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What Is a VPN and its Significance 

A Virtual Private Network (VPN) creates a secure and reliable network connection between a device and the internet. It hides your IP address by rerouting it through the VPN’s host servers. For example, if you connect to a US server, you appear to be browsing from the US, even if you’re in India. It also encrypts the data being transferred in real-time so that it is not decipherable by third parties such as ad companies, the government, cyber criminals, or others.

All online activity leaves a digital footprint that is tracked for data collection, and surveillance, increasingly jeopardizing user privacy. VPNs are thus a powerful tool for enhancing the privacy and security of users, businesses, governments and critical sectors. They also help protect users on public Wi-Fi networks ( for example, at airports and hotels), journalists, activists and whistleblowers, remote workers and businesses, citizens in high-surveillance states, and researchers by affording them a degree of anonymity. 

What VPNs Do and Don’t 

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•  What VPNs Can Do:
  
  • Mask your IP address to enhance privacy.
  • Encrypt data to protect against hackers, especially on public Wi-Fi.
  • Bypass geo-restrictions (e.g., access streaming content blocked in India).
•  What VPNs Cannot Do:
  
  • Make you completely anonymous and protect your identity (websites can still track you via cookies, browser fingerprinting, etc.).
  • Protect against malware or phishing.
  • Prevent law enforcement from tracing you if they have access to VPN logs.
  • Free VPNs usually even share logs with third parties. 

VPNs in the Context of India’s Privacy Policy Landscape 

In April 2022, CERT-In (Computer Emergency Response Team- India) released Directions under Section 70B (6) of the Information Technology (“IT”) Act, 2000, mandating VPN service providers to store customer data such as “validated names of subscribers/customers hiring the services, period of hire including dates, IPs allotted to / being used by the members, email address and IP address and time stamp used at the time of registration/onboarding, the purpose for hiring services, validated address and contact numbers, and the ownership pattern of the subscribers/customers hiring services” collected as part of their KYC (Know Your Customer) requirements, for a period of five years, even after the subscription has been cancelled. While this directive was issued to aid with cybersecurity investigations, it undermines the core purpose of VPNs- anonymity and privacy. It also gave operators very little time to carry out compliance measures. 

Following this, operators such as NordVPN, ExpressVPN, ProtonVPN, and others pulled their physical servers out of India, and now use virtual servers hosted abroad (e.g., Singapore) with Indian IP addresses. While the CERT-In Directions have extra-territorial applicability, virtual servers are able to bypass them since they physically operate from a foreign jurisdiction. This means that they are effectively not liable to provide user information to Indian investigative agencies, beating the whole purpose of the directive. To counter this, the Indian government could potentially block non-compliant VPN services in the future. Further, there are concerns about overreach since the Directions are unclear about how long CERT-In can retain the data it acquires from VPN operators, how it will be used and safeguarded, and the procedure of holding VPN operators responsible for compliance. 

Conclusion: The Need for a Privacy-Conscious Framework

The CERT-In Directions reflect a governance model which, by prioritizing security over privacy, compromises on safeguards like independent oversight or judicial review to balance the two. The policy design renders a lose-lose situation because virtual VPN services are still available, while the government loses oversight. If anything, this can make it harder for the government to track suspicious activity.  It also violates the principle of proportionality established in the landmark privacy judgment, Puttaswamy v. Union of India (II) by giving government agencies the power to collect excessive VPN data on any user. These issues underscore the need for a national-level, privacy-conscious cybersecurity framework that informs other policies on data protection and cybercrime investigations. In the meantime, users who use VPNs are advised to choose reputable providers, ensure strong encryption, and follow best practices to maintain online privacy and security.

References 

• https://www.kaspersky.com/resource-center/definitions/what-is-a-vpn 
• https://internetfreedom.in/top-secret-one-year-on-cert-in-refuses-to-reveal-information-about-compliance-notices-issued-under-its-2022-directions-on-cybersecurity/#:~:text=tl;dr,under%20this%20new%20regulatory%20mandate. 
• https://www.wired.com/story/vpn-firms-flee-india-data-collection-law/#:~:text=Starting%20today%2C%20the%20Indian%20Computer,years%2C%20even%20after%20they%20have

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Introduction

The hospitality industry is noted to be one of the industries most influenced by technology. Hotels, restaurants, and travel services are increasingly reliant on digital technologies to automate core operations and customer interactions. The shift to electronic modes of conducting business has made the industry a popular target for cyber threats. In light of increasing cyber threats, safeguarding personal and sensitive personal data on the part of the hospitality industry becomes significant not only from a customer standpoint but also from an organisational and legal perspective.

