Completely agree. My interpretation of the guidance is the same (i.e. "continuing to use the exact same systems as were decided on and deployed prior to 11 May would not require a notice and replacing dead hardware with the same thing doesn't require this notice either"). As such, I'd be surprised if there had been a large number of submissions from every operator within 6 months. On 26 November 2014 at 12:00, wrote:

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Today's Topics:

1. Re: FW: Letter to Network Operators 24 Nov 2014 (Alexander Neilson)

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Message: 1 Date: Tue, 25 Nov 2014 12:12:41 +1300 From: Alexander Neilson To: Dave Mill Cc: "nznog(a)list.waikato.ac.nz" Subject: Re: [nznog] FW: Letter to Network Operators 24 Nov 2014 Message-ID: <3B4DF5F6-1C93-4023-AE3E-D5D483D7CC0A(a)neilson.net.nz> Content-Type: text/plain; charset="utf-8"

What I think is missing here is where providers have a standard system they have used with the same hardware before May 11th.

These were decisions made beforehand, no change to deployment, or not covered by an area of specified security interest.

How many people on this list would have changed the manufacturer / type of equipment used in the NOC / core network that meets the threshold in 6 months?

IANAL

However from my lay reading of the guidance and exemptions continuing to use the exact same systems as were decided on and deployed prior to 11 May would not require a notice and replacing dead hardware with the same thing doesn?t require this notice either.

So I am not sure that a low number of notifications is an odd thing unless people had major changes to their core and a short run time to make these changes.

Others may want to chime in with their experiences.

Regards Alexander

Alexander Neilson Neilson Productions Limited

alexander(a)neilson.net.nz 021 329 681 022 456 2326

...

On 25/11/2014, at 11:51 am, Dave Mill wrote:

I'm actually surprised that our GCSB overlords haven't done something like this sooner. To me it seems pretty obvious that not all network providers are using/following the new guidelines. And much better an email like this one than a proper slap by the NCSC/GCSB.

To explain my logic without giving too much away.

We are a small ISP. We have submitted proposals under this new law. Lets call our number of proposals X.

At a technical conference recently the GCSB were able to share with us their rough total number of proposals. That number was also reasonably obvious from the proposal numbering system the NCSC use. Lets call this number Y.

Y wasn't that much bigger than X. I'm talking 5 or 6 times bigger from memory.

We have spent a lot of time and effort in following this new legislation. I think its only fair that others do also (lets not debate whether we needed the legislation here). And with the numbers talked about so far I think its pretty clear that some organisations out there aren't following this new legislation.

At the very least (based on Ray's comments) most network operators should be submitting at least 5 - 10 standard builds each IMHO.

Cheers Dave

On Mon, Nov 24, 2014 at 8:30 PM, Ray Taylor > wrote: I am assuming this refers to notifications about equipment changes, vendor suppliers etc?

It may come as a surprise to these people but most network operators create standards and stick to them!

Ray Taylor

Taylor Communications

ray(a)ruralkiwi.com mailto:ray(a)ruralkiwi.com

Ph 021-483-280

Network status 06-929-9082

From: TICSA [mailto:TICSA(a)ncsc.govt.nz mailto:TICSA(a)ncsc.govt.nz] Sent: Monday, 24 November 2014 3:21 p.m. To: TICSA Subject: Letter to Network Operators 24 Nov 2014

Dear Network Operator

Please find attached a letter to all network operators. This letter shares our surprise at the low number of notifications received from registered network operators to date. We want to reinforce that we are here to support you in meeting your obligations under the TICSA.

We thank those network operators who have actively engaged with us under the TICSA since May.

Kind regards

From the TICSA Team

This electronic message, together with any attachments, contains information that is provided in confidence and may be subject to legal privilege. Any classification markings must be adhered to. If you are not the intended recipient, you must not peruse, disclose, disseminate, copy or use the message in any way. If you have received this message in error, please notify us immediately by return email and then destroy the original message. The Government Communications Security Bureau (GCSB) accepts no responsibility for changes to this e-mail, or to any attachments, after its transmission from GCSB. Thank you.

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