April 15, 2002
by Bruce Schneier
Founder and CTO
Counterpane Internet Security, Inc.
A free monthly newsletter providing summaries, analyses, insights, and commentaries on computer security and cryptography.
Back issues are available at <http://www.schneier.com/crypto-gram.html>. To subscribe, visit <http://www.schneier.com/crypto-gram.html> or send a blank message to email@example.com.
Copyright (c) 2002 by Counterpane Internet Security, Inc.
In this issue:
- How to Think About Security
- Crypto-Gram Reprints
- Is 1024 Bits Enough?
- Counterpane News
- Liability and Security
- Comments from Readers
If security has a silly season, we're in it. After September 11, every two-bit peddler of security technology crawled out of the woodwork with new claims about how his product can make us all safe again. Every misguided and defeated government security initiative was dragged out of the closet, dusted off, and presented as the savior of our way of life. More and more, the general public is being asked to make security decisions, weigh security tradeoffs, and accept more intrusive security.
Unfortunately, the general public has no idea how to do this.
But we in computer security do. We've been doing it for years; we do it all the time. And I think we can teach everyone else to do it, too. What follows is my foolproof, five-step, security analysis. Use it to judge any security measure.
Step one: What problem does the security measure solve? You'd think this would be an easy one, but so many security initiatives are presented without any clear statement of the problem. National ID cards are a purported solution without any clear problem. Increased net surveillance has been presented as a vital security requirement, but without any explanation as to why. (I see the problem not as one of not having enough information, but of not being able to analyze and interpret the information already available.)
Step two: How well does the security measure solve the problem? Too often analyses jump from the problem statement to a theoretical solution, without any analysis as to how well current technology actually solves the problem. The companies that are pushing automatic face recognition software for airports and other public places spend all their time talking about the promises of a perfect system, while skipping the fact that existing systems work so poorly as to be useless. Enforcing a no-fly zone around a nuclear reactor only makes sense if you assume a hijacker will honor the zone, or if it is large enough to allow reaction to a hijacker who doesn't.
Step three: What other security problems does the measure cause? Security is a complex and inter-related system; change one thing and the effects ripple. If the government bans strong cryptography, or mandates back-doors, the resultant weaker systems will be easier for the bad guys to attack. National ID cards require a centralized infrastructure that is vulnerable to abuse. In fact, the rise of identity theft can be linked to the increased use of electronic identity. Make identities harder to steal through increased security measures, and that will only make the fewer stolen identities more valuable and easier to use.
Step four: What are the costs of the security measure? Costs are not just financial, they're social as well. We can improve security by banning commercial aircraft. We can make it harder for criminals to outrun police by mandating 40 mph speed maximums in automobiles. But these things cost society too much. A national ID card would be enormously expensive. The new rules allowing police to detain illegal aliens indefinitely without due process cost us dearly in liberty, as does much of the PATRIOT Act. We don't allow torture (officially, at least). Why not? Sometimes a security measure, even though it may be effective, is not worth the costs.
Step five: Given the answers to steps two through four, is the security measure worth the costs? This is the easy step, but far too often no one bothers. It's not enough for a security measure to be effective. We don't have infinite resources. We don't have infinite patience. As a society, we need to do the things that make the most sense, that are the most effective use of our security dollar.
Some security measures pass these tests. Increasing security around dams, reservoirs, and other infrastructure points is a good idea. Not storing railcars full of hazardous chemicals in the middle of cities should have been mandated years ago. New building evacuation plans are smart, too. These are all good uses of our limited resources to improve security.
This five-step process works for any security measure, past, present, or future:
1) What problem does it solve?
2) How well does it solve the problem?
3) What new problems does it add?
4) What are the economic and social costs?
5) Given the above, is it worth the costs?
When you start using it, you'd be surprised how ineffectual most security is these days. For example, only two of the airline security measures put in place since September 11 have any real value: reinforcing the cockpit door, and convincing passengers to fight back. Everything else falls somewhere between marginally improving security and a placebo.
Natural Advantages of Defense: What Military History Can Teach Network Security, Part 1
Microsoft Active Setup "Backdoor":
Cryptography: The Importance of Not Being Different:
Threats Against Smart Cards:
Attacking Certificates with Computer Viruses:
Last month I wrote about Dan Bernstein's factoring research, and how it might affect RSA key lengths. Recently there's been a discussion on BugTraq, as cypherpunk Lucky Green cited the research as his primary motivation for revoking his 1024-bit PGP keys.
