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Research Security Requirements and Ontario Colleges and Universities

There’s a lot happening, legislatively in Ontario. One item worth highlighting concerns the requirement for Ontario colleges and universities to develop security research plans.

The federal government has been warning that Canadian academic research is at risk of exfiltration or theft by foreign actors, including by foreign-influenced professors or students who work in Canadian research environments, or by way of electronic and trade-based espionage. In response, the federal government has established a series of guidance documents that Canadian researchers and universities are expected to adhere to where seeking certain kinds of federal funding.

The Ontario government introduced Bill 33, Supporting Children and Students Act, 2025 on May 29, 2025. Notably, Schedule 3 introduces requirements for security plans for Ontario college of applied arts and technology and publicly funded university.

The relevant text from the legislation states as follows:

Research security plan

Application

20.1 (1) This section applies to every college of applied arts and technology and to every publicly-assisted university.

Development and implementation of plan

(2) Every college or university described in subsection (1) shall develop and implement a research security plan to safeguard, and mitigate the risk of harm to or interference with, its research activities.

Minister’s directive

(3) The Minister may, from time to time, in a directive issued to one or more colleges or universities described in subsection (1),

(a) specify the date by which a college or university’s research security plan must be developed and implemented under subsection (2);

(b) specify the date by which a plan must be provided to the Minister under subsection (4) and any requirements relating to updating or revising a plan; and

(c) specify topics to be addressed or elements to be included in a plan and the date by which they must be addressed.

Review by Minister

(4) Every college or university described in subsection (1) shall provide the Minister with a copy of its research security plan and any other information or reports requested by the Minister in respect of research security.

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Japan’s New Active Cyberdefence Law

Japan has passed legislation that will significantly reshape the range of cyber operations that its government agencies can undertake. As reported by The Record, the law will enable the following.

  1. Japan’s Self-Defence Forces will be able to provide material support to allies under the justification that failing to do so could endanger the whole of the country.
  2. Japanese LEAs can infiltrate and neutralize hostile servers before any malicious activity has taken place and to do so below the level of an armed attack against Japan.
  3. The Self-Defence Forces be authorized to undertake offensive cyber operations against particularly sophisticated incidents.
  4. The government will be empowered to analyze foreign internet traffic entering the country or just transiting through it. (The government has claimed it won’t collect or analyze the contents of this traffic.) Of note: the new law will not authorize the government to collect or analyze domestically generated internet traffic.
  5. Japan will establish an independent oversight panel that will give prior authorization to all acts of data collection and analysis, as well as for offensive operations intended to target attackers’ servers. This has some relationship to Ministerial oversight of the CSE in Canada, though perhaps (?) with a greater degree of control over the activities understand by Japanese agencies.

The broader result of this legislative update will be to further align the Japanese government, and its agencies, with its Five Eyes friends and allies.

It will be interesting to learn over time whether these activities are impaired by the historical stovepiping of Japan’s defence and SIGINT competencies. Historically the strong division between these organizations impeded cyber operations and was an issue that the USA (and NSA in particular) had sought to have remedied over a decade ago. If these issues persist then the new law may not be taken up as effectively as would otherwise be possible.

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Implications for Canada of an Anti-Liberal Democratic USA

Any number of commentators have raised concerns over whether the USA could become an illiberal state and the knock on effects. A recent piece by Dr. Benjamin Goldsmith briefly discussed a few forms of such a reformed state apparatus, but more interestingly (to me) is his postulation of the potentially broader global effects:

  • The dominant ideology of great powers will be nationalism.  
  • International politics will resemble the realist vision of great powers balancing power, carving out spheres of influence.  
  • It will make sense for the illiberal great powers to cooperate in some way to thwart liberalism – a sort of new ‘Holy Alliance’ type system could emerge.  
  • The existing institutional infrastructure of international relations will move towards a state-centric bias, away from a human-rights, liberal bias.   
  • International economic interdependence, although curtailed since the days of high “globalisation,” will continue to play an important role in tempering great-power behaviour.  
  • Democracy will be under greater pressure globally, with no great power backing and perhaps active US encouragement of far-right illiberal parties in established and new democracies.  
  • Mass Politics and soft power will still matter, but the post-truth aspect of public opinion in foreign policy will be greater.  

For a middle state like Canada, this kind of transformation would fundamentally challenge how it has been able to operate for the past 80 years. This would follow from the effects of this international reordering and due to our proximity to a superpower state that has broadly adopted or accepted an anti-liberal democratic political culture.

