A public controversy among computer security experts in China has erupted over the degree of national security assessment required in general and what specifically is required by the new Cybersecurity Law and related regulations. Ni Guangnan, an academician with the Chinese Academy of Engineering and a longstanding proponent of indigenous technology in China, recently argued (in a piece translated here) that the new Windows 10 China Government Edition should not be approved for government procurement because it has not yet formally passed the new law’s national security review process. Here, Wang Jun, lead engineer of the China Information Technology Security Evaluation Center (CNITSEC) which is a third-party review organization for the Chinese government, argues that the Microsoft-CETC joint venture behind the new custom Windows edition was developed in consideration of Chinese government security priorities and therefore should be given due consideration as “secure and controllable.” Wang also provides important insights into the degree to which the nascent national security review system has already started to operate and describes in detail his view of how the process is expected to work.
The following was translated from the Chinese original by Rogier Creemers, Paul Triolo, and Graham Webster.
Southern Metropolis Daily Original
Academician Ni Guangnan of the Chinese Academy of Engineering stated recently in a media article that the Windows 10 version for the Chinese government has not passed cybersecurity review, and should remain outside of the government procurement catalogue. What is cybersecurity review? How does this matter implement the regulatory system just established on 1 June, and what network products is it aimed at?
A Southern Metropolis Daily (SMD) journalist interviewed Wang Jun, General Engineer at the China Information Technology Security Evaluation Center (CNITSEC). Wang Jun has answered these questions from an expert perspective, he indicated that cybersecurity review has a set of activations and review procedures exclusive to itself, these are identical for domestic and foreign products, there is no difference.
Wang Jun indicated that cybersecurity should be discussed in an open environment. The Chinese government version of Windows 10 may be considered as a positive trial in order to resolve the objective requirements concerning operating systems inside China at present, and raising our own technological levels and capabilities.
The general security review for Window 10 has begun, the security review situation for the governmental version is hitherto not understood.
SMD: Has the Chinese Government version of Windows 10 undergone security review?
Wang Jun: The forerunner of the Chinese Government version of Windows 10 is the common version of Windows 10, it is a commercial product of Microsoft, and is the common version distributed worldwide. As I understand it, our country has already started its cybersecurity review (hereafter named security review) of the common version of Windows 10. CNITSEC is designated by the Cyberspace Administration of China, and has undertaken third-party evaluation work of the common version of Windows 10; but at present, I have not seen a decision by the controlling department concerning whether it passed or not.
With regard to whether the governmental version of Windows 10 is on the way towards cybersecurity review, I have not yet heard about the circumstances in this matter.
SMD: And what is the result of the third-party evaluation by CNITSEC of the common version of Windows 10?
Wang Jun: We have major conclusions in two areas: the first is that we have discovered that in comparison with Win8, Win7 and earlier operating systems, the security functions in Windows 10 have been improved substantially. Second, a number of security risk points still exist, in fact, in the common version of Windows 10. According to the work agreement, we are not yet able to reveal details.
SMD: Security review has only been determined by law in the past few years, did we have similar work before this?
Wang Jun: The cybersecurity review system was only finally established in 2016, but before that, similar work actually had been begun.
In 2003, the National Development and Reform Commission authorized CNITSEC to act as a national monitoring body, and represented China in concluding a Government Security Program agreement for source code inspection with Microsoft; this is a multilateral agreement, and Microsoft has concluded GSP agreements with many countries. Considering that a fair few national governments have security concerns with Microsoft operating systems, Microsoft agreed to, through the GSP program, open up source code in a small scale and with secrecy protection, but because this involved intellectual property protection, it only took place in in a small scale, and did not turn into open source. Microsoft, from its side, exhibited a positive attitude, and where we were concerned, this added a channel for understanding.
GSP is an agreement in which both sides are equal, and security review means that when there are risks in a product that may influence national security, we represent the country in conducting a review, and the scope of security review may be broadened.
SMD: Some experts say Windows 8 and Windows 10 use trustworthy technology; will this mean manufacturers have a strong controlling power over operating systems?
Wang Jun: I basically agree with this point of view, in the common Windows 10 operating system, the manufacturer has a very strong controlling power over the system. But the strengthening of this sort of controlling power may have a double-edged sword effect. If it is especially strong, it possibly may mean that user controllability over this system is weakened; on the other hand, if user controllability over operating systems is extremely strong, hackers can equally have these kinds of capabilities, and in this kind of situation, it may also bring new security risks, because of that, we need to find a point of balance.
Where China is concerned, the common version of Windows 10 is not a complete black box.
SMD. So where the Chinese government is concerned, Windows 10 is not a black box after all, right?
Wang Jun: Right. According to the GSP agreement, Microsoft has provided an opportunity to review source code, but as to what the details are that come up in review, these may only be made public with the agreement of both sides.