Role of cybersecurity in the hospitality industry

A hospitality industry-based entity (“HI entity”) deploys several technologies not only to automate operations but to also deliver excellent customer experiences. Technologies such as IoTs that enable smart controls in rooms, Point-of-Sale systems that manage reservations, Call Accounting Systems that track and record customer calls, keyless entry systems, and mobile apps that facilitate easy booking and service requests are popularly used in addition to operative technologies such as Property Management Systems, Hotel Accounting Systems, Local Area Networks (LAN).{1} These technologies collect vast volumes of data daily due to the nature of operations. Such data necessarily includes personal information such as names, addresses, phone numbers, email IDs etc. and sensitive information such as gender, bank account and payment details, health information pertaining to food allergens etc. Resultantly, the breach and loss of such critical data impacts customer trust and loyalty and in turn, their retention within the business. Lack of adequate cybersecurity measures also impacts the reputation and goodwill of an HI entity since customers are more likely to opt for establishments that prioritise the protection of their data. In 2022, cybercriminals syphoned 20GB of internal documents and customer data from Marriott Hotels, which included credit card information and staff information such as wage data, corporate card number and even a personnel assessment file. A much larger breach was seen in 2018, where 383 million booking records and 5.3 million unencrypted passport numbers were stolen from Marriott’s servers.{2}

Cybersecurity is also central to safeguarding trade secrets and key confidential trade information. An estimate of US $6 trillion per year on average amounts to losses generated from cybercrimes.{3} The figure, however, does not include the cost of breach, expenses related to incident response, legal fees, regulatory fines etc which may be significantly higher for a HI entity when loss of potential profits is factored in.

Cybersecurity is also central from a legal standpoint. Legal provisions in various jurisdictions mandate the protection of guest data. In India, the Digital Personal Data Protection Act 2023, imposes a penalty of up to Rs. 50 Crores on a breach in observing obligations to take reasonable security safeguards to prevent personal data breach.{4} Similarly, the General Data Protection Regulation (GDPR) of the European Union also has guidelines for protecting personal data. Several other industry-specific rules, such as those pertaining to consumer protection,  may also be applicable.

Breaches and Mitigation

There are several kinds of cyber security threats faced by an HI entity. “Fake Booking” is a popular method of cyber attack, whereby attackers build and design a website that is modelled exactly after the hotel’s legitimate website. Many customers end up using such malicious phishing websites thereby exposing their personal and sensitive personal data to threats. Additionally, the provision of free wifi within hotel premises, usually accessible freely to the public, implies that a malicious actor may introduce viruses and updates bearing malware. Other common cyber threats include denial of service (DoS) attacks, supply chain attacks, ransomware threats, SQL injection attacks (a type of attack where malicious code is inserted into a database to manipulate data and gain access to information), buffer overflow or buffer overrun (when the amount of data exceeds its storage capacity, implying that the excess data overflows into other memory locations and corrupt or overwrites data in those locations). 

One of the best ways to manage data breaches is to leverage newer technologies that operate on a “privacy by design” model. An HI entity must deploy web application firewalls (WAF) that differ from regular firewalls since they can filter the content of specific web applications and prevent cyber attacks. Another method to safeguard data is by deploying a digital certificate which binds a message/instruction to the owner/generator of the message. This is useful in preventing any false claims fraud by customers. Digital certificates may be deployed on distributed ledger technologies such as blockchain, that are noted for their immutability, transparency and security. Self-sovereign identities or Identifiers (SSI) are also a security use-concept of blockchain whereby individuals own and control their personal data, thereby eliminating reliance on central authorities.{5} In the hospitality industry, SSIs enhance cybersecurity by securely storing identity-related information on a decentralised network, thereby reducing the risk of data breaches. Users can selectively share their information, ensuring privacy and minimising data exposure. This approach not only protects guests' personal details but also streamlines authentication processes, making interactions safer and more efficient.

From a less technical standpoint, cybersecurity insurance may be opted for by a hotel to secure themselves and customer information against breach. Through such insurance, a hotel may cover the liability that arises from breaches caused by both first- and third-party actions.{6} Additionally, Payment Cards Industry Data Security Standards should be adhered to, since these standards ensure that businesses should apply best practices when processing credit card data through optimised security. Employee training and upskilling in basic, practical cybersecurity measures and good practices is also a critical component of a comprehensive cybersecurity strategy.

References:

• [1]  The Growing Importance of Cybersecurity in the Hospitality Industry”, Alfatec, 11 September 2023 https://www.alfatec.ai/academy/resource-library/the-growing-importance-of-cybersecurity-in-the-hospitality-industry
• [2]  Vigliarolo, Brandon, “Marriott Hotels admit to third data breach in 4 years”, 6 July 2022 https://www.theregister.com/2022/07/06/marriott_hotels_suffer_yet_another/#:~:text=In%20the%20case%20of%20the,of%20an%20individual%20organization%20ever. 

