Synthesis of Draft
In short, the draft covers the following subjects:
- Maintaining privacy of the user
- Non-interference with legitimate traffic
- Recommendation for types of tools
- Challenge of "definitive vs. likely" in informing user
- Dealing with user complaints
- Sharing of bot information with other ISPs
- Use of Honeynets
- Informing users:
- Postal Mail
- "Walled Garden"
- Web browser message
- Guided Remediation
So for me this actually brings up a couple of questions. First of all, who's responsible for a bot on the network? And second, what is actually going to work in a situation like this?
If there is a bot -- or really, any malicious piece of code -- on a user's personal system, who is responsible for discovering and/or remediating it? Unfortunately, it's not obvious. The user, obviously, owns all of his computers and networking equipment, up to and in some cases including the DSL or cable modem. That said, the ISP owns the actual connectivity. The ISP also will also get the black eye if malicious packets are coming through its networks, for example, if computers on the ISP's networks are used in DDoS attacks. The hope is that the ISP would have found and remediated the malicious code before that happens, but how far can (and should) the ISP go in the attempt to do so?
What Actually Works
The draft, in discussing options for informing users, talks about a "walled garden". What a "walled garden" does is place the user's account in some degree of isolation from the rest of the network, cutting off access to some or all services. The presumption is that the user will notice that his access is cut off and will contact the ISP, initiating a dialog that can lead to remediation. The draft mentions that the walled garden can persist until the problem is remediated, or it can be lifted as soon as the user has been informed of the malicious code.
In my opinion, the walled garden should actually serve the following multiple purposes:
- Inform the user of a potential bot or malware based on the ISP's scanning (etc.) activity;
- Remain as a safety net while the ISP and the user dialog about further malware scanning and remediation, and begin that process;
- If the malware is found to actually exist, remain as a continued safety net until everything has been done, by both the ISP and the user, to remediate the situation.
In other words, keep the user's account isolated to at least some degree until the problem is fixed. Obviously, this is not going to be something that users will necessarily like, especially if they don't understand what's going on. And here is where I think ISPs need to take more responsibility, from the start, when user first sign up for Internet service.
In general, ISPs sign users up for Internet service, and then they just let them go. For users like myself, who know what they're doing on a network, and just want to be left alone, this is a pretty good option. But any user can become the victim of malicious code, no matter how sophisticated they are, and I think that ISPs are letting users down when they don't try to educate them about malware and what it can do. Just providing users with a CD of "connection" software, which may or may not contain AV and antispyware tools at a minimum, is not enough to fulfill an ISP's responsibility to keep bots and malware from reinfecting the Internet from its users' machines.
That's why I think the extended walled garden approach is necessary, combined with the ISP stepping in and helping the user confirm the presence of the malware and then help them remove it. But I also think that the ISP has to take more responsibility up front, to help the user understand what malware is, what it can do, and what to do to mitigate possible threats. In other words, I like the draft as far as it goes, but I think that it doesn't go far enough.