This brings up the interesting question: are 1024-bit RSA keys insecure, and what should we do about them?
The current public factoring record is 512 bits, using general purpose computers. Prudence requires us to suspect that institutions like the NSA can do better, although we don't know how much better.
Way back in 1995, I estimated key lengths required to be secure from different adversaries: individuals, corporations, and governments (Applied Cryptography, 2nd Edition, table 7.6, page 162). Back then I suggested that people migrate towards 1280-bit keys, and even 1536-bit keys, if they were concerned about large corporate or government adversaries:
|Recommended Public-Key Key Lengths (in bits)|
Looking back on those numbers written seven years ago, I think they were conservative but not unduly so. Factoring, at least in the academic community, has not progressed as fast as I expected it to. But mathematical progress is bursty, and a single breakthrough could more than make up for lost time. So if I were making recommendations today, I would still stand by my 2000 estimates above.
I have long believed that a 1024-bit key could fall to a machine costing $1 billion. And that a 1024-bit RSA key is approximately equivalent to a 80-bit symmetric key. (In Applied Cryptography, I wrote that a 768-bit RSA key is equivalent to an 80-bit symmetric key; that's probably too low an RSA key.)
Comparing symmetric and public-key keys is a lot like comparing apples and oranges. I recommend 128-bit symmetric keys because they are just as fast at 64-bit keys. That's not true for public-key keys. Doubling the key size roughly corresponds to a six-times speed slowdown in software. This might not matter with PGP, but it will make client-server applications like SSL slow to a crawl. I've seen papers claiming that you need 3072-bit RSA keys to correspond to 128-bit symmetric keys and 15K-bit RSA keys for 256-bit symmetric keys. This kind of thinking is ridiculous; the performance trade-offs and attack models are so different that the comparisons don't make sense.
But there's no reason to panic, or to dump existing systems. I don't think Bernstein's announcement has changed anything. Businesses today could reasonably be content with their 1024-bit keys, and military institutions and those paranoid enough to fear from them should have upgraded years ago.
To me, the big news in Lucky Green's announcement is not that he believes that Bernstein's research is sufficiently worrisome as to warrant revoking his 1024-bit keys; it's that, in 2002, he still has 1024-bit keys to revoke.
This discussion highlights the huge inertia in key rollover. Many people are still using short keys. Lucky Green's e-mail sheds a light on this phenomenon. He wrote "In light of the above, I reluctantly revoked all my personal 1024-bit PGP keys and the large web-of-trust that these keys have acquired over time." The web of trust attached to those keys was of great value, and reestablishing it with a new set of keys will be difficult and time-consuming. To Green, that pain was more important than having a "long enough" key.
Lucky Green's BugTraq announcement:
My essay on Bernstein's factoring paper:
Other essays on the Bernstein paper:
This is a novel idea. Two neural nets begin with secret random weights and then train on each other's output. Turns out they synchronize much sooner than can an observer who can only see the output but not affect it.
Has al Qaeda been hacked?
Spray-on microdots containing unique UIDs used to identity products:
The pathetic part is that it took this convict four years to invent the substitution cipher, and he didn't even think of breaking everything up into five-letter blocks.
The authors of the poorly named "Responsible Disclosure" RFC did the right thing. They withdrew their document from the IETF.
Meanwhile, Steve Bellovin and Randy Bush published a competing document.
The SSSCA has a new name now: The Consumer Broadband and Digital Television Promotion Act (CBDTPA). Sen. Hollings submitted the bill. It's still a disaster for the computer industry.
eBay is being criticized for not using SSL to secure their more sensitive Web pages. Honestly, I think this is mostly besides the point. eBay's weaknesses are not based around people eavesdropping on Web traffic; they're based on vulnerabilities in their Web servers, insecure passwords, etc. While using SSL is probably a good idea, it would significantly hit their performance. I don't think this is significant enough to worry about.
Latest news on the FBI's Carnivore eavesdropping software (now with the more friendly name DCS-100):
A good essay on the implications of what Brilliant Digital has done by spreading their Trojan with KaZaA:
Decent article on cyberterrorism:
The 2002 CSI/FBI Computer Crime Survey has been released. This is a great study, now in its seventh year. Almost all of the scary statistics that appear in the press about computer crime come from this survey. You owe it to yourself to read the original data.