• [3] Shabani, Neda & Munir, Arslan. (2020). A Review of Cyber Security Issues in the Hospitality Industry. 10.1007/978-3-030-52243-8_35. https://www.researchgate.net/publication/342683038_A_Review_of_Cyber_Security_Issues_in_Hospitality_Industry/citation/download    
• [4] The Digital Personal Data Protection Act 2023 https://www.meity.gov.in/writereaddata/files/Digital%20Personal%20Data%20Protection%20Act%202023.pdf 
• [5]  “What is self-sovereign identity?”, Sovrin, 6 December 2018 https://sovrin.org/faq/what-is-self-sovereign-identity/ 
• [6] Yasar, Kinza, “Cyber Insurance”, Tech Target https://www.techtarget.com/searchsecurity/definition/cybersecurity-insurance-cybersecurity-liability-insurance 

Introduction

India's Computer Emergency Response Team (CERT-In) has unfurled its banner of digital hygiene, heralding the initiative 'Cyber Swachhta Pakhwada,' a clarion call to the nation's citizens to fortify their devices against the insidious botnet scourge. The government's Cyber Swachhta Kendra (CSK)—a Botnet Cleaning and Malware Analysis Centre—stands as a bulwark in this ongoing struggle. It is a digital fortress, conceived under the aegis of the National Cyber Security Policy, with a singular vision: to engender a secure cyber ecosystem within India's borders. The CSK's mandate is clear and compelling—to detect botnet infections within the subcontinent and to notify, enable cleaning, and secure systems of end users to stymie further infections.

What are Bots?

Bots are automated rogue software programs crafted with malevolent intent, lurking in the shadows of the internet. They are the harbingers of harm, capable of data theft, disseminating malware, and orchestrating cyberattacks, among other digital depredations.

A botnet infection is like a parasitic infestation within the electronic sinews of our devices—smartphones, computers, tablets—transforming them into unwitting soldiers in a hacker's malevolent legion. Once ensnared within the botnet's web, these devices become conduits for a plethora of malicious activities: the dissemination of spam, the obstruction of communications, and the pilfering of sensitive information such as banking details and personal credentials.

How, then, does one's device fall prey to such a fate? The vectors are manifold: an infected email attachment opened in a moment of incaution, a malicious link clicked in haste, a file downloaded from the murky depths of an untrusted source, or the use of an unsecured public Wi-Fi network. Each action can be the key that unlocks the door to digital perdition.

In an era where malware attacks and scams proliferate like a plague, the security of our personal devices has ascended to a paramount concern. To address this exigency and to aid individuals in the fortification of their smartphones, the Department of Telecommunications(DoT) has unfurled a suite of free bot removal tools. The government's outreach extends into the ether, dispatching SMS notifications to the populace and disseminating awareness of these digital prophylactics.

Stay Cyber Safe

To protect your device from botnet infections and malware, the Government of India, through CERT-In, recommends downloading the 'Free Bot Removal Tool' at csk.gov.in.' This SMS is not merely a reminder but a beacon guiding users to a safe harbor in the tumultuous seas of cyberspace.

Cyber Swachhta Kendra

The Cyber Swachhta Kendra portal emerges as an oasis in the desert of digital threats, offering free malware detection tools to the vigilant netizen. This portal, also known as the Botnet Cleaning and Malware Analysis Centre, operates in concert with Internet Service Providers (ISPs) and antivirus companies, under the stewardship ofCERT-In. It is a repository of knowledge and tools, a digital armoury where users can arm themselves against the specters of botnet infection.

To extricate your device from the clutches of a botnet or to purge the bots and malware that may lurk within, one must embark on a journey to the CSK website. There, under the 'Security Tools' tab, lies the arsenal of antivirus companies, each offering their own bot removal tool. For Windows users, the choice includes stalwarts such as eScan Antivirus, K7 Security, and Quick Heal. Android users, meanwhile, can venture to the Google Play Store and seek out the 'eScan CERT-IN Bot Removal ' tool or 'M-Kavach2,' a digital shield forged by C-DAC Hyderabad.

Once the chosen app is ensconced within your device, it will commence its silent vigil, scanning the digital sinews for any trace of malware, excising any infections with surgical precision. But the CSK portal's offerings extend beyond mere bot removal tools; it also proffers other security applications such as 'USB Pratirodh' and 'AppSamvid.' These tools are not mere utilities but sentinels standing guard over the sanctity of our digital lives.

USB Pratirodh

'USB Pratirodh' is a desktop guardian, regulating the ingress and egress of removable storage media. It demands authentication with each new connection, scanning for malware, encrypting data, and allowing changes to read/write permissions. 'AppSamvid,' on the other hand, is a gatekeeper for Windows users, permitting only trusted executables and Java files to run, safeguarding the system from the myriad threats that lurk in the digital shadows.

Conclusion

In this odyssey through the digital safety frontier, the Cyber Swachhta Kendra stands as a testament to the power of collective vigilance. It is a reminder that in the vast, interconnected web of the internet, the security of one is the security of all. As we navigate the dark corners of the internet, let us equip ourselves with knowledge and tools, and may our devices remain steadfast sentinels in the ceaseless battle against the unseen adversaries of the digital age.

References

• https://timesofindia.indiatimes.com/gadgets-news/five-government-provided-botnet-and-malware-cleaning-tools/articleshow/107951686.cms
• https://indianexpress.com/article/technology/tech-news-technology/cyber-swachhta-kendra-free-botnet-detection-removal-tools-digital-india-8650425/

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