Updating email addresses, GDPR style

After scrambling to find a bandaid solution for the upcoming domainpocalypse caused by EURid, I set myself out tomake sure that all my accounts everywhere use a more stable domain. Some of you might have noticed, because it was very visible in me submitting .mailmap files to a number of my projects to bundle together old and new addresses alike.

Unfortunately, as I noted on the previous post, not all the services out there allow you to change your email address from their website, and of those, very few allow you to delete the account altogether (I have decided that, in some cases, keeping an account open for a service I stopped using is significantly more annoying than just removing it). But as Daniel reminded me in the comments, the Right to rectification or Right to correction, allows me to leverage GDPR for this process.

I have thus started sending email to the provided Data Protection contact for various sites lacking an email editing feature:

Hello,

I’m writing to request that my personal data is amended, under my right to correction (Directive 95/46/EC (General Data Protection Regulation), Article 16), by updating my email address on file as [omissis — new email] (replacing the previous [omissis — old email] — which this email is being sent from, and to which you can send a request to confirm identity).

I take the occasion to remind you that you have one month to respond to this request free of charge per Art. 12(3), that according to the UK Information Commissioner’s Office interpretation (https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/right-of-access/) you must comply to this request however you receive it, and that it applies to the data as it exists at the time you receive this.

The responses to this have been of all sorts. Humans being amused at the formality of the requests, execution of the change as requested, and a couple of push backs, which appear to stem from services that not only don’t have a self-service way to change the email address, but also seem to lack technical means to change it.

The first case of this is myGatwick — the Gatwick airport flyer portal. When I contacted the Data Protection Officer to change my email address, the first answer was that at best they could close the account for the old email address and open a new one. I pointed out that’s not what I asked to do and not what the GDPR require them to do, and they tried to argue that email addresses are not personal data.

The other interesting case if Tile, the beacon startup, which will probably be topic of a separate blog post because their response to my GDPR request is a long list of problems.

What this suggests to me is that my first guess (someone used email addresses as primary keys) is not as common as I feared — although that appears to be the problem for myGatwick, given their lack of technical means. Instead, the databases appears to be done correctly, but the self-service feature of changing email address is just not implemented.

While I’m not privy to product decisions for the involved services, I can imagine that one of the reasons why it was done that way, is that implementing proper access controls to avoid users locking themselves in, or to limit the risk of account takeover, is too expensive in terms of engineering.

But as my ex-colleague Lea Kissner points out on Twitter, computers would be better at not introducing human errors in the process to begin with.

Of all the requests I sent and were actioned, there were only two cases in which I have been asked to verify anything about either the account or the email address. In both cases my resorting to GDPR requests was not because the website didn’t have the feature, but rather that it failed: British Airways and Nectar (UK). Both actioned the request straight from Twitter, and asked security questions (not particularly secure, but still good enough compared to the rest).

Everyone else have at best sent an email to the old address to inform of the change, in reply to my request. This is the extent of the verification most of the DPO appear to have put on GDPR requests. None of the services were particularly critical: takeaway food, table bookings, good tea. But if it was not me sending these requests I would probably be having a bad half an hour the next time I tried using them.

Among the requests I sent yesterday there was one to delete my account to Detectify — I have used it when it was a free trial, found it not particularly interesting to me, and moved on. While I have expressed my intention to disable my account on Twitter, the email I sent was actioned, deleting my account (or at least it’s expected to have been deleted now), without a confirmation request of any kind, or any verification that I did indeed have access to the account.

Maybe they checked the email headers to figure out that I was really sending as the right email address, instead of just assumed so because it looked that way. I can only imagine that they would have done more due process if I was a paying customer, if nothing else to keep getting money. I just find it interesting that it’s a security-oriented company, and didn’t realise that it’s much more secure to provide the self-service interfaces rather than letting a human decide, there.

dot-EU Kerfuffle: what’s in an email anyway?

You may remember that last year I complained about what I defined the dot-EU kerfuffle, related to the news that EURid had been instructed to cancel the domain registrations of UK entities after Brexit. I thought the problem was passed when they agreed to consider European citizen as eligible holders of dot-EU domains, with an agreement reached last December, and due to enter into effect in… 2022.

You would think that, knowing that a new regulation needs to enter into effect, EURid would stop their plan of removing access to those domains for the UK residents for the time being, but it’s not so. Indeed, they instead sent a notice that effectively suggests that any old and new domain that would be then taken off the zone by marking them as WITHDRAWN first, and REVOKED second.

This means that on 2020-03-30, a lot of previously-assigned domains will be available for scammers, phishers, and identity thieves, unless they are transferred before this coming May!

