Navigating the CERT-In directions for business operations.

On 28 April 2022, CERT-In released directions for cybersecurity incident reporting. With the compliance deadline of 28 June fast approaching, industry bodies shared their concerns with CERT-In and MoS Rajeev Chandrashekhar on 10 June 2022.

At the meeting, MoS asked for suggestions for a reasonable time frame for Small and Medium Enterprises (SMEs) to comply with CERT-In’s directions. Rootconf organized a meeting with representatives from SMEs on 14 June 2022 to discuss the issue of compliance timeline. SME representatives opined that 300 days from 28 June 2022 is a reasonable time frame for complying with CERT-In’s directions.

The intention of this document is to collectively navigate through the new CERT-In directions published on 28th April 2022, with the SME community, and provide useful suggestions pertaining to the directions, such that there is ample time to incorporate them, and minimum friction in implementation. Additional suggestions that came up in the meeting are as follows:

A. Periodic consultations with industry bodies to discuss issues that emerge during compliance.

1. Increase clarity around logging data;

• Exact data logging requirements for service providers.
• The number of days that data is to be stored, as costs increase almost exponentially with time (a table with cost breakdown for storage is provided at the end of this document).

2. On incident reporting:

• Create a “good Samaritan” framework for individuals in organizations who report incidents. Complying with investigations should not be seen as a burden on the organization/ individual doing the reporting.
• Require reporting when systems are impacted due to DDoS/DoS attacks and not for every targeted scan. This will help cull the costs of compliance, as targeted scans happen very frequently. More specifically, reporting on DDoS attacks should be required even if systems are not impacted whereas, DoS attacks should be reported only if systems are impacted.
• Maintenance of a portal by CERT-In, with form-based submissions as a reporting mechanism to streamline the process. This way, reporters can easily ensure necessary data is furnished and can track the status of their submission.

3. Investigation participation of service providers, when required, over email, phone or remote video conferencing as opposed to being summoned in person.

4. Parity in compliance requests for both foreign and Indian companies. Typically the ask for data from Indian companies is much higher than when dealing with foreign companies.

5. Provide clarity on methods used by CERT-In to ensure security of the data they receive.

B. Organize training and capacity building for law enforcement officers.

1. Build knowledge around data access and sharing that are stipulated in the current sharing regulations. For example, intermediary rules need to be better clarified so that Service Providers are not under direct investigation for abuse of their platform by third party users

2. Manage incident reports handling of complex deployments.

C. Introduce certification-like approach for compliance.

1. Help organizations to implement the requirements in a more structured manner. The compliance can thus be transparently evaluated based on the requirements.

D. Provide a wider range of options for customer validation.

1. Aadhaar-based customer validation via services such as digio.in and bureau.id, which do not collect a copy of Aadhaar but use it for name and address verification or Aadhaar signatures through separate OTPs

2. Vetting of third-party identity validation providers outside of India to facilitate foreign companies’ and nationals’ identity and address validation as many foreign nationals may not be comfortable providing passport scans.

Log retention cost breakdown:

Rootconf is invested in facilitating further interactions between CERT-In and representatives from the SME community to improve the state of cybersecurity in the Indian tech ecosystem.