epa-sgd-crypt draft
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content/blog/epa-sgd-crypto/index.rst
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---
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title: "75 Million Lives, Two Keys"
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date: 2025-01-05T23:42:00+01:00
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draft: true
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---
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2025 has begun. In this new year, with its new national healthcare record system, the country of Germany will start one
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of the largest rollouts of a cryptographic system in history. While the system has received scrutiny as well as
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resulting harsh criticism from a number of parties ranging from NGOs to everyday civilians, the system has received
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surprisingly little attention from the academic applied cryptography crowd. Additionally, previous criticism of
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the system has largely revolved around organizational issues. While valid, we belive that some cryptographic issues at
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the core of the system have escaped attention unitl now. In particular, at the core of the system is a key escrow system
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that contains several questionable design choices and that in its overall design seems out of place in 2025.
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The aim of the system is to serve as a shared storage for all healthcare records of a person. In the system, a person's
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entire patient file with all documentation on the treatment process including test results, images and other raw data
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will be stored in something vaguely resembling cloud storage such that all healthcare providers that the person visits
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can access the entire file. This centralized, synchronized storage eliminates the need for transferring this data
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between hospitals and doctors offices by fax, mail or physical media as it was common practice until now. After a
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development and testing phase lasting approximately five years, the German government decided to roll out the system to
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everybody insured under Germany's mandatory national health insurance scheme, totalling approximately 75 million people,
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on January 15th 2025.
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In this article, we will give an overview of the system's cryptographic design before highlighting a few odd
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design choices that could amount to a viable attack vector to the powerful adversaies
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## Context and involved parties
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Germany has a national, mandatory health insurance system. The system is open to any permanent resident of the country
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irrespective of citizenship. The system is mandatory in that while residents can choose between a number of both
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publically owned as well as private healthcare providers, it is not possible to opt out of the system. The public health
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insurance providers cover approximately 90% of German residents. These providers are organized in an umbrella
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organization named "GKV Spitzenverband". The resposibility of this umbrella organization largely revolves around
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negotiating prices with pharmaceutical companies and with healthcare providers as a publically sanctioned cartel, but
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also includes the specification and operation of shared IT infrastructure for billing and data exchange between
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healthcare providers.
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While GKV Spitzenverband is the party that ultimately holds responsibility for the regulatory administration of national
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healthcare IT infrastructure, it has delegated large parts of both the technical specification of this infrastructure as
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well as its day-to-day operation to Gematik GmbH, a state-owned limited liability corporation created specifically for
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the purpose of developing and implementing national healthcare IT standards. The electronic healthcare record system we
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describe in this article was standardized and implemented by Gematik GmbH under the direction of GKV Spitzenverband.
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Healthcare providers in Germany need to be registered with GKV Spitzenverband to serve members of public health
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insurance providers. Since these public providers constitute approximately 90% market share, the vast majority of
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healthcare providers are registered this way.
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## Design principles
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## Cryptographic design
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## The implied adversary model
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While Gematik GmbH publishes detailed specifications of the systems they standardize, these specifications and some
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associated implementation guidelines are about the extent of public information. Software implementations are being kept
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secret, and while standardization results are available, a large fraction of design rationale is discussed behind closed
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doors. From an academic perspective, the most glaring omission in Gematik GmbH's public documents is any definition of a
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threat model or an adversary model. As a result of this, we will deduce an adversary model below by contextualizing the
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published standards in the national healthcare setting. We will base our further analysis of the system on this
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adversary model.
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## Previous reviews and audits of the system
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[0] https://www.destatis.de/DE/Themen/Arbeit/Arbeitsmarkt/Qualitaet-Arbeit/Dimension-2/krankenversicherungsschutz.html
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