Commission’s CPNI rules of the Telecommunications Act of 1996 to providers of interconnected VoIP service.

CALEA

Communications Assistance for Law Enforcement Act (CALEA) conduct electronic surveillance by imposing specific obligations on “telecommunications carriers” for assisting law enforcement, including delivering call interception and call identification functionality to the government with a minimum of interference to customer service and privacy.

Read more about CALEA and its roles in VoIP here Regulatory and Legal Considerations with WebRTC development

GDPR (General Data Protection Regulation)  in European Union 2018

Supersedes the 1995 Data Protection Directive

Establishes requirements of organizations that process data, defines the rights of individuals to manage their data, and outlines penalties for those who violate these rights.

No personal data may be processed unless this processing is done under one of six lawful bases specified by the regulation (consent, contract, public task, vital interest, legitimate interest or legal requirement). When the processing is based on consent the data subject has the right to revoke it at any time.

Controllers must notify Supervising Authorities (SA)s of a personal data breach within 72 hours of learning of the breach.

California Consumer Privacy Act (CCPA) 2019

consumer rights relating to the access to, deletion of, and sharing of personal information that is collected by businesses. 

Allows consumers to know whether their personal data is sold or disclosed , to whom .

Allows opt-out right for sales of personal information

Right to deletion – to request a business to delete any personal information about a consumer collected from that consumer

Personal Data Protection Bill (PDP) – India 2018

This bill introduces various private and sensitive protection frameworks  like restriction on retention of personal data, Right to correction and erasure (such as right to be forgotten) , Prohibition and transparency of processing of personal data. It also classifies data fiduciaries  including certain social media intermediaries. 

The Bill amends the Information Technology Act, 2000 to delete the provisions related to compensation payable by companies for failure to protect personal data.

Other data privacy acts similar to GDPR 

  • South Korea’s Personal Information Protection Act  2011
  • Brazil’s Lei Geral de Proteçao de Dados (LGPD)  2020
  • Privacy Amendment (Notifiable Data Breaches) to Australia’s Privacy Act 2018
  • Japan’s Act on Protection of Personal Information 2017
  • Thailand Personal Data Protection Act (PDPA) 2020

Features offered by VOIP companies for Data privacy 

  • Access Control & Logging
  • Auto Data Redaction / Account Deletion policy 
  • SIEM (Security information and event management) alerts 
  • Information security , Encrypted Storage For Recordings & Transcripts
  • Disclosing all third party services that are involved in data processing too
  • Role Based Access Control and 2 Factor Authentication
  • Data Security Audits and appointing  data protection officer to oversee GDPR compliance

Against Robocalls and SPIT ( SPAM over Internet Telephony)

 2009 Truth in Caller ID Act 

Telephone Consumer Protection Act of 1991

Implementation of Do not call registry against use of robocalls, automatic dialers, and other methods of communication

Do-Not-Call Implementation Act of 2003

if a business has an established relationship with a customer, it can continue to call them for up to 18 months. If a consumer calls the company, say, to ask for information about the product or service, the company has three months to get back to him.

if the customer asks to not receive calls, the company must stop calling, or be subject to fines.

Exemptions – Calls from a not-for-profit B organisation , informational messages as flight cancellations , Calls from sales and debt collectors etc

Personal Data Privacy and Security Act 2009

Implemented to curb  identity theft and computer hacking. Sensitive personal identifiable information includes : victim’s name, social security number, home address, fingerprint/biometrics data, date of birth, and bank account numbers.

Any company that is breached must notify the affected individuals by mail, telephone, or email, and the message must include information on the company and how to get in touch with credit reporting agencies

If the breach involves government or national security , company must also contact the Secret Service within fourteen days 

TRACED Act (Telephone Robocall Abuse Criminal Enforcement and Deterrence) 2019

Canadian Radio-television and Telecommunications Commission (CRTC) 2018 -32

A solution mechanism has already been standardised and active in adoption called STIR / SHAKEN ( Secure Telephony Identity Revisited / Signature-based Handling of Asserted information using toKENs) described in another article here.

Emergency services 

FCC E911 E911 / VoIP E911 rules

Unlike traditional telephone connections, which are tied to a physical location, VOIP’s packet switched technology allows a particular number to be anywhere making it more difficult for it to reach localised services like emergency numbers of Public Safety Answering Points (PSAPs) . Thus FCC regulations as well as the New and Emerging Technologies 911 Improvement Act of 2008 (NET 911 Act), interconnected VoIP providers are required to provide 911 and E911 service. 

Ref : 

Regulatory/Legal Considerations and CALEA with WebRTC development

This post is deals with some less known real world implication of developing and integrating WebRTC with telecom service providers network and bring the solution in action . The  regulatory and legal constrains are bought to light after the product is in action and are mostly result of short sightedness .  The following is a list of factors that must be kept in mind while webRTC solution is in development stages

  • WebRTC services from telecom provider depend on the access technology, which may differ if the user accessing the network through a third party Wi-Fi hotspot.
  • User/network type may also dictate if decryption of the media is possible/required.
  • For Peer-to-Peer paths, media could be extracted through the use of network probes or other methodology

Then there are Other Considerations such as specific services, for example if WebRTC is used to create softphones software permitting users to receive or originate calls to the PSTN, the current view is to treat this as a fully interconnected VoIP service subject to all the rules that apply to the PSTN – regardless of technologies employed.

CALEA

Communications Assistance for Law Enforcement Act (CALEA) , a  United States wiretapping law passed in 1994, during the presidency of Bill Clinton.

  • CALEA requirement for an LTE user may be very different than the CALEA requirements for a user accessing the network through a third party Wi-Fi hotspot.
  • For media going through the SBC, CALEA may use a design similar to existing CALEA designs.
calea intercept infrstructure
calea intercept infrastructure

Read more on WebRTC Security here which discusses SOP (single origin policy ) , CORs ( cross origin requests) , JSONP , ICE , location sharing , scerensharing , Long term access to camera and microphone , SRTP DTLS as well as best practises for secure communication

VoIP and WebRTC platform security largely depend on the underlying protocols such as SIP . SIP is an robuts and time tested VoIP proctol to facilitate VoIP calls . To learn more about SIP security against atacks like

  • Registration Hijacking
  • Impersonating a Server
  • Temparing Message bodies
  • mid-session threats like tearing down session
  • Denial of Service and Amplification

Also security mechnisms like

  • Full encryption vs hop by hop encrption
  • Transport and Network Layer Security
  • SIP over TLS
  • SRTP

Read more about Certificates , compliances and Security in VoIP which summarized

  • HIPAA (Health Insurance Portability and Accountability Act) ,
  • SOX( Sarbanes Oxley Act of 2002) ,
  • Privacy Related Compliance certificates like COPPA (Children’s Online Privacy Protection Act ) of 1998  ,
  • CPNI (Customer Proprietary Network Information) 2007 ,
  • GDPR (General Data Protection Regulation)  in European Union 2018,
  • California Consumer Privacy Act (CCPA) 2019 ,
  • Personal Data Protection Bill (PDP) – India 2018 and
  • also specificatiosn against Robocalls and SPIT ( SPAM over Internet Telephony) among others

Read about General Data Protection Regulation (GDPR) in VoIP

STIR/SHAKEN – Secure Telephony Identity Revisited / Signature-based Handling of Asserted information using toKENs