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© JANET(UK) 2011 Running a Public Communications Service Andrew Cormack Chief Regulatory Adviser, Janet Andrew.Cormack@ja.net Andrew.Cormack@ja.net
© JANET(UK) 2011 What is a public comms. service? “public electronic communications service” means any electronic communications service that is provided so as to be available for use by members of the public; (Communications Act 2003, s.151) E.g. Open library terminal, open/commercial wifi hotspot, hotel, cybercafe, housing estate, business park,... NB: Most BCE doesn’t involve public traffic NB: Janet is not a public network service
© JANET(UK) 2011 Which laws are different? The following have additional rules for public services –EC Telecomms Directives (security & privacy) –UK Interception Law –UK/EU Data Retention –UK Copyright Infringement – maybe Future developments likely at EC and UK level
© JANET(UK) 2011 Responsibilities for the service Must comply with Ofcom guidance on security –Documented risk management process (e.g. ISO27001) –Take appropriate measures to deliver security Must report “significant” security breaches to Ofcom, e.g. –100K users disconnected for 12 hours, or –Failure reported to Government department or in the media
© JANET(UK) 2011 Responsibilities for privacy Must design service/systems to protect privacy Must report all privacy breaches to ICO –Consequences and mitigation action taken –And to user if PD or privacy “adversely affected” Traffic/flow data only used for prescribed purposes –Transmission; Billing and traffic management; Customer enquiries; Fraud prevention/detection; Other legal duties Not research –Must delete/anonymise as soon as no longer needed Unlawful interception by operator is a criminal offence
© JANET(UK) 2011 Responsibilities for users Must (if notified by Home Office) retain data about use –Time, duration, type, source, destination of communication –Can agree by contract who does this Best if done by the organisation that authenticates users Various other responsibilities being discussed –Dealing with copyright infringements (Digital Economy Act) –Dealing with infected user equipment –Network Neutrality (restrictions on traffic management)
© JANET(UK) 2011 How far do these extend? Which networks/equipment –Probably anything that might carry public traffic –Good idea to separate those Which organisations are responsible? –Service: Organisation, Janet and ISP –Privacy: Organisation, Janet and ISP –Users: Organisation or ISP
© JANET(UK) 2011 Don’t Forget: State Aid law Using public funds to distort a commercial market –Illegal: fine plus repayment with interest Public Internet access is a commercial market –State Aid law likely to apply Possible approaches (see Janet guidance) –Library terminal: provide “supported Internet access” –Wifi Hotspot: open tender, including use of backhaul –Hotel/cybercafe: charge market rate to trading subsidiary –Broadband gaps: BIS authorisation for individual projects
© JANET(UK) 2011 Policies etc. Janet Policies protect Janet reputation/operation –Need SecPol and AUP whenever Janet addresses used Access control, Manage security threats, Enforce AUP, etc. –Otherwise use Policy of ISP whose addresses are used –Always need disconnection right to protect service to others Other IP address issues –RIPE/WHOIS contact data => body with User responsibilities Copyright enforcement responsibility likely to follow this –Beware of IP address “authorisation” Internal services, licensed content, firewalls, etc.
© JANET(UK) 2011 To run a public network service... It/you must (+ bullets apply to Janet backhaul too) +Be designed according to Ofcom security principles +Report significant (availability) breaches to Ofcom +Report all privacy breaches to ICO +Only use traffic data for prescribed purposes –Only use interception (if at all) with great care –Be prepared to retain information about users –Be prepared to deal with copyright infringement reports +Deal with State Aid issues Probably want to separate this from your R&E service
© JANET(UK) 2011 Discussion Themes How to segregate? Authentication: when/where/how? ISP access Institutional Risk Assessment & Responsibilities Pricing Models Community Support
© JANET(UK) 2011 Questions?
Copyright JNT Association JANET Briefing, 20 th Jan, Digital Economy Act 2010 Andrew Cormack Chief Regulatory Adviser, JANET(UK)
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