ISPA Pulls UK Internet Villain Category Over Mozilla DoH Fallout

One embarrassment too many. The UK Internet Service Providers Association (ISPA) has, at the 11th hour, decided to scrap the “Internet Villain” category from their annual industry awards event, which came after a global backlash over their decision to nominate Mozilla due to their DNS-over-HTTPS (DoH) push.

The decision to stick Mozilla (Firefox, Thunderbird etc.) under the villain category for their DNS-over-HTTPS (DoH) solution (see here and here for context) did not, as anybody familiar with the situation might rightfully expect, go down particularly well around the world.

Admittedly big broadband ISPs and politicians are concerned that large scale third-party deployments of DoH, which encrypts DNS requests using the now common HTTPS protocol for websites (i.e. turning IP addresses into human readable domain names like ISPreview.co.uk and back again), could disrupt their ability to censor, track and control related internet services.

The above position is however a particularly narrow way of looking at the technology, not least because at its core DoH is all about protecting user privacy and making internet connections more secure (much like HTTPS has done for websites). As a result DoH (as well as its older sibling DoT) is often praised and widely supported by the wider internet community.

Mozilla is by no means alone in pushing DoH but they found themselves being somewhat singled out by the ISPA because of their proposal to enable the feature by default within Firefox (this has yet to happen), which is something that has proven contentious (i.e. who controls the DoH server in the USA? Do you trust them more than your UK ISP? etc.). This might also break a number of general ISP account management features.

Predictably this move triggered a huge backlash, which might have been avoided had the ISPA also nominated Mozilla for the Hero category to provide some balance. Initially the ISPA defended their position but at the 11th hour they’ve opted to avoid an embarrassing situation by scrapping the entire category, which is a shame since both of the other two nominations (Trump and Article 13 in the EU Copyright Directive) were widely accepted.

ISPA Statement on the 2019 Internet Villain Category

In the 21 years the event has been running it is probably fair to say that no other nomination has generated such strong opinion. We have previously given the award to the Home Secretary for pushing surveillance legislation, leaders of regimes limiting freedom of speech and ambulance-chasing copyright lawyers.

The villain category is intended to draw attention to an important issue in a light-hearted manner, but this year has clearly sent the wrong message, one that doesn’t reflect ISPA’s genuine desire to engage in a constructive dialogue. ISPA is therefore withdrawing the Mozilla nomination and Internet Villain category this year.

While we are withdrawing the nomination, we still believe that it is important to properly scrutinise the implementation plans for DoH. Below we set out our position in more detail and we will continue to develop this position and engage with our members, browser and app companies, DNS resolvers and vendors, policymakers and the wider Internet community on this issue.

Any implementation of DoH (or equally any other flavour of encrypted DNS) should be capable of achieving the expected privacy and security benefits, while at the same time being mindful of the complex internet eco system, as well as the different user relationship and trust models that are in play.

User choice: An application switching to DoH should ensure that this switch does not undermine choices that have been previously made by the user. For example, if parents have decided to filter an internet connection in their home via network or local level DNS controls, these choices should not simply be ignored by the application.

User consent: Any application switching to DoH should ensure that the decision to switch resolvers is made by a user who is:

a/ fully informed about the implications of switching resolvers, and
b/ fully capable of expressing consent, e.g. relevant admin rights need to be protected and decisions should be made by main account holders

Furthermore, DoH discovery and selection should allow users to change their resolver selections as they wish too, e.g. they may wish to revisit selections when new resolvers become available.

Data protection: Any application switching to DoH should ensure that a DoH resolver fully complies with the local data protection requirements.

Security: Any application switching to DoH should ensure that the selected DoH provider is capable of replicating existing security policies and capabilities such as malware protection that are currently in place for that user.

Online safety: Any application switching to DoH should ensure that the selected resolver should be capable of replicating the online safety policies that are currently in place for that user.

User and access-network-operator support: If DoH doesn’t work or is slow, a customer’s internet access will be affected. The customer will contact their ISP, not the DoH provider, but the ISP won’t be able to fix things for them. As a minimum, any application switching to DoH should ensure that the selected resolver should provide a 24/7 user call centre reachable via low-cost/local rate telephony and an online support capability. Support for fault-diagnosis and resolution between ISP, resolver and users should also be provided.

There are numerous other areas that we could go into, e.g. how DoH affects enterprise networks, or content caching, and the points raised in this post are only an initial outline. We recognise that things have started moving at Internet Engineering Task Force level, for example, and look forward to engaging in a constructive discussion.

One irony of this episode is that many more people have now become familiar with DoH and as a result take-up has rocketed over the past couple of weeks, which might not be the sort of outcome that bigger ISPs would like to see (it’s that pesky user choice thing again).

However it’s important not to paint all providers with the same brush, particularly smaller providers where DNS choice is less contentious (i.e. fewer things for it to break). One such provider, AAISP, even made a £2,940 donation to the Mozilla Foundation: “The amount was chosen because that is what our fee for ISPA membership would have been, were we a member,” said the ISP.

In fairness we do think there is a debate here around the issue of enabling DoH by default in third-party apps (it’s usually best to give people the option but not to force it upon them), although DoH itself is more often than not a welcome improvement.