I wrote more about the survey, its strengths and limitations, last year:
CERT's top six attack trends. A good essay to read.
Guidelines for securing Windows 2000:
"Free Speech Online and Offline," by Ross Anderson. Excellent essay and a good European perspective on a UK export bill.
NSA Security Recommendation Guides:
Counterpane has announced its Q1 results. 30 billion network events monitored and analyzed. 57,000 potential intrusions researched. 10,000 intrusions detected and prevented. Attack success rate while Counterpane was watching: 0.006%. Attacks that succeeded long enough to cause damage while Counterpane was watching: 0.00%.
Counterpane's success in defending networks is the subject of a Business Week article:
And this article in Internet Week:
These are both good articles, because they quantitatively show the benefits of Counterpane monitoring.
Counterpane Managed Security Monitoring now available in Latin America:
The Stanford Law School Center for Internet and Society is holding a one-day Conference on Cyber Security and Disclosure, May 9 at Stanford. Schneier is delivering the luncheon talk.
Schneier will be presenting Counterpane's solution in Baltimore, Dallas, Denver, New York, Sacramento, Salt Lake City, and Tallahassee. If you would like to attend, sign up here:
Today, computer security is at a crossroads. It's failing, regularly, and with increasingly serious results. I believe it will improve eventually. In the near term, the consequences of insecurity will get worse before they get better. And when they get better, the improvement will be slow and will be met with considerable resistance. The engine of this improvement will be liability -- holding software manufacturers accountable for the security and, more generally, the quality of their products -- and the timetable for improvement depends wholly on how quickly security liability permeates cyberspace.
Network security is not a problem that technology can solve. Security has a technological component, but businesses approach security as they do any other business risk: in terms of risk management. Organizations optimize their activities to minimize their cost * risk product, and understanding those motivations is key to understanding computer security today.
For example, most organizations don't spend a lot of money on network security. Why? Because the costs are significant: time, expense, reduced functionality, frustrated end users. On the other hand, the costs of ignoring security and getting hacked are small: the possibility of bad press and angry customers, maybe some network downtime, none of which is permanent. And there's some regulatory pressure, from audits or lawsuits, that add additional costs. The result: a smart organization does what everyone else does, and no more.
The same economic reasoning explains why software vendors don't spend a lot of effort securing their products. The costs of adding good security are significant -- large expenses, reduced functionality, delayed product releases, annoyed users -- while the costs of ignoring security are minor: occasional bad press, and maybe some users switching to competitors' products. Any smart software vendor will talk big about security, but do as little as possible.
Think about why firewalls succeeded in the marketplace. It's not because they're effective; most firewalls are installed so poorly as not to be effective, and there are many more effective security products that have never seen widespread deployment. Firewalls are ubiquitous because auditors started demanding firewalls. This changed the cost equation for businesses. The cost of adding a firewall was expense and user annoyance, but the cost of not having a firewall was failing an audit. And even worse, a company without a firewall could be accused of not following industry best practices in a lawsuit. The result: everyone has a firewall, whether it does any good or not.
Network security is a business problem, and the only way to fix it is to concentrate on the business motivations. We need to change the costs; security needs to affect an organization's bottom line in an obvious way. In order to improve computer security, the CEO must care. In order for the CEO to care, it must affect the stock price and the shareholders.
I have a three-step program towards improving computer and network security. None of the steps have anything to do with the technology; they all have to do with businesses, economics, and people.
Step one: enforce liabilities. This is essential. Today there are no real consequences for having bad security, or having low-quality software of any kind. In fact, the marketplace rewards low quality. More precisely, it rewards early releases at the expense of almost all quality. If we expect CEOs to spend significant resources on security -- especially the security of their customers -- they must be liable for mishandling their customers' data. If we expect software vendors to reduce features, lengthen development cycles, and invest in secure software development processes, they must be liable for security vulnerabilities in their products.
