Apple’s Private Relay Service Creates Challenges for UK ISPs

Technology giant Apple recently released their iOS 15 software for iPad (15.5) and iPhones, which introduced a new feature called ‘iCloud Private Relay’ that “hides your IP address and browsing activity [when using Safari] so that no one – including Apple – can see [it].” Naturally, the UK Government and broadband ISPs have concerns.

Apple states that their Private Relay feature is “designed to protect your internet privacy” and should “have no impact on your browsing experience” (albeit with a few caveats), which is something that many in the wider internet community will generally praise. The feature has been in development for quite a while, but the key difference now is that consumers can start using it more widely.

However, much like the previous debate over another privacy enhancing feature – DNS over HTTPS (DoH), not everybody is a fan. By that, we of course mean the UK government, which enjoys the ability to snoop on your online activity. Not to mention any ISPs that like to know where your traffic is going so that they can optimise (e.g. ensure video traffic goes to a faster local cache), log (e.g. internet snooping) and sometimes also filter it (e.g. website blocking), for good or ill.

The good news for both parties is that Apple’s new feature is currently only a beta, with limited availability, and in order to access it you’d first have to pay for an iCloud+ account (although you can buy an iCloud account from just £0.79/mo for 50GB and these can be upgraded to ‘Plus’ at no extra cost). On top of that it only works with traffic that goes through the Safari browser. All of these factors will limit take-up, at least for now.

What Makes Private Relay Different?

In order to understand why politicians and ISPs are concerned, you first have to understand what makes Private Relay different. On the surface, the new feature sounds a lot like an encrypted Virtual Private Network (VPN) or TOR, although it probably has more in common with the latter of those two.

Essentially, it works by separating the web requests for the content you want from the place that request goes, which is done by using two proxy servers. Apple explains it as follows.

Apple’s Description of Private Relay

Normally when you browse the web, information contained in your web traffic, such as your DNS records and IP address, can be seen by your network provider and the websites you visit. This information could be used to determine your identity and build a profile of your location and browsing history over time. iCloud Private Relay is designed to protect your privacy by ensuring that when you browse the web in Safari, no single party – not even Apple – can see both who you are and what sites you’re visiting.

When Private Relay is enabled, your requests are sent through two separate, secure internet relays. Your IP address is visible to your network provider and to the first relay, which is operated by Apple. Your DNS records are encrypted, so neither party can see the address of the website you’re trying to visit. The second relay, which is operated by a third-party content provider, generates a temporary IP address, decrypts the name of the website you requested and connects you to the site. All of this is done using the latest internet standards to maintain a high-performance browsing experience while protecting your privacy.

What’s The Problem?

Firstly, on Apple’s claim of having “no impact on your browsing experience“… well, we have our doubts. Some people have reported worse performance when using the relay (e.g. slower latency and connection speeds) and indeed Apple themselves immediately contradict themselves by stated that “some websites, networks or services that rely on viewing your IP address or browsing activity may need to make updates for Private Relay” (i.e. a very roundabout way of saying that it can mess up a fair few things) – some of those you won’t care about, but others you might.

Apple notes that using Private Relay may result in problems signing-in to some services and difficulties when accessing region-restricted content (many VPN users will already know all about this). Likewise, they warn that ISPs, such as those with Parental Controls or other Network-Level Filtering systems, “may not be compatible” with the service. Private Relay will also turn off automatically when you roam into a country where it isn’t available, which is kind of silly for an internet service, but then Apple might have problems if they allowed this (e.g. China).

The Director of Public Consultancy firm 419 Consulting, Andrew Campling, recently published quite a good explainer on the impact that Private Relay could have on broadband ISPs and mobile network operators (here). As well as warning that it could affect the congestion management and peering optimisation activities that ISPs undertake, Andrew also notes that it may become harder for ISPs to comply with certain Quality of Service (QoS) related measurements that can be required by regulators (e.g. Ofcom).

Likewise, Private Relay may disrupt sophisticated edge content caching. For example, a lot of video content (e.g. Netflix) can be cached much more locally to the ISP to save performance and money, but if this can’t function then the content will be served off-net (i.e. risk of higher latency, congestion and higher costs etc.). And there’s more..

Extract from the 419 Consulting Report

Content Blocking and Filtering

Content blocking and filtering are used by network operators and ISPs for several reasons including:

• In response to court orders blocking access to illegal content such as child sexual abuse material (CSAM)
• To block access to malicious content
• To provide optional filtering capabilities that enable users to block access to certain categories of content, for example in the form of parental controls.

These facilities may not function correctly if Private Relay is enabled. In terms of blocking access to illegal content, legislators and regulators may need to amend existing instruments if they wish to bring Private Relay into scope.

“Zero-Rating” of Content

In consumer markets, both fixed and mobile networks may offer light users packages with data caps at reduced cost, the trade-off being that any data that is consumed over the cap can be relatively expensive. An ISP may opt to allow the customers of these packages access to certain content without it counting towards the data cap.

Zero-rated content may include:

• So-called “public good” material (for example, content related to public health or education)
• Certain premium content (for example sports, films or other entertainment-related material)

The ability to zero-rate content is lost if the ISP has no visibility of the website that a user is accessing. Users may experience unexpected increases in their bills if they do not realise that content that they were previously able to access freely is now impacting their data allowance.

Lawful Interception

In some markets, network operators and/or ISPs will have obligations relating to lawful interception of activity undertaken by their users. In terms of voice calls, whether over a mobile network or wi-fi, lawful interception abilities are not affected. However, any access to content, for example by the Safari web browser, is encrypted under Private Relay and so the ISP is unable to help with lawful interception; law enforcement agencies will need to contact Apple to undertake these obligations.

Data Retention and Disclosure

Network operators and/or ISPs may also have obligations concerning data retention and disclosure. As with lawful interception, the ability of network operators or ISPs to fulfil data retention or disclosure obligations is mixed. Voice calls over mobile networks or wi-fi are not impacted by Private Relay and so operators can continue to meet any obligations. However, where a user accesses content, the operator can only show a connection to Apple has been made and not the content that was accessed so law enforcement agencies will need assistance from Apple in order to map access to content to an operator.

Copyright Infringement

There may be issues in jurisdictions where ISPs are no longer able to meet the requirements of court-mandated blocking of access to copyright-infringing material and sites. This may require the scope of court orders and regulatory instruments to be expanded to include Apple to maintain their effectiveness.

As we said earlier, some of these issues may not bother you and could even be welcomed (i.e. a small price to pay for the extra privacy afforded), but others are more of a pain. We suspect that some problems may be resolvable by internet sites and services moving to work more closely with Apple, but others will be harder to resolve. But there are potential caveats to doing that too.

The report warns that the partners involved with Apple in the delivery of Private Relay, currently believed to include Akamai, Fastly and Cloudflare, may also find some benefit from the knowledge of sites being accessed through the service, which could conceivably deliver a market advantage. The service may also incentivise content providers to work more closely with Apple friendly CDNs, which might result in market distortions.

In addition, should Private Relay be rolled out more generally in the future, and away from the current subscription model, then it would place Apple at the centre of a high percentage of web transactions. Now that’s a lot of power to be handing one company, even if it does claim that the traffic would all be super private.

As Andrew’s report highlights, “the market dominance of Apple [already] deters companies from going on-record with concerns.” Governments and regulators will no doubt be keeping a close eye on all this. As for consumers, if you have access then it’s probably worth a try, but keep in mind that there are caveats and some things may not work. Beta.