You can get more user-focused read of this in this article by The Register, which does good justice to the situation, despite the author seemingly being a leaver, from the ending of a previous article linked there. One of the useful part of that article is knowing that there are over 45 thousands domain name assigned to individuals residing in the UK — and probably a good chunk of those are of either Europhiles Brits, or citizen of other EU countries residing in the UK (like me).

Why should we worry about this, given the amount of other pressing problems that Brexit is likely to cause? Well, there is a certain issue of people being identified by email addresses that contain domain names. What neither EURid nor The Register appear to have at hand (and me even less) would be to figure out how many of those domains actually are used as logins, or receive sensitive communications such as GP contacts from NHS, or financial companies.

Because if someone can take over a domain, they can take over the email address, and very quickly from there you can ruin the life of, or at least heavily bother, any person that might be using a dot-EU domain. The risks for scams, identity theft and the like are being ignored once again by EURid to try to make a political move, at a time when nobody is giving a damn of what EURid is doing.

As I said in the previous post, I have been using flameeyes[dot]eu as my primary domain for the past ten or eleven years. The blog was moved on its own domain. My primary website is still there but will be moved shortly. My primary email address is changed. You’ll see me using a dot-com email address more often.

I’m now going through the whole set of my accounts to change the email they have on file for me with a new one on a dot-com domain. This is significantly helped by having all of them on 1password, but that’s not enough — it only tells you which services that use email as username. It says nothing about (say) the banks that use a customer number, but still have your email on file.

And then there are the bigger problems.

Sometimes the email address is immutable.

You’d be surprised on how many websites have either no way to change an email address. My best guess is that whoever designed the database schema thought that just using the email address as a primary key was a good idea. This is clearly not the case, and it has not been the case ever. I’d be surprised if anyone who got their first email address from an ISP would be making that mistake, but in the era of GMail, it seems this is often forgotten.

I now have a tag for 1Password to show me which accounts I can’t change the email address of. Some of them are really minimal services, that you probably wouldn’t be surprised to just store an email address as identifier, such as the Fallout 4 Map website. Some appear to have bugs with changing email addresses (British Airways). Some … surprised me entirely: Tarsnap does not appear to have a way to change email address either.

While for some of these services being unable to receive email is not a particularly bad problem, for most of them it would be. Particularly when it comes to plane tickets. Let alone the risk that any one of those services would store passwords in plain text, and send them back to you if you forgot them. Combine that with people who reuse the same password everywhere, and you can start seeing a problem again.

OAuth2 is hard, let’s identify by email.

There is another problem if you log into services with OAuth2-based authentication providers such as Facebook or (to a lesser extent) Google. Quite a few of those services would create an account for you at first login, and use the email address that they are given by the identity provider. And then they just match the email address the next time you login.

While changing Google’s email address is a bit harder (but not impossible if, like me, you’re using GSuite), changing the address you register on Facebook with is usually easy (exceptions exist). So if you signed up for a service through Facebook, and then changed your Facebook address, you may not be able to sign in again — or you may end up signing up for the service again when you try.

In my case, I changed the domain associated of my Google account, since it’s a GSuite (business) account. That made things even more fun, because even if services may remember that Facebook allows you to change your email address, many might have forgotten that technically Google allows you to do that too. While Android and ChromeOS appear to work fine (which honestly surprised me, sorry colleagues!), Pokémon Go got significantly messed up when I did that — luckily I had Facebook connected to it as well, so a login later, and disconnect/reconnect of the Google account, was enough for it to work.

Some things are working slightly better than other. Pocket, which allows you to sign in with either a Firefox account, a Google account, or an email/password pair, appears to only care about the email address of the Google account. So when I logged in, I ended up with a new account and no access to the old content. The part that works well is that you can delete the new account, and immediately after login to the old one and replace the primary email address.

End result? I’m going through nearly every one of my nearly 600 accounts, a few at a time, trying to change my email address, and tagging those where I can’t. I’m considering writing a standard template email to send to any support address for those that do not support changing email address. But I doubt they would be fixed in time before Brexit. Just one more absolute mess caused by Cameron, May, and their friends.

The dot-EU kerfuffle — or how EURid is messing with their own best supporters

TL;DR summary: be very careful if you use a .eu domain as your point of contact for anything. If you’re thinking of registering a .eu domain to use as your primary domain, just don’t.


I have forecasted a rant when I pointed out I changed domain with my move to WordPress.

I have registered flameeyes.eu nearly ten years ago, part of the reason was because flameeyes.com was (at the time) parked to a domain squatter, and part because I have been a strong supported of the European Union.