Legislatures could impose liability on the computer industry, by forcing software manufacturers to live with the same product liability laws that affect other industries. If software manufacturers produced a defective product, they would be liable for damages. Even without this, courts could start imposing liability-like penalties on software manufacturers and users. This is starting to happen. A U.S. judge forced the Department of Interior to take its network offline, because it couldn't guarantee the safety of American Indian data it was entrusted with. Several cases have resulted in penalties against companies who used customer data in violation of their privacy promises, or who collected that data using misrepresentation or fraud. And judges have issued restraining orders against companies with insecure networks that are used as conduits for attacks against others.
However it happens, liability changes everything. Currently, there is no reason for a software company not to offer more features, more complexity. Liability forces software companies to think twice before changing something. Liability forces companies to protect the data they're entrusted with.
Step two: allow parties to transfer liabilities. This will happen automatically, because this is what insurance companies do. The insurance industry turns variable-cost risks into fixed expenses. They're going to move into cyber-insurance in a big way. And when they do, they're going to drive the computer security industry...just like they drive the security industry in the brick-and-mortar world.
A company doesn't buy security for its warehouse -- strong locks, window bars, or an alarm system -- because it makes it feel safe. It buys that security because its insurance rates go down. The same thing will hold true for computer security. Once enough policies are being written, insurance companies will start charging different premiums for different levels of security. Even without legislated liability, the CEO will start noticing how his insurance rates change. And once the CEO starts buying security products based on his insurance premiums, the insurance industry will wield enormous power in the marketplace. They will determine which security products are ubiquitous, and which are ignored. And since the insurance companies pay for the actual liability, they have a great incentive to be rational about risk analysis and the effectiveness of security products.
And software companies will take notice, and will increase security in order to make the insurance for their products affordable.
Step three: provide mechanisms to reduce risk. This will happen automatically, and be entirely market driven, because it's what the insurance industry wants. Moreover, they want it done in standard models that they can build policies around. They're going to look to security processes: processes of secure software development before systems are released, and processes of protection, detection, and response for corporate networks and systems. And more and more, they're going to look towards outsourced services.
The insurance industry prefers security outsourcing, because they can write policies around those services. It's much easier to design insurance around a standard set of security services delivered by an outside vendor than it is to customize a policy for each individual network.
Actually, this isn't a three-step program. It's a one-step program with two inevitable consequences. Enforce liability, and everything else will flow from it. It has to.
Much of Internet security is a common: an area used by a community as a whole. Like all commons, keeping it working benefits everyone, but any individual can benefit from exploiting it. (Think of the criminal justice system in the real world.) In our society we protect our commons -- our environment, healthy working conditions, safe food and drug practices, lawful streets, sound accounting practices -- by legislating those goods and by making companies liable for taking undue advantage of those commons. This kind of thinking is what gives us bridges that don't collapse, clean air and water, and sanitary restaurants. We don't live in a "buyer beware" society; we hold companies liable for taking advantage of buyers.
There's no reason to treat software any differently from other products. Today Firestone can produce a tire with a single systemic flaw and they're liable, but Microsoft can produce an operating system with multiple systemic flaws discovered per week and not be liable. This makes no sense, and it's the primary reason security is so bad today.
From: Bancroft Scott <baososs.com>
Subject: SNMP Vulnerabilities
ASN.1, like any other language, can be implemented correctly or incorrectly. As can be seen from the CERT advisory, <http://www.cert.org/advisories/CA-2002-03.html>, there are many implementations of SNMP that have no vulnerabilities, and many which do. This fact by itself shows that the vulnerabilities lie with the implementations, not with ASN.1 or BER, for both flawed and flawless SNMP applications implement the same protocol and were subject to the same tests from Oulu University.
It is critical that all network applications, whether they use ASN.1 or not, be fully tested. E-mail programs have been known to have more than their share of bugs, but it would be wrong to state that the e-mail protocol (SMTP) is flawed; it is e-mail implementations that are flawed. Protocols that use ASN.1 are no different; it is wrong to conclude that applications that use ASN.1 are likely to be vulnerable. If applications that use ASN.1 are properly implemented and tested they are as safe as any other properly implemented and tested application.
From: Alessandro Triglia <sandromclink.it>
Subject: SNMP Vulnerabilities
I was very concerned with the results of the tests performed by the University of Oulu, which show that a very large number of existing SNMP implementations are vulnerable to various types of attacks.
However, I disagree with your statement that "The vulnerabilities [...] stem from problems in the reference code (probably) used inside the Abstract Syntax Notation (ASN.1) and Basic Encoding Rules (BER)."