Concerning the first, what does this international reordering mean for Canada when nationalism reigns supreme after decades of developing economic and cultural integrations with the USA? What might it mean to be under a ‘sphere of influence’ with an autocratic or illiberal country? How would Canada appease Americans who pushed our leaders to support other authoritarian governments, or else? Absent the same commitments (and resources) to advocate for democratic values and human rights (while recognizing America’s own missteps in those areas) what does it mean for Canada’s own potential foreign policy commitments? And in an era of rising adoptions of generative AI technologies that can be used to produce and spread illiberal or anti-democratic rhetoric, and without the USA to regulate such uses of these technologies, what does this mean for detecting truth and falsity in international discourse?

In aggregate, these are the sorts of questions that Canadians should be considering and is part of why our leaders are warning of the implications of the changing American political culture.

When it comes to our proximity to a growing anti-liberal democratic political cultural, we are already seeing some of those principles and rhetoric taking hold in Canada. As more of this language (and ideology) seeps into Canadian discourse there is a growing chance that Canada’s own democratic norms might be perverted with extended exposure and following American pressures to compel alterations in our democratic institutions.

The shifts in the USA were not entirely unexpected. And the implications have been previously theorized. An anti-liberal democratic political culture will not necessarily take hold amongstAmericans and their political institutions. But the implications and potential global effects of such a change are before us, today, and it’s important to carefully consider potential consequences. Middle states, such as Canada, that possess liberal democratic cultures must urgently prepare ways to plot through what may be a very chaotic and disturbing next few decades.

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Categorizing Contemporary Attacks on Strong Encryption

Matt Burgess at Wired has a good summary article on the current (and always ongoing) debate concerning the availability of strong encryption.

In short, he sees three ‘classes’ of argument which are aimed at preventing individuals from protecting their communications (and their personal information) with robust encryption.

  1. Governments or law enforcement agencies are asking for backdoors to be built into encrypted platforms to gain “lawful access” to content. This is best exemplified by recent efforts by the United Kingdom to prevent residents from using Apple’s Advanced Data Protection.
  2. An increase in proposals related to a technology known as “client-side scanning.” Perhaps the best known effort is an ongoing European proposal to monitor all users’ communications for child sexual abuse material, notwithstanding the broader implications of integrating a configurable detector (and censor) on all individuals’ devices.
  3. The threat of potential bans or blocks for encrypted services. We see this in Russia, concerning Signal and legal action against WhatsApp in India.

In this broader context it’s worth recognizing that alleged Chinese compromises of key American lawful interception systems led the US government to recommend that all Americans use strongly encrypted communications in light of network compromises. If strong encryption is banned then there is a risk that there will be no respite from such network intrusions while, also, likely creating an entirely new domain of cyber threats.

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An Initial Assessment of CLOUD Agreements

The United States has bilateral CLOUD Act agreements with the United Kingdom and Australia, and Canada continues to also negotiate an agreement with the United States.1 CLOUD agreements are meant to alleviate some of the challenges attributed to the MLAT process, namely that MLATs can be ponderous with the result being that investigators have difficulties obtaining information from communication providers in a manner deemed timely.

Investigators must conform with their domestic legal requirements and, with CLOUD agreements in place, can serve orders directly on bilateral partners’ communications and electronic service providers. Orders cannot target the domestic residents of a targeted country (i.e., the UK government could not target a US resident or person, and vice versa). Demands also cannot interfere with fundamental rights, such as freedom of speech. 2

A recent report from Lawfare unpacks the November 2024 report that was produced to explain how the UK and USA governments actually used the powers under their bilateral agreement. It showcases that, so far, the UK government has used this substantially to facilitate wiretap requests, with the UK issuing,

… 20,142 requests to U.S. service providers under the agreement. Over 99.8 percent of those (20,105) were issued under the Investigatory Powers Act, and were for the most part wiretap orders, and fewer than 0.2 percent were overseas production orders for stored communications data (37).

By way of contrast, the “United States made 63 requests to U.K. providers between Oct. 3, 2022, and Oct. 15, 2024. All but one request was for stored information.” Challenges in getting UK providers to respond to US CLOUD Act requests, and American complaints about this, may cause the UK government to “amend the data protection law to remove any doubt about the legality of honoring CLOUD Act requests.”

