FOI 4294 Document 1
KEYS, Daniel
From:
KEYS, Daniel
Sent:
Monday, 15 June 2020 7:21 AM
To:
McBride, Paul; s22
Subject:
FW: Correspondence from Minister Robert to the Prime Minister re Apple and
Google Exposure Notification Framework [SEC=OFFICIAL]
Attachments:
MS20-000022 - Letter to the Prime Minister from Minister Robert re Apple and
Google ENF.pdf
FYI regarding the use of the Apple and Google ENF.
Daniel Keys
Chief Information Officer and Chief Security Officer
Information Technology Division | Corporate Operations Group
Australian Government Department of Health
T: (02) 6289 s22 | M: s22
| E: xxxxxx.xxxx@xxxxxx.xxx.xx
Location: Sirius Building 2.N.510
PO Box 9848, Canberra ACT 2601, Australia
Executive Assistant
s22
| (02) 6289 s22 |s22
@health.gov.au
Executive Officer
s22
| (02) 6289 s22 | s22
health.gov.au
The Department of Health acknowledges the traditional owners of country throughout Australia, and their continuing connection to land, sea and
community. We pay our respects to them and their cultures, and to elders both past and present.
From: s47E(d)
Sent: Saturday, 13 June 2020 11:04 AM
To: KEYS, Daniel
Cc: s47E(d)
Subject: FW: Correspondence from Minister Robert to the Prime Minister re Apple and Google Exposure Notification
Framework [SEC=OFFICIAL]
Hi Daniel
Please see letter attached for info
MPS – please log in PDMS and assign to ITD for info
Thanks
s22
s22
Department Liaison Officer
Office of the Hon Greg Hunt MP
Minister for Health
T: s47E(d)
| M:s47E(d)
E:s47E(d)
@health.gov.au
Suite M1.41, PO Box 6022, Parliament House, Canberra ACT 2600, Australia
From: s47E(d)
@dta.gov.au>
Sent: Friday, 12 June 2020 2:46 PM
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FOI 4294 Document 1
To:
@
s47E(d) pm.gov.au>
Cc:s47E(d)
@health.gov.au>;
@p
s47E(d) mc.gov.au; s47E(d)
s47E(d) dta.gov.au>
Subject: Correspondence from Minister Robert to the Prime Minister re Apple and Google Exposure Notification
Framework [SEC=OFFICIAL]
OFFICIAL
Good afternoon
Please find attached correspondence from Minister Robert to the Prime Minister regarding Apple and Google
Exposure Notification Framework. No hard copy to follow
This letter has been copied to the Minister for Health, The Hon. Greg Hunt MP and Minister for Foreign Affairs, The
Hon. Marise Payne.
Kind regards
s22
A/g Departmental Liaison Officer
Office of the Hon Stuart Robert MP
Minister for the National Disability Insurance Scheme
Minister for Government Services
Parliament House, Canberra ACT 2600
M: s47E(d)
E:s47E(d)@dta.gov.au
OFFICIAL
______________________________________________________________________
IMPORTANT: This message, and any attachments to it, contains information
that is confidential and may also be the subject of legal professional or
other privilege. If you are not the intended recipient of this message, you
must not review, copy, disseminate or disclose its contents to any other
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KEYS, Daniel
From:
KEYS, Daniel
Sent:
Friday, 12 June 2020 2:31 PM
To:
s22
; McBride, Paul; s22
Subject:
RE: Apple and Google API Letter to MO [SEC=OFFICIAL]
Attachments:
Apple Google ENF Exposure Notification Framework 3 June 2020.pdf
Thanks s22
Here is the slide deck that the DTA presented to their MO that informed their decision. I’ve also shared this with the
office so it doesn’t come as a surprise.
Cheers
Daniel Keys
Chief Information Officer and Chief Security Officer
Information Technology Division | Corporate Operations Group
Australian Government Department of Health
T: (02) 6289 s22 | M: s22
| E: xxxxxx.xxxx@xxxxxx.xxx.xx
Location: Sirius Building 2.N.510
PO Box 9848, Canberra ACT 2601, Australia
Executive Assistant
s22
| (02) 6289 s22 | s22
@health.gov.au
Executive Officer
s22
| (02) 6289 s22 | s22
@health.gov.au
The Department of Health acknowledges the traditional owners of country throughout Australia, and their continuing connection to land, sea and
community. We pay our respects to them and their cultures, and to elders both past and present.
