Emergency, which service ……..?

Most people are familiar with the process for making an emergency call - whether it is to the Police, Fire Service, Ambulance or Coastguard. Pick up a phone and dial 999 - or 112 as the pan-European common emergency call number.

When the call is answered by the emergency service operator at the telco, the operator will ask you which service you require and will ask you to confirm the number you are calling from. No problems there.

The operator will see the calling line number displayed in front of them and can immediately cross-reference with reverse look up to identify the location. OK, no problems there - but hold on a minute, what happens if you are not using a land-line?

Technology has moved on and there can no longer be an assumption that all users are calling from a fixed land-line. Emergency calls can be made from a mobile number and, increasingly, from a Voice over IP phone (VoIP). Now, these latter two present something of a problem. Mobile numbers are not geographic (they do not have a specific regional location exchange code) and can be made from pretty much anywhere (except in my house where the mobile does not work!). Emergency operators can access data from the mobile providers to locate the cell where the call is being made from - and triangulation from a number of base stations can provide a fairly accurate geographic location of the calling phone. That’s what law enforcement do when they want to track a criminal or suspect target - the mobile phone is a very effective piece of electronic tracking gadgetry sitting in your pocket. You don’t have to make a call, the phone will register itself with the local cell whenever it is switched on and will thereby giveaway its position.

OK, again, no real problems there. Problems arise with VoIP. There may be a number associated with a VoIP call but it may be a geographic number and the geographic number assigned to the call may bear no relevance to the actual geographic location of the VoIP handset or software. This may be connecting through any IP link - perhaps a fixed line broadband circuit or perhaps a WiFi connection in a public place (cafe, pub, airport etc.).

The Ofcom General Conditions of Service require providers to make details of callers available to emergency service operators. For fixed line and for mobile calls that is fine - the provider has all the data and can cross-reference databases. For VoIP there is a problem - the VoIP service is likely to be provided by a different service provider to the underlying IP transport. The VoIP provider may have a record of the geographic number associated with the call and may be able to reference that to a customer - but cannot tell whether or not the customer is at the location they have. The IP address used for the call and included within the packet data will be allocated by the ISP providing the transport layer - there may be no quick look-up between the VoIP provider and the ISP to determine the location and user of the IP address. It is quite possible that the VoIP user could log in from a range of IPs during a single day - particularly if they are connecting using WiFi access points.

The problem can have tragic consequences. A Canadian family called the emergency services using a VoIP service - the trackback from their initial service registration indicated a location in Toronto so that was where the medical team was sent. Unfortunately the family were hundreds of miles away in Calgary and had not updated the location information held by the VoIP provider.

To overcome the problem the emergency services want to be able to make a quick look up request to ISPs to determine the telephone line reference (CBUK record) for the line on which the VoIP call originated. That might seem straightforward but the practicalities are much less so. There is no standard format for ISP customer service records and there is no standard interface that will allow an external agency to access and requues information from those databases. Emergency service developers have suggested that ISPs should install systems that will allow real-time look-up requests from the emergency service operator. The operator would identify the call as a VoIP origin, identify the associated IP address, refer that to a central look-up registry to identify the ISP (RIPE?) and then pass the request to the ISP who would be expected to return the CBUK reference for the line. All this in real-time and in no longer than it has taken you to read this last paragraph.

The implementation of the Data Retention Directive at a European level has meant that there have been developments to create a standardised form of data request - ETSI standards. Implementing these may be fine for the larger operators who have teams of developers and can bear the costs. But for the medium and smaller level ISPs there will be a real problem - substantial development costs and quite likely whole changes to back end and Internet facing systems. It is quite likely that the smaller ISPs will simply not have the resources to be able to comply.

The Crusher can see another problem here. Once an interface system is in place then a remote operator will be able to input an IP address and return a telephone line reference which can be used to determine a location. That is exactly the type of information that typical Section 22 notices issued under the Regulation of Investigatory Powers Act (RIPA) often require - law enforcement agencies can issue a notice requiring an ISP to provide details of a user. Requests often cite a date, time and IP address - and require the ISP to identify the user. If that can be done automatically by the emergency operator then it will not be long before other parts of law enforcement agencies (LEAs) identify the route as a rapid way to investigative data. Politicians will trot out the tired old lines about importance for public safety, citizens have nothing to fear etc. And will then introduce legislative changes that permit LEAs to process automatic data requests.

Any development for emergency use will have to be developed with extensive safeguards and strict controls. These must ensure that access can only be made in genuine emergency situations and that it is not possible to investigators to access for alternate purposes. Equally, it must not be possible for other organisations to attempt to access data - for example, for rights owners to try to identify end users flagged up as potential copyright infringers.

The emergency request is fairly self-explanatory. The problem is the likelihood and the inevitability of mission creep.