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+title: 10 requirements for the evaluation of "Contact Tracing" apps
+date: 2020-04-06 15:19:28 
+updated: 2020-04-06 15:19:28 
+author: linus
+tags: pressemitteilung, updates
+
+"Corona apps" are on everyone's lips as a way to contain the SARS-CoV-2 epidemic. CCC publishes 10 requirements for their evaluation from a technical and societal perspective.
+
+<!-- TEASER_END -->
+
+Currently, technically supported "contact tracing" is being considered
+as means to counteract the spread of SARS-CoV-2 in a more targeted
+manner. The general motivation is to allow greater freedom of movement
+for the broad spectrum of society by allowing quick tracing and
+interruption of infection chains. Contacts of infected persons should be
+alerted more quickly and thus be able to quarantine themselves more
+quickly. This, in turn, should prevent further infections. A "corona
+app" could therefore protect neither ourselves nor our contacts: It
+would be designed to break chains of infection by protecting the
+contacts of our contacts.
+
+## Contact Tracing as a risk technology
+
+There are a number of suggestions for the technical implementation of
+this concept. These proposals range from dystopian systems of full
+surveillance to targeted, completely anonymous methods of alerting
+potentially infected persons without knowledge of the specific person.
+
+In principle, the concept of a "Corona App" involves an enormous risk
+due to the contact and health data that may be collected. At the same
+time, there is a chance for "privacy-by-design" concepts and
+technologies that have been developed by the crypto and privacy
+community over the last decades. With the help of these technologies, it
+is possible to unfold the epidemilogical potential of contact tracing
+without creating a privacy disaster. For this reason alone, all concepts
+that violate or even endanger privacy must be strictly rejected.
+
+In the following, we outline social and technical minimum requirements
+for such technologies. The CCC sees itself in an advisory and
+observation role in this debate. *We will not recommend* specific apps,
+concepts or procedures. We however *advise against* the use of apps that
+do not meet these requirements.
+
+## I. Societal requirements
+
+### 1. Epidemiological sense & purpose
+
+The basic prerequisite is that "contact tracing" can realistically help
+to significantly and demonstrably reduce the number of infections. The
+validation of this assessment is the responsibility of epidemiology. If
+it turns out that "contact tracing" via app is not useful or does not
+fullfil the purpose, the experiment must be terminated.
+
+The application and any data collected must be used exclusively to
+combat SARS-CoV-2 infection chains. Any other use must be technically
+prevented as far as possible and legally prohibited.
+
+### 2. Voluntariness & freedom from discrimination
+
+For an epidemiologically significant efficacy, a "contact tracing" app
+requires a high degree of dissemination in society. This wide
+distribution must not be achieved by force, but only by implementing a
+trustworthy system that respects privacy. Against this background, there
+must be no levying of fees for use as well as no financial incentives
+for usage.
+
+People who refuse to use it must not experience any negative
+consequences. Ensuring this is a matter for politics and legislation.
+
+The app must regularly inform people about its operation. It must allow
+for simple temporary deactivation and permanent removal. Restrictive
+measures, e.g. an "electronic shackles" function to control contact
+restrictions, must not be implemented.
+
+### 3. Fundamental privacy
+
+Only with a convincing concept based on the principle of privacy can
+social acceptance be achieved at all.
+
+At the same time, verifiable technical measures such as cryptography and
+anonymisation technologies must ensure user privacy. It is not
+sufficient to rely on organisational measures, "trust" and promises.
+Organisational or legal hurdles against data access cannot be regarded
+as sufficient in the current social climate of state-of-emergency
+thinking and possible far-reaching exceptions to constitutional rights
+through the Infection Protection Act.
+
+We reject the involvement of companies developing surveillance
+technologies as "covid washing". As a basic principle, users should not
+have to 'trust' any person or institution with their data, but should
+enjoy documented and tested technical security.