It will be interesting to further assess how CLOUD Acts operate, in practice, at a time when there is public analysis of how the USA-Australia agreement has been put into effect.


  1. In Canada, the Canadian Bar Association noted in November 2024 that new enabling legislation may be required, including reforms of privacy legislation to authorize providers’ disclosure of information to American investigators. ↩︎
  2. Debates continue about whether protections built into these agreements are sufficient. ↩︎
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Details from the DNI’s Annual VEP Report

For a long time external observers wondered how many vulnerabilities were retained vs disclosed by FVEY SIGINT agencies. Following years of policy advocacy there is some small visibility into this by way of Section 6270 of Public Law 116-92. This law requires the U.S. Director of National Intelligence (DNI) to disclose certain annual data about the vulnerabilities disclosed and retained by US government agencies.

The Fiscal Year 2023 VEP Annual Report Unclassified Appendix reveals “the aggregate number of vulnerabilities disclosed to vendors or the public pursuant to the [VEP] was 39. Of those disclosed, 29 of them were initial submissions, and 10 of them were reconsiderations that originated in prior years.”1

There can be many reasons to reassess vulnerability equities. Some include:

  1. Utility of given vulnerabilities decrease either due to changes in the environment or research showing a vulnerability would not (or would no longer) have desired effect(s) or possess desired operational characteristics.
  2. Adversaries have identified the vulnerabilities themselves, or through 4th party collection, and disclosure is a defensive action to protect US or allied assets.
  3. Independent researchers / organizations are pursuing lines of research that would likely result in finding the vulnerabilities.
  4. By disclosing the vulnerabilities the U.S. agencies hope or expect adversaries to develop similar attacks on still-vulnerable systems, with the effect of masking future U.S. actions on similarly vulnerable systems.
  5. Organizations responsible for the affected software (e.g., open source projects) are now perceived as competent / resourced to remediate vulnerabilities.
  6. The effects of vulnerabilities are identified as having greater possible effects than initially perceived which rebalances disclosure equities.
  7. Orders from the President in securing certain systems result in a rebalancing of equities regarding holding the vulnerabilities in question.
  8. Newly discovered vulnerabilities are seen as more effective in mission tasks, thus deprecating the need for the vulnerabilities which were previously retained.
  9. Disclosure of vulnerabilities may enable adversaries to better target one another and thus enable new (deniable) 4th party collection opportunities.
  10. Vulnerabilities were in fact long used by adversaries (and not the U.S. / FVEY) and this disclosure burns some of their infrastructure or operational capacity.
  11. Vulnerabilities are associated with long-terminated programs and the release has no effect of current, recent, or deprecated activities.

This is just a very small subset of possible reasons to disclose previously-withheld vulnerabilities. While we don’t have a strong sense of how many vulnerabilities are retained each year, we do at least have a sense that rebalancing of equities year-over-year(s) is occurring. Though without a sense of scale the disclosed information is of middling value, at best.

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VW Leaks Geolocation Data

Contemporary devices collect vast sums of personal and sensitive information, and usually for legitimate purposes. However this means that there are an ever growing number of market participants that need to carefully safeguard the data they are collecting, using, retaining, or disclosing.

One of Volkswagen’s software development subsidiaries, Cariad, reportedly failed to adequately secure software installed in VW, Audi, Seat, and Skoda vehicles:

The sensitive information was left exposed on an unprotected and misconfigured Amazon cloud storage system for months – the problem has now been patched.

In some 466,000 of the 800,000 vehicles involved, location data was extremely precise so that anyone could track the driver’s daily routine. Spiegel reported that the list of owners includes German politicians, entrepreneurs, the entire EV fleet driven by Hamburg police, and even suspected intelligence service employees – so while nothing happened, it seriously could have been a lot worse.

This is a case where no clear harm has been detected. But it speaks more broadly of the continuing need for organizations to know what sensitive information they are collecting, the purposes of the collection, and need to establish adequate controls to protect collected and retained data.

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ASD is Clearly Preparing for a Quantum Future

National cryptological organizations, such as the NSA, CSE, GCHQ, ASD, and GCSB, routinely assess the strength of different modes of encryption and offer recommendations on what organizations should be using. They make their assessments based on the contemporary strength of encryption algorithms as well as based on the planned or expected vulnerabilities of those algorithms in the face of new or forthcoming technologies.