In the national security review process of the common version of Windows 10, our center has undertaken third-party evaluation work, in Beijing. It has also inspected and verified the source code of the common version. Furthermore, the scope of its review and verification of source code is broader than under the original GSP agreement.
SMD: Can one guarantee security through inspecting source code?
Wang Jun: Between conducting source code inspections and coming to a conclusion whether a product is safe or not, there is a lot of technical work that needs to be done. One cannot simply say that “I give you the source code to look at and so it is absolutely safe,” one should also not simply believe that technological monitoring means going through source code line by line.
SMD: What technical methods are required to reach a determination of security?
Wang Jun: Source code security examination is in fact one of the methods for the third-party evaluation part of cybersecurity review or information security evaluation, but it is not the only method. Determining the security of network products is a comprehensive process requiring multiple methods. For instance, monitoring program behavior in the real work environment is one evaluation method, as is reverse engineering of executable files.
There are also international common criteria (CC) for security examination of network products (if operating systems are considered a kind of product). CC are also an important reference indicator for our Evaluation Center’s product security evaluation.
Operating system source code can run as long as 100 million lines. How much to look at, what part to look at, and how to judge the code are decided according to objectives of the technology evaluator in the third party evaluation process. Reading every single line is perhaps ideal, but doing so would require an enormous amount of time and resources. On the other hand, from the perspective of a technology evaluator’s methods, looking at every line may not be necessary. But as evaluators we ask for 100 percent of the source code and then, starting from a foundation of analyzing the program’s structure and how it integrates with the user’s machine, we decide which modules specifically require examination and verification.
Cybersecurity reviews must be triggered by someone, and they do not separate domestic from international.
SMD: Are national cybersecurity reviews the same thing as “user testing” and “security testing”?
Wang Jun: Simply put, security reviews and technological evaluation or user evaluation are not the same thing. In the process of security review, however, technology evaluation or user evaluation may be included. Security reviews are about the possibility of network products and services influencing national security.
According to the Security Review Measures for Network Products and Services, the security review process must first be triggered, and the measures clearly enumerate several conditions for triggering. One is if relevant national authorities believe a type of product or service requires cybersecurity review. Two is if national trade associations recommend security review. Three is if the market reflects that it must be done. We believe the market includes the masses, users, etc.
As soon as someone suggests security review, a legally determined work procedure must be undertaken. This work procedure should be defined ahead of time by the competent national department. Security review is serious and important work that cannot be taken lightly and executed at a word; it requires a work procedure and official confirmation before beginning.
SMD: What is the work procedure for national cybersecurity reviews?
Wang Jun: In my understanding of the relevant laws and regulations, once it is initiated, there are several steps. First, a third-party evaluation organization appointed by the competent department undertake objective evaluation of the network product or service for requirements such as security, controllability, reliability, data validation (材料的真实性), user control of the product, etc.
At the same time, there is another set of work, for instance relevant examinations, background investigations, determination of whether there is any unfair competition or influence on the national economy and market. This comprehensive investigation can take place at the same time.
Once the technology evaluation and comprehensive investigation are complete, the results are be submitted to a committee of experts for opinions, independent examination, and judgment. The competent organ finally determines whether review has been passed. It cannot listen only to one side’s opinion, so it asks a high-level experts’ committee to submit judgment and opinions. We are all responsible for our own conclusions and work independently.
Finally, the cybersecurity review office synthesizes the views and reports up to the cybersecurity review committee, which issues the result of the security review.
SMD: Does national cybersecurity review only target foreign network products?
Wang Jun: According to my understanding of the spirit of the Cybersecurity Law, the cybersecurity review does not distinguish between domestic and foreign, cybersecurity review does not have a nationality preference, and it’s not the case that foreign things are all examined while domestic things are not.
I believe that, it doesn’t matter if it’s Microsoft’s general use edition of Windows, the joint venture C&M Information Technology Co.’s Windows 10 China Government Edition, or another Chinese-made operating system. If the product needs to undergo relevant security review, according to the law- and regulation-decided procedure, they can all go through cybersecurity review. The legal requirements are the same.
Once technological evaluation or security investigation, the procedure, standards, and requirements are the same. Of course, different product circumstances may determine different emphases, but on the whole the requirements are the same.
“Developing Windows 10 China Government Edition was a kind of attempt”
SMD: Many people believe a Chinese operating system should replace [Windows]. As an expert, do you agree with this view?
Wang Jun: My own personal view is that our country has a portion of professions and fields that at this stage objectively need to use the Windows platform. Technologically, Windows is in some ways advanced, and it has formed an ecosystem. Many of our applications have developed a certain extent of dependency on the Windows system, and without saying whether this dependency is rational, it’s an objective fact. I understand that some professional users, including some in critical information infrastructure areas, would have difficulty simply switching to a non-Windows operating system.
Thus under these conditions, forcing switchover to non-Windows systems is not necessarily the best choice.