The conclusions of the Oulu report are that "implementation errors plague several SNMP products." There is no suggestion or implication that the standardized ASN.1 encoding rules may be responsible for the existence of such defects in the products. The Oulu report talks very clearly about "implementation errors."
Also note that there is no such thing as a "reference code" in the ASN.1 standards. Many ASN.1 toolkits exist, both free and commercial, and implementers may also choose to implement their own BER decoder by hand, if they so wish. In any case, implementers are entirely responsible for the quality, standard-compliance, and robustness of their products.
The Oulu test report discovered defects in many SNMP implementations. These defects are situated both at the SNMP protocol application level and at the BER decoder level. Blaming the ASN.1 and BER standards for a defect in the implementation of the decoder is as inappropriate as blaming a protocol standard for any defects in the implementation of the protocol.
In other words, it is not appropriate to draw from the Oulu report the conclusion that the ASN.1 and BER standard may be, in some way, responsible for some intrinsic vulnerability of a BER decoder implementation. Any existing system vulnerability is the consequence of a non-compliant (or not robust enough) implementation, either of the protocol or of the encoder/decoder.
As a further consideration, I believe it is totally inappropriate to deduce that a security threat exists in other protocols that are defined in ASN.1. A security threat may exist in protocol implementations, of course, if the implementations have not been built correctly and have not been sufficiently tested against all the possible attacks.
Subject: SNMP vulnerabilities
I was part of the official communications between CERT and an affected vendor, so there is much that is part of that confidential exchange I cannot go into. However I did write to CERT expressing concern at the "further delays to this already long overdue advisory."
CERT has a published disclosure policy: "All vulnerabilities reported to the CERT/CC will be disclosed to the public 45 days after the initial report, regardless of the existence of availability of patches or workarounds from affected vendors. Extenuating circumstances, such as active exploitation, threats of an especially serious (or trivial) nature, or situations that require changes to an established standard may result in earlier or later disclosure."
The only exception being: "Threats that require 'hard' changes (changes to standards, changes to core operating system components) will cause us to extend our publication schedule."
From what I saw at the time the SNMP issues did not involve a change to a standard or a change to a core operating system component and therefore should not have received any special treatment.
I did ask CERT for a detailed response as part of the public announcement outlining why the delays were necessary and the consequences to their published disclosure policy. If you are contacting CERT for a comment I'd be asking them that question again and looking at the numerous leaks that occurred before the official release.
From: "Bernd Kreimeier" <bkoddworld.com>
Subject: an overlooked aspect of SSSCA/CBDTPA
I believe that the implications of the CBDTPA reach far beyond practicality or fair use, and take the inherent conflict between first amendment and copyright to a new level which is unacceptable for a free society. This is not just a consumer rights issue, it is a question of civil liberties, and institutional safeguards.
This initiative mandates a technology that, once installed, will permit ubiquitous surveillance of information transfer, and is fundamentally at odds with encrypted transmissions.
From the point of view of constitutional safeguards, a case can be made that permitting (much more so demanding) such a technology is in direct conflict with a framework that spawned such (for a European's eye extreme) measures as the second amendment's "right to keep and bear arms," to protect the people against a perceived possibility of a totalitarian regime of domestic or foreign origin.
In the late 70's, a German professor of law, Prof. Alexander Rossnagel made a case against a nuclear fuel cycle based on "breeding" weapon-grade plutonium, on grounds that the security requirements of large scale use of such a technology, and the resulting legal and institutional changes for law enforcement (in particular because of the risk-driven shift to incident prevention), were incompatible with the foundations of a free society.
I believe a similar case can be made with respect to the SSSCA/CBDTPA, and the positions publicly taken by the bill's sponsors and supporters (e.g. with respect to intercepting "legacy piracy").
In particular, it is once again the shift to prevention that is a clear indicator of an extension of the concept of law enforcement beyond what can be accepted in a democratic society.
Scott Tousley <Scott.Tousley@anser.org>
Subject: Full-Disclosure Essay
Re the "Nice essay on the full disclosure debate":
I think you fail to point out the hidden motives that might be behind a vote for full disclosure from the legal community. The author states that the "the best defense to legal action in the IT product security setting is proof that the manufacturer followed security best practices." But corporate and/or provider practices can and will be argued by trial lawyers at great expense, because nothing can be perfectly implemented, least of all ill-defined best practices.