Quantum computing has the potential to undermine the security that is currently provided by a range of approved cryptographic algorithms.1 On December 12, 2024, Australia’s ASD published a series of recommendations for what algorithms should be deprecated by 2030. What is notable about their decision is that they are proposing deprecations before other leading agencies, including the USA’s National Institute of Standards and Technology and Canada’s CSE, though with an acknowledgement that the deprecation is focused on High Assurance Cryptographic Equipment (HACE).

To-be-deprecated algorithms include:

  • Elliptic Curve Diffie-Hellman (EDHC)
  • Elliptic Curve Digital Signature Algorithm (ECDSA)
  • Module-Lattice-Based Digital Signature Algorithm 65 (ML-DSA-65)
  • Module-Lattice-Based Key Encapsulation Mechanism 768 (ML-KEM-768)
  • Rivest-Shamir-Adleman (RSA)
  • Secure Hashing Mechanisms 224 and 256 (SHA-224 and RSA-256)
  • AES-128 and AES-192

Given that the English-speaking Five Eyes agencies regularly walk in near-lockstep we might see updated guidance from the different agencies in the coming weeks and months. Alternately, policy processes may prevent countries from updating their standards (or publicly announcing changes), leaving ASD as a path leader in cybersecurity while other agencies wait until policy mechanisms eventually lead to these algorithms being deprecated by 2035.

Looking further out, and aside from the national security space, the concerns around cryptographic algorithms speak to challenges that embedded systems will having in the coming decade where manufacturers fail to to get ahead of things and integrate quantum-resistance algorithms in the products they sell. Moreover, for embedded systems (e.g., Operational Technology, Internet of Things, and related systems) where it may be challenging or impossible to update cryptographic algorithms there may be a whole world of currently-secure solutions that will become woefully insecure in the not-so-distant future. That’s a future that we need to start planning for, today, so that at least a decade’s worth of work can hopefully head off the worst of the harms associated with deprecated embedded systems’ (in)security.


  1. What continues to be my favourite, and most accessible, explanation of the risks posed by quantum computing is written by Bruce Schneier. ↩︎
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Cybercrime, Advanced Persistent Threats, and Human-Centric Security

RUSI has published a compelling essay arguing that policy makers and threat intelligence groups should focus more time and attention towards the activities of cyber criminals.

Contemporary cyber criminals:

  • have many operational characteristics that parallel those of nation-state supported advanced persistent threats
  • are quickly innovating and developing new exploit processes and chains in reaction to market developments, and
  • have a real and significant impact on the lives of people around the world.

Moreover, criminals are increasingly targeting critical infrastructure, an activity-type which has characteristically been associated with nation-state supported organizations.

While it’s left unstated in the essay, Larson is also implicitly is calling for a focus on human-centric security practices. Such a focus would see policy makers and cyber practitioners work to more actively stymie the worst harms felt by individuals and communities affected by cyber operations or incidents. Such a focus might, also, see countries or organizations shift resources away from impeding nation-state supported threat actors and towards law enforcement agencies and cybersecurity bodies or, alternately, see national governments update operational guidance to prioritize targeting cyber criminals’ organizations or infrastructure using offensive cyber capacities.

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The Data Broker Economy Continues to Endanger Individuals’ Privacy

Mobile advertisers and data brokers routinely collect vast amounts of sensitive information without individuals’ meaningful consent. Sometimes this collection is explicitly mentioned in the terms of service that advertisers provide. However, in many other cases, this collection is linked to “free” functionality services that developers integrate into their applications at the cost of losing control of their users’ data.

These kinds of data brokers fuel a large and mostly invisible data market. But there are times where aspects of it (accidentally) emerge from the shadows.

Recent reporting, first covered by 404 Media, reveals how Fog Reveal sells geolocation services to government agencies. Geofences can be placed around targeted persons’ friends’ and families’ homes, places of worship, doctors’ offices, and offices of a person’s lawyer. Fences can be established retroactively as well as proactively.

These same capacities, it must be noted, can and are also exploited by non-law enforcement agencies. Recent reporting has showcased how the activities of these kinds of data brokers can endanger national security, and they can also put the safety of political and business leaders, to say nothing of regular people, at risk of harm.

Fog Reveal and similar companies are offering an expansive for-sale surveillance capacity. And the capacity, which was once the thing of science fiction, has somehow become banally available for those who can convince private vendors to provide access to the data they have collected.

There remains an open question of how to remedy the current situation: should the focus be on regulating bad actors after they appear or, instead, invest the political capital required to stop the processes enabling the data collection in the first place?