On the other hand, in the open environment, if we can ensure security and controllability of a piece of advanced foreign technology, we can at least say there’s no need to exclude it or decide not to use it.
SMD: How do you view Windows 10 China Government Edition?
Wang Jun: Windows 10 China Government Edition was jointly developed by China Electronics Technology Group (CETC) and Microsoft, and the C&M Information Technology Co. was set up with CETC holding 51% of shares and Microsoft holding 49%. According to my understanding, in their cooperation, Microsoft is willing to open source code under the condition that intellectual property is protected. I believe developing Windows 10 or another later government-use edition in this method is a positive and meaningful attempt.
We understand the goal of this method is to try to give government and critical information infrastructure users an improved edition that suits Chinese users’ security requirements better than the general edition. This is a way to explore new solutions to problems at this stage. I think it’s something to look forward to.
SMD: Do you think that developing a Windows 10 Chinese government version and developing a domestic operating system is not contradictory?
Wang Jun: For the R&D of a domestic operating system, plus the time required to put one into use, and packaging this to form an ecological environment requires a certain amount of time.
The use of the Windows 10 China Government-specific version, and the R&D and vigorous promotion of the application of a domestic operating system, including the construction of an ecological environment, can be carried out in parallel. In deciding whether or not to implement this parallel situation, it may well be worth considering the issue in terms of improving the degree of control over China’s cybersecurity, and the actual needs of users. We should allow this attempt in a tolerant manner.
Of course, this is for government departments and critical information infrastructure users. Other social users, and business users, must decide according to their own needs what kind of operating system to use.
A “Domestic system does not mean that it must be secure”
SMD: For domestic operating system security issues, what are your views? Is a domestic operating system secure?
Wang Jun: From a security point of view, domestic systems have some advantages compared to some foreign systems, but we cannot simply think that a domestic system must be secure. There are several reasons for this, first of all, any product has vulnerabilities, and vulnerabilities are a fundamental problem of cybersecurity, there is no certain security situation.
Second, some of our own domestically produced systems can be more reassuring in some aspects of security than for foreign products, for example, we do not have to worry about deliberate or passive implantation of malicious programs by the designer; but we may have gaps in terms of other aspects of security with other people, such as our understanding and mastering of security issues and anti-attack capabilities, there may be areas that we are not sufficient. The question of security is a comprehensive consideration.
Third, there are some equipment may be OEM abroad (the original design is abroad, we just got the production license); there are some domestic systems that use open source software, but for OEM and open source itself, domestic systems may also carry security issues.
Moreover, because the special nature of open source systems, there is not a manufacturer, so there may be loopholes and no one to solve the situation. Taking these factors together, we cannot simply say that the domestic network products must be secure.
SMD: So, do you think the Windows 10 China Government Edition requires a complete network review?
Wang Jun: As I just said, network products and services, whether domestic or foreign, whether it is domestic firm or joint venture, are also required in accordance with relevant national laws and regulations to carry out the necessary security assessment, or even a security review. The Windows 10 China Government Edition should also be no exception. Of course, to start a security review requires things to be done in accordance with the relevant legal procedures. If you meet the conditions for triggering the security review, in accordance with the legal procedures, it is possible to conduct a cybersecurity review.
SMD: Is it not the government procurement of critical information network infrastructure that requires conducting a cybersecurity review? So the security review and government procurement are naturally bound into one piece?
Wang Jun: As far as I know, the two are not naturally bound together. Government procurement also has its own procedural requirements. In the Cybersecurity Law, there is a provision for procurement that states that “network products or services that have not passed a security assessment or security review” may not be purchased. We should pay attention to the understanding of “have not,” which should be understood as “should undergo but did not undergo a cybersecurity review.”
Therefore, according to the current law, I think it is clear that if a product did not pass a security review, and clearly announced that it did not pass, it cannot be entered into the procurement directory.
SMD: The current technical testing for security is usually just testing a sampling, how to ensure that each computer operating system is secure?
Wang Jun: We are currently testing the methods, concerned about the two aspects of dynamic and static, but we are limited by the current technology and methods, and there is more of a focus on the static state. We are responsible for certain samples and security conclusions at a given point in time, but these are not permanent and it is difficult to achieve permanent security testing. However, the evaluation agency will try to make up for the relevant deficiencies, such as continuous monitoring, on-line monitoring or testing methods to strengthen the understanding, and mastering of the dynamic security situation.
SMD: Some people worry about the security of foreign products, fearing incidents such as described by Snowden. Is this not justified?
Wang Jun: This concern is reasonable—no one dares to say no. This is one of the reasons we have always stressed security and controllability. But we should not ask for absolute security, just as we do not stop driving a car because of the risk of traffic accidents. In fact, we also have a certain degree of anti-risk ability, through our work, to improve the security and controllability of foreign products, so that the risk is reduced to an acceptable level. Then we can use foreign advanced products.
Southern Metropolis Daily reporter Wu Bin from Beijing