+
+### 4. Transparency and verifiability
+
+The complete source code for the app and infrastructure must be freely
+available without access restrictions to allow audits by all interested
+parties. Reproducible build techniques must be used to ensure that users
+can verify that the app they download has been built from the audited
+source code.
+
+## II. Technical requirements
+
+### 5. No central entity to trust
+
+A completely anonymous contact tracing without omniscient central
+servers is technically possible. A dependence of the users' privacy on
+the trustworthiness and competence of the operator of central
+infrastructure is technically not necessary. Concepts based on this
+"trust" are therefore to be rejected.
+
+In addition, promised security and trustworthiness of centralised
+systems - for example against the connection of IP addresses with
+anonymous user IDs - cannot be effectively verified by users. Systems
+must therefore be designed to guarantee the security and confidentiality
+of user data exclusively through their encryption and anonymisation
+concept and the verifiability of the source code.
+
+### 6. Data economy
+
+Only minimal data and metadata necessary for the application purpose may
+be stored. This requirement prohibits the central collection of any data
+that is not specific to a contact between people and its duration.
+
+If additional data such as location information are recorded locally on
+the phones, users must not be forced or tempted to pass this data on to
+third parties or even publish it. Data that is no longer needed must be
+deleted. Sensitive data must also be securely encrypted locally on the
+phone.
+
+For voluntary data collection for epidemiological research purposes that
+goes beyond the actual purpose of contact tracing, a clear, separate
+consent must be explicitly obtained in the app's interface and it must
+be possible to revoke it at any time. This consent must not be a
+prerequisite for use.
+
+### 7. Anonymity
+
+The data that each device collects about other devices must not be
+suitable for deanonymizing their users. The data that each person may
+pass on about themself must not be suitable for deanonymising the
+person. It must therefore be possible to use the system without
+collecting or being able to derive personal data of any kind. This
+requirement prohibits unique user identifications.
+
+IDs for "contact tracing" via wireless technology (e.g. Bluetooth or
+ultrasound) must not be traceable to persons and must change frequently.
+For this reason, it is also forbidden to connect or derive IDs with
+accompanying communication data such as push tokens, telephone numbers,
+IP addresses used, device IDs etc.
+
+### 8. No creation of central movement or contact profiles
+
+The system must be designed in such a way that movement profiles
+(location tracking) or contact profiles (patterns of frequent contacts
+traceable to specific people) can't be established intentionally or
+unintentionally. Methods such as central GPS/location logging or linking
+the data to telephone numbers, social media accounts and the like must
+therefore be rejected as a matter of principle.
+
+### 9. Unlinkability
+
+The design of the temporary ID generation must be such that IDs cannot
+be interpreted and linked without possession of a user controlled
+private key. They must therefore not be derived from other directly or
+indirectly user identifying information. Regardless of the way IDs are
+communicated in the event of infection, it must be ruled out that the
+collected "contact tracing" data can be chained over longer periods of
+time.
+
+### 10. Unobservability of communication
+
+Even if the transmission of a message is observed in the system (e.g.
+via communication metadata), it must not be possible to conclude that a
+person is infected himself or herself or has had contact with infected
+persons. This must be ensured both with regard to other users and to
+infrastructure and network operators or attackers who gain insight into
+these systems.
+
+## Role of the CCC
+
+For well over 30 years, CCC has engaged in voluntary work at the
+intersection between technology and society. [Our ethical
+principles](/en/hackerethics) stand for privacy, decentralization and
+data economy – and against any form of surveillance and coercion.
+
+Without claiming to be exhaustive, in this article we name minimum
+privacy requirements that a "Corona App" must meet in order to be
+socially and technologically tolerable at all. CCC will under no
+circumstances ever provide a concrete implementation with approval,
+recommendation, a certificate or test seal.
+
+It is the responsibility of the developers of contact tracing systems to
+prove the fulfillment of these requirements or to have them proven by
+independent third parties.