From: s22
Sent: Friday, 12 June 2020 12:36 PM
To: KEYS, Daniel ; McBride, Paul ; s22
Cc: s22
Subject: Apple and Google API Letter to MO [SEC=OFFICIAL]
Good afternoon Daniel and Paul
As you will be aware, there is significant activity occurring with the release of the new Apple and Google API.
This email is to give you a heads up that the DTA Minister will be writing a letter to the Prime Minister and our
Health Minister on the DTA’s position and plans for addressing the recent API’s releases. I have not been privy to the
contents of this letter, however I will assume it will bounce to you both at some stage. Currently the letter is with
the DTA Ministers Office and it may be inbound at any time.
Current situation (as I understand it):
DTA have a prototype of the new API and are undertaking numerous tests to see how it could support or
enhance the current COVIDSafe application.
The specific component DTA are interested in is an element called the Exposure Notification Framework
(ENF). This element will significantly resolve Bluetooth connectivity issues (handshakes and interactions with
other devices such as medical etc).
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DTA’s position overall is to not adopt the API in its current state as it completely changes the business model
of the COVIDSafe which would mean we basically start again (legal, policy tech). The preference is to work
with Google and Apple to change the way the API is constructed, so they can pick and choose the elements
of interest such as the ENF of interest.
To do this I believe DTA have had some pushback from Google and Apple, noting it is all or nothing.
DTA is now in the process of engaging with numerous countries on this specific issue, and will be
establishing a coalition of the willing to begin placing international pressure on Google and Apple to work
through a change where all benefit.
o Note feedback from international engagement has suggested Australia is seen to be the world
leader in such a capability and they are looking at us for advice.
I will advise when any further developments are in hand.
s22
Director, Business Architecture and Delivery
Delivery Manager COVIDSafe Health Portal
National Incident Response Division
Department of Health
s22
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FOI 4294 Document 4
Google/Apple
Exposure Notification Framework
(ENF)
Discovery Phase - May 2020
dta.gov.au
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FOI 4294 Document 4
What are Google and Apple introducing?
Phase 1
Phase 2
• On 20 May 2020, Apple and Google
• Over the coming months, Google and Apple
introduced new 'exposure notification APIs’
wil be making changes to their underlying
that use the Bluetooth capability on devices to
operating system to include the exposure
support contact tracing.
notification capability as a native function.
• The feature was introduced in the most recent
• This means users wil not necessarily need a
version of iOS (13.5x) and requires an
Government contact tracing app on their
authorised government app to take advantage
device to be notified of a close contact.
of the feature.
Source: Apple Google exposure notification API frequently asked questions v1.1
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We want ENF’s improved Bluetooth connectivity
The major benefit of the ENF is a promised Bluetooth performance improvement, we
would like access to that improvement without needing to adopt the whole ENF.
While Apple/Google have promised this improvement to us, we have been unable to
validate their claims and compare against the significant Bluetooth improvements we
have already made in COVIDSafe over several releases.
Bluetooth Performance Risk
The ENF does not provide data about Bluetooth performance to our developers in a
way that allows easy comparison between the ENF and COVIDSafe. We are working
with Apple/Google to finalise a prototype to undertake testing. Preliminary results wil
be available by the end of next week. Further real-life testing wil also be required.
If testing does not show the promised Bluetooth performance improvements, the ENF
could generate less encounter data than COVIDSafe. Additionally, if the Bluetooth
improvements are marginal compared to COVIDSafe, we would need to consider
whether adopting the ENF is warranted given the effort and process change it causes.
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The ENF will reduce device compatibility
Adopting the ENF wil mean less device compatibility compared to COVIDSafe.
This means less Australians wil be able to participate contact tracing. The
groups most likely affected wil include at-risk parts of the community, such as
elderly users and those from lower socio-economic communities.
