Inside Risks 139, CACM 45, 1, January 2002

Uncommon Criteria
Rebecca Mercuri

The software development process can benefit from the use of established standards and procedures to assess compliance with specified objectives, and reduce the risk of undesired behaviors. One such international standard for information security evaluation is the Common Criteria (CC, ISO IS 15408, 1999, Although use of the CC is currently mandated in the United States for government equipment (typically military-related) that processes sensitive information whose ``loss, misuse, or unauthorized access to or modification of which could adversely affect the national interest or the conduct of Federal programs'' (Congressional Computer Security Act of 1987), it has been voluntarily applied in other settings (such as health care). In the USA, oversight of CC product certification is provided by the National Institute of Standards and Technologies (NIST).

The goal of the CC is to provide security assurances via anticipation and elimination of vulnerabilities in the requirements, construction, and operation of information technology products through testing, design review, and implementation.  Assurance is expressed by degrees, as defined by selection of one of seven Evaluation Assurance Levels (EALs), and then derived through assessment of correct implementation of the security functions appropriate to the level selected, and evaluation in order to obtain confidence in their effectiveness.

However, the use of standards is not a panacea, because product specifications may contain simultaneously unresolvable requirements. Even the CC, which is looked upon as a 'state of the art' standard, disclaims its own comprehensiveness, saying that it is ``not meant to be a definitive answer to all the problems of IT security. Rather, the CC offers a set of well understood security functional requirements that can be used to create trusted products or systems reflecting the needs of the market.'' As it turns out, the CC methodology falls short in addressing and detecting all potential design conflicts.

This major flaw of the CC is directly related to its security functional requirement hierarchy. In selecting an EAL appropriate to the product under evaluation, the CC specifies numerous dependencies among the items necessary for implementing a level's criteria of assurance. In essence, it formulates a mapping whereby if you choose to implement X, you are required to implement Y (and perhaps also Z, etc.). But the CC fails to include a similar mapping for counter-indications, and does not show that if you implement J then you can not implement K (and perhaps also not L, etc.).

A good example of how this becomes problematic arises when both anonymity and auditability are required. The archetypical application of such simultaneous needs occurs in off-site election balloting, but one can also find this in such arenas as Swiss-style banking or AIDS test reporting. If the CC process were to be used with voting (to date, no such standards have been mandated, but NIST involvement is now being considered), it must assure that each ballot is cast anonymously, unlinkably, and unobservably, protecting the voter's identity from association with the voting selections. Because access to the ballot-casting modules requires prior authentication and authorization, pseudonymity through the use of issued passcodes seems to provide a plausible solution. But the CC does not indicate how it is possible to maintain privacy while also resolving the additional requirement that all aliases must ultimately be traceable back to the individual voters in order to assure validity.

Furthermore, the need for anonymity precludes the use of traditional transaction logging methods for providing access assurances. Randomized audit logs have been proposed by some voting system vendors, but equipment or software malfunction, errors, or corruption can easily render these self-generated trails useless. Multiple electronic backups provide no additional assurances, since if the error occurs between the point of user data entry and the writing of the cast ballot, all trails would contain the same erroneous information. Pure anonymity and unlinkability, then, are possible only if authentication and authorization transactions occur separately from balloting, but this is difficult to achieve in a fully-electronic implementation.

The remedy to this and other such flaws in the CC involves augmentation with extensions that go beyond the current standard. For voting, one solution is to produce voter-verified paper ballots for use in recounts. Thus, the use of the CC in the secure product development cycle is encouraged, but prudent application and consideration of risks imposed by conflicting requirements is also necessary.

Rebecca Mercuri ( is an assistant professor of computer science at Bryn Mawr College with a PhD from the University of Pennsylvania. Her dissertation, Electronic Vote Tabulation Checks and Balances, contains a detailed discussion of the common criteria evaluation process. See for further information, including a computer security checklist.