Final spell pass using grammarly
grammarly is pretty garbage
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paper.tex
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paper.tex
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@ -78,18 +78,17 @@ paper-based workflows that are error-prone and lead to healthcare providers ofte
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patient's medical records. Data in scope for the system includes medical letters, laboratory results, and medical
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imaging files.
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Due to Germany's mandatory health insurace laws, the system's user base encompasses the majority of all German
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residents. People who have replaced their public health insurance with private insurance currently are not subject to
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Due to Germany's mandatory health insurance laws, the system's user base encompasses the majority of all German
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residents. People who have replaced their public health insurance with private insurance as of now are not subject to
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the system. In Germany, by law private health insurance is only available to people from the top 10th percentile of
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household income. This means that the system disproportionally affects people who have low income, creating an equity
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issue. While it is possible to opt out from the use of the system, the process of opting out is difficult. Additionally,
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both the government through advertising campaigns and health insurance providers have publically depicted the system in
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a one-sidedly positive way, meaning that it is unlikely the majority of people subject to the system have a
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comprehensive understanding of the system's benefits and risks that would be necessary for an informed decision on
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opting out.
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the government and health insurance providers have publically depicted the system in a one-sidedly positive way, meaning
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that it is unlikely the majority of people subject to the system have a comprehensive understanding of the system's
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benefits and risks that would be necessary for an informed decision.
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While there has been loud criticism of the system's security from civil society organizations such as digital rights
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nonprofit organization Chaos Commputer Club (CCC) \cite{kochMoreMoreExperts2025} and several severe security flaws have
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nonprofit organization Chaos Computer Club (CCC) \cite{kochMoreMoreExperts2025} and several severe security flaws have
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been demonstrated practically, this criticism has largely been ignored by the political structures in charge. We observe
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that despite this civil society outrage and the system's large scale, it has received little attention from the academic
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cryptography and information security community.
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@ -108,26 +107,26 @@ bits of entropy\footnote{
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}. Finally, we note that according to specification, the only physical security requirement for the protection of this
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highly sensitive secret is a ``hard, opaque potting material'', with no tamper detection and response required.
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We base our analysis on the system's publicly available standards in their latest version as of writing of this paper in
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April 2025, describing version 3.0 of the healthcare record system \cite{
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We base our analysis on the system's publicly available standards in their latest version as of the writing of this
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paper in April 2025, describing version 3.0 of the healthcare record system \cite{
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gematikSpezifikationAktensystemEPA2025,
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gematikUbergreifendeSpezifikationVerwendung2024,
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}. We note that the implementation might well deviate from these standards and be more secure - however, with the
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system's history of flaws, we believe that is unlikely to be the case and the reference implementation provided by the
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specification authority \cite{GithubRepositoryERPFD} follows the standards' minimum requirements closely. As of now,
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}. We note that the implementation might well deviate from these standards and be more secure--however, with the
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system's history of flaws, we believe this is unlikely to be the case. The reference implementation provided by the
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specification authority \cite{GithubRepositoryERPFD} follows the specified minimum requirements closely. As of now,
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there is no meaningful way for either the public or for researchers such as us to ascertain the concrete implementation
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security of the system.
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\section{The Design of ePA}
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ePA is embedded into Germany's national public healtcare backend system ``Telematikinfrastruktur'' (TI). TI is a highly
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ePA is embedded into Germany's national public healthcare backend system ``Telematikinfrastruktur'' (TI). TI is a highly
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complex system, and a detailed description would exceed the limits of this paper. Briefly put, TI consists of a shared
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DMZ that parties like insurance providers and healthcare providers connect to through a VPN. At the client location,
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this VPN connection is created from a specialized VPN appliance named ``Konnektor'' that simultaneously hosts as a
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trusted environment executing some software for purposes such as authentication. The Konnektor hosts several smart cards
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that store keys used for authentication.
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this VPN connection is terminated by a specialized VPN appliance named ``Konnektor'' that simultaneously hosts a trusted
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environment executing some software for purposes such as authentication. The Konnektor hosts several smart cards that
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store keys used for authentication.
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Every person enrolled in the system as well as every healthcare professional providing services in it is issued a ID
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Every person enrolled in the system as well as every healthcare professional providing services under it is issued an ID
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card that contains a smart card that contains keys used to authenticate towards the central infrastructure. The primary
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use of these smart cards up to now is that when someone visits a healthcare provider, they will insert their ID card
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into a terminal so the healthcare provider can automatically fetch their personal information such as name, birth date,
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@ -148,7 +147,7 @@ encrypted records themselves. Records are symmetrically encrypted with keys that
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inside an HSM. While the current version of the standard is unclear on the exact mechanism of key derivation, in
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previous versions of the standard, the escrow service's root key, a random salt, and the healthcare ID number of the
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person owning the record was used in SHA256-HKDF. The specification requires that a new root key is generated once a
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year, but as far as we can tell, key rollover is not done automatically, but is only meant to be done when the
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year, but as far as we can tell, key rollover is not done automatically but is only meant to be done when the
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\emph{user} requests it, and old root keys must be retained forever to ensure old records can be accessed.