Also, I note the author's convenient linkage of attacker and provider/source ("If a hack attack, by its nature unsolicited and unwanted, can lead to liability for the problem being found against the ISP in question -- where does the willful non disclosure of a potential flaw leave a Microsoft or an AOL?"), and it seems to me again a trial lawyer's attitude where someone must be found legally and hence financially responsible (else where is a hard working lawyer to find a return on his legal business?).
Finally, "There are always practical limits to the baring of the corporate soul when an error is identified, but reticence that crosses the border into the realm of withholding information that would assist consumers in protecting themselves, is a compounded sin. At the very least, reticence illustrates a measure of corporate disdain for the consuming public." Fancy words, but again, I see the motivation as mostly if things are kept quiet, it is that much harder for the legal business to grow this new liability business area.
From: Gwendolynn ferch Elydyr <gwenreptiles.org>
Subject: Re: CRYPTO-GRAM, March 15, 2002
>Hacking is judo: using network software to do things
>it was never intended to do.
Being completely pedantic, Aikido would probably be a better comparison than Judo. Although they both involve redirection of force, Aikido has a much greater focus on redirecting your opponent (and then getting away) than Judo, which tends to result in both parties rolling around on the floor wrestling.
From: Stefan Lucks <lucksweisskugel.informatik.uni-mannheim.de>
Subject: Re: Liability and Security
I enjoyed reading the essay, and I agree with most of it. Enforcing liability can be a crucial point to improve computer and network security. However, I am missing another crucial point, namely responsibility.
Large organizations may be able to hire the computer security experts they need for a sound risk management and a responsible security policy. But this does not scale well for small organizations and individuals.
Without the ordinary user being able to make reasonable decisions about risk avoidance and risk acceptance, computers and networks are insecure. This ability is what I mean by responsibility.
Liability depends on responsibility. (This is an oversimplification. Think of it as a general principle.) If you sell your house, and sometime later a tiny asteroid hits the earth, smashes the house and kills the buyer, you wont be hold liable. (I am not a lawyer, but would hope so! ;-)) You did not know about the asteroid, you could not have known about it, and you would not have been able to protect the house against the asteroid.
In the physical world, people understand basic security issues, such as how to lock a door, and what it means to lock it or to leave it open. I am free to leave my home without locking the door, and I know about the risk of doing so. (If someone breaks in, my insurance wont pay.)
In the digital world, things are quite different today. How many ordinary users understand simple computer security issues, as e.g. the following?
- When opening a Word document from someone else, one may actually execute some potentially malicious code (a word-virus or a word-worm such as ILOVEYOU).
- The e-mail from my.girlfriend.net may actually be sent by an adversary, such as my.girlfriends.exlover.com.
- When you send a Word document you have written, you may reveal much more to the receiver than you can see yourself when you print the document. WYSIWYG (What You See Is What You Get)? Nonsense, you may get much more than what is shown to you by default, if you know where to look. (A Word document may contain the entire history of its changes.)
So problems are
1. Bad user interfaces (from a security point of view), and
2. Users not understanding security issues.
Thus, we need improved user interfaces, but also the users will have to gain some knowledge about computer and Internet security. This is not much different from people learning the concept of a key and of house security (which happened in Europe at the time of the industrial revolution, I believe) when this was new.
Liability may force software producers to improve their user interface, but this is only the first step, and the users will have to do the second.
CRYPTO-GRAM is a free monthly newsletter providing summaries, analyses, insights, and commentaries on computer security and cryptography. Back issues are available on <http://www.schneier.com/crypto-gram.html>.
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CRYPTO-GRAM is written by Bruce Schneier. Schneier is founder and CTO of Counterpane Internet Security Inc., the author of "Secrets and Lies" and "Applied Cryptography," and an inventor of the Blowfish, Twofish, and Yarrow algorithms. He is a member of the Advisory Board of the Electronic Privacy Information Center (EPIC). He is a frequent writer and lecturer on computer security and cryptography.
Counterpane Internet Security, Inc. is the world leader in Managed Security Monitoring. Counterpane's expert security analysts protect networks for Fortune 1000 companies world-wide.
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Schneier on Security is a personal website. Opinions expressed are not necessarily those of Co3 Systems, Inc..