Apple
COVIDSafe is currently backward compatible to iOS version 10 and the iPhone
5s. The ENF is only compatible with iPhone 6 or later devices running the
current iOS version 13.5 (released on 20 May 2020) or above. Apple has
advised that the uptake of version 13.5 has been slightly slower than usual but
have not confirmed actual rates.
Android
Android users wil be able to access the ENF if they are running v6.0 or later,
currently covering 87% of Android users. COVIDSafe supports greater
backward compatibility to Android v5.1, currently covering 98% of Android
users.
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The impact of adopting the ENF is significant
Our approach to contact tracing would fundamental y change.
Adopting the ENF would mean revisiting decisions that underpin our current
contact tracing model supporting public health outcomes. The decentralised ENF
model limits access for State and Territories officials to effectively manage the
pandemic.
Patient to Patient tracing and identification of an infection source are not possible
under the ENF.
The ENF maintains encounters for 14 days (compared to 21 days for COVIDSafe),
allowing a shorter time window to track infection exposure after a positive test.
The algorithm defining a close contact is managed on the phone. If the Bluetooth
performance improvements do not eventuate, there is no way health officials can
compensate. By uploading the raw encounter data and running the algorithm in the
health portal, COVIDSafe allows health officials to apply their knowledge and
discretion to triage high risk cases including the elderly or an infection cluster.
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The impact of adopting the ENF is significant
All contact data col ected to date would be lost.
This means Australia’s 21-day contact tracing data pool needs to be rebuilt. The
lost encounter data would be a vulnerability in our efforts to contain coronavirus.
A new Privacy Impact Assessment (PIA) would be required and legislative
amendments may be needed.
The implementation of the current PIA and legislation represented may weeks of
work, parliamentary scrutiny and working with the OAIC on privacy concerns. Al of
this work would need to recommence if the ENF was adopted.
Security and privacy risk would be re-introduced.
ACSC have advised the ENF would reintroduce privacy and security risks that
have been overcome in COVIDSafe as part of the recent encryption (crypto)
update in Release 4.
This will re-expose vulnerable users to potential malicious attacks under the ENF.
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Worldwide adoption of the ENF is mixed
Ireland, Germany, Italy and Denmark recently moved from building a bespoke application to the ENF. A number of other countries are engaging with Apple /
Google to test how the ENF may integrate with their systems and processes.
France: After public and
Staying with bespoke app
Staying with ENF compatible
parliamentary scrutiny on data
Austria: Integrating ENF within
privacy, a parliamentary vote
solutions
current live app to resolve technical
approved release of the app 3 June.
issues for iOS.
●
France
●
India
●
Netherlands
●
Czechia
●
Norway
●
Israel
●
Finland
●
Austria
●
Australia
●
Iceland
●
Switzerland
●
Canada
●
Singapore
●
Poland
●
Estonia
●
Portugal
Singapore: Not likely to shift from
●
UK
●
Cyprus
current app, as they consider Public
Health requirements a key priority.
Germany: Pivoted to approach
Sharing feature improvement inputs
compatible with ENF in response to
with Google and Apple ENF.
Moving to bespoke app
Moving to ENF solution
pressure from media, data
protection lobby and Apple.
●
New Zealand (building diary app)
●
Italy
UK: Has an app in pilot on the Isle of
●
Germany
Wight with ~70k (~50% of pop.) It is
●
Ireland
Ireland: Pivoted to ENF approach;
in discussion with GA to assess API
●
Denmark
primarily in response to adoption
feasibility and options.
concerns due to data privacy and
app stability.
Countries in
bold have already launched their apps
Note : Bespoke apps refer to app making bespoke use of Bluetooth radio or other processes for contact tracing as opposed to GA-API for Exposure Notificatio
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Next Steps
Testing
• We have integrated with the Apple API and expect to integrate with the Google
API shortly. This wil allow prototype testing against the ENF framework next
week to assess the Bluetooth performance improvements against COVIDSafe.
Further conversations with Apple and Google are required
• Access to the Bluetooth improvements in the ENF may enable further
performance improvements to COVIDSafe.
• It is worthwhile to continue discussions with Apple / Google to determine if that is
possible without needing to adopt the entire framework and the subsequent
impact that would have on the national coronavirus response.
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Document Outline