In those ten years I started using the domain not just for my website, but as my primary contact email. It’s listed as my contact address everywhere, I have all kind of financial, commercial and personal services attached to that email. It’s effectively impossible for me to ever detangle from it, even if I spend the next four weeks doing nothing but amending registrations — some services just don’t allow you to ever change email address; many requires you to contact support and spend time talking with a person to get the email updated on the account.

And now, because I moved to the United Kingdom, which decided to leave the Union, the Commission threatens to prevent me from keeping my domain. It may sound obvious, since EURid says

A website with a .eu or .ею domain name extension tells your customers that you are a legal entity based in the EU, Iceland, Liechtenstein or Norway and are therefore, subject to EU law and other relevant trading standards.

But at the same time it now provides a terrible collapse of two worlds: technical and political. The idea that you any entity in control of a .eu domain is by requirement operating under EU law sounds good on paper… until you come to this corner case where a country leaves the Union — and now either you water down this promise, eroding trust in the domain by not upholding this law domain, or you end up with domain takeover, eroding trust in the domain on technical merit.

Most of the important details for this are already explained in a seemingly unrelated blog post by Hanno Böck: Abandoned Domain Takeover as a Web Security Risk. If EURid will forbid renewal of .eu domains for entities that are no longer considered part of the EU, a whole lot of domains will effectively be “up for grabs”. Some may currently be used as CDN aliases, and be used to load resources on other websites; those would be the worst, as they would allow the controller of the domains to inject content in other sites that should otherwise be secure.

But even more important for companies that used their .eu domain as their primary point of contact: think of any PO, or invoice, or request for information, that would be sent to a company email address — and now think of a malicious actor getting access to those communications! This is not just the risk that me (and any other European supporter who happened to live in the UK, I’m sure I’m not alone) as a single individual have — it’s a possibly unlimited amount of scams that people would be subjected to, as it would be trivial to pass for a company, once their domain is taken over!

As you can see from the title, I think this particular move is also going to hit the European supporters the most. Not just because of those individuals (like me!) who wanted to signal how they feel part of something bigger than their country of birth, but also because I expect a number of UK companies used .eu domain specifically to declare themselves open to European customers — as otherwise, between pricing in Sterling, and a .co.uk domain, it would always feel like buying “foreign goods”. Now those companies, that believed in Europe, find themselves in the weakest of positions.

Speaking of individuals, when I read the news I had a double-take, and had to check the rules for .eu domains again. At first I assumed that something was clearly wrong: I’m a European Union citizen, surely I will be able to keep my domain, no matter where I live! Unfortunately, that’s not the case:

In this first step the Registrant must verify whether it meets the General
Eligibility Criteria, whereby it must be:
(i) an undertaking having its registered office, central administration or
principal place of business within the European Union, Norway, Iceland
or Liechtenstein, or
(ii) an organisation established within the European Union, Norway, Iceland
or Liechtenstein without prejudice to the application of national law, or
(iii) a natural person resident within the European Union, Norway, Iceland or
Liechtenstein.

If you are a European Union citizen, but you don’t want your digital life to ever be held hostage by the Commission or your country’s government playing games with it, do not use a .eu domain. Simple as that. EURid does not care about the well-being of their registrants.

If you’re a European company, do think twice on whether you want to risk that a change in government for the country you’re registered in would lead you to open both yourself, your suppliers and your customers into the a wild west of overtaken domains.

Effectively, what EURid has signalled with this is that they care so little about the technical hurdles of their customers, that I would suggest against ever relying on a .eu domain for anyone at all. Register it as a defense against scammers, but don’t do business on it, as it’s less stable than certain microstate domains, or even the more trendy and modern gTLDs.

I’ll call this a self-goal. I still trust the European Union, and the Commission, to have the interests of the many in their mind. But the way they tried to apply a legislative domain to the .eu TLD was brittle at best to begin with, and now there’s no way out of here that does not ruin someone’s day, and erode the trust in that very same domain.

It’s also important to note that most of the bigger companies, those that I hear a lot of European politicians complain about, would have no problem with something like this: just create a fully-own subsidiary somewhere in Europe, say for instance Slovakia, and have it hold onto the domain. And have it just forward onto a gTLD to do business on, so you don’t even give the impression of counting on that layer of legislative trust.

Given the scary damage that would be caused by losing control over my email address of ten years, I’m honestly considering looking for a similar loophole. The cost of establishing an LLC in another country, firmly within EU boundaries, is not pocket money, but it’s still chump change compared to the amount of damage (financial, reputation, relationships, etc) that it would be a good investment.