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\section{Related Work}
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@ -158,8 +157,8 @@ key escrow service. \textcite{fischlinKryptographischeAnalyseSpezifikation2021}
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dimension of the key escrow service used in an older version of the standard, and is now obsolete.
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\textcite{slanySicherheitsanalyseZurSicherheit2020} approaches the system at a higher level, and focuses on the
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cryptography of the inner protocol layers spoken between the system's components. Industry research organization
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Fraunhofer SIT were comissioned for a structured, theoretical assessment of attack paths to the
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system \cite{fraunhofersitAbschlussberichtSicherheitsanalyseGesamtsystems2024}. We are not currently aware of
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Fraunhofer SIT was comissioned for a structured, theoretical assessment of attack paths to the system
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\cite{fraunhofersitAbschlussberichtSicherheitsanalyseGesamtsystems2024}. We are not currently aware of
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independent academic security research on the system.
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The design and operation of the system have been independently described in detail by civil society activists, who have
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@ -177,9 +176,9 @@ more scrutiny.
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\subsection{Use of Key Escrow}
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First, the system's general approach of using a key escrow service instead of securely storing the keys inside the
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system's already existing smart card infrastructure is concerning, given that this key escrow service poses as a
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system's already existing smart card infrastructure is concerning, given that this key escrow service poses a
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centralized security risk. The system's designers made this decision since it was deemed important that access to an
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encrypted record can be restored quickly after an insurance ID card is lost, without requiring cooperation of the
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encrypted record can be restored quickly after an insurance ID card is lost, without requiring the cooperation of the
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healthcare providers holding the primary copies of the person's medical records.
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While key escrow services have been a topic of political debate in decades past, in the cryptographic community,
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@ -195,7 +194,7 @@ surface \cite{
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The system's overall cryptographic design is intentionally kept simple. The standard explicitly mentions that symmetric
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primitives have been preferred over asymmetric primitives in the core key escrow functions due to the risk of an attack
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on asymmetric primitives in the long term. Notably, other advanced cryptographic techniques such as secret sharing
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schemes, oblivious pseudo-random functions or multiparty computation that could help with the security and privacy of
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schemes, oblivious pseudo-random functions, or multiparty computation that could help with the security and privacy of
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the key escrow service are also absent while the system relies extensively on the engineering-based security guarantees
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of TEEs and HSMs.
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@ -218,8 +217,8 @@ attacks on national digital infrastructure are a realistic concern.
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Physical security has received some consideration in the system's specification. First, smart cards are used extensively
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for authentication. Second, Hardware Security Modules are used in key locations of the system to process some
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cryptographic secrets. The core of the system's key escrow sevice is implemented inside an HSM. However, it is notable
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that the actual security level required of this HSM is only FIPS 140-2 level
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cryptographic secrets. The core of the system's key escrow service is implemented inside an HSM. However, it is notable
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that the actual security level required for this HSM is only FIPS 140-2 level
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3 \cite{usnationalinstituteofstandardsandtechnologySecurityRequirementsCryptographic2002}. Not only has FIPS 140-2
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been superseded by FIPS 140-3 since
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2019 \cite{usnationalinstituteofstandardsandtechnologySecurityRequirementsCryptographic2019}, its security level 3 mostly
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@ -229,8 +228,8 @@ coating is specified to be tamper-evident, but notably no active tamper detectio
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this standard. In contrast to the newer FIPS 140-3 standard and the related ISO/IEC 19790 \cite{ISOIEC19790} as well as
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ISO/IEC 24759 \cite{ISOIEC24759} standards, FIPS 140-2 does not make any particular requirements regarding resistance to
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side-channel attacks. The lack of tamper response, unspecified resistance to side-channel attacks and the fact that the
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ePA specification only requires the long-lived key escrow root key inside the HSM to have 256 bit of security lead to an
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unsatisfactory overall constellation.
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ePA specification only requires the long-lived key escrow root key inside the HSM to have 256 bits of security lead to
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an unsatisfactory overall constellation.
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\section{Conclusion}
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@ -239,7 +238,7 @@ standardization and implementation process, several cryptographic compromises en
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Even assuming that nation-scale key escrow is a good idea, the implementation of this key escrow system seems to stray
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from current best practice. The system uses a secret key with only 256 bits of entropy to derive highly sensitive secret
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keys for potentially tens of millions of people sharing an insurance provider. The cryptographic design of this escrow
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system is unsophisticated, ignoring the past three decades in crytographic developments in particular in multiparty
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system is unsophisticated, ignoring the past three decades in cryptographic developments particularly in multiparty
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computation (MPC) and other secret sharing techniques in favor of an engineering approach. In the engineering dimension,
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the system's physical security is only held to the basic level 3 of the obsolete FIPS 140-2 standard, which is
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considerably less secure than an average credit card payment terminal. The system's root keys are only protected by a
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