This article looks at the best practices around publication (of code) to enable open source contribution.
Data Leakage Risk
Financial firms are technology organisations. All such organisations need to worry about Intellectual Property Risk. IP Leakage can happen anywhere. Arguably, risks are greater in finance because of the penalties that regulators may apply.
See: DLP Software for a discussion on the common ways in which regulated firms use DLP software, and how this isn't appropriate for open source contributions.
Publishing the Right Way
There is a right way and a wrong way to publish code to the Internet from within a regulated firm.
Specifically, publication must observe the controls that have been set up to guard against accidental leakage of of intellectual property or secrets.
Warning: Publishing open source by simply pasting it online or emailing it is likely to result in disciplinary procedure.
1. Outgoing Control Process
Developers work inside the firm and contribute Git pull requests via a controlled, monitored process.
- Tools can be used to apply a DLP workflow to the GitHub / GitLab source control processes.
- This is a way to push data over the firewall, but with compliance controls.
- This can introduce extra friction on contributing open source.
- However, these tools may help with evidencing (in the form of records) may need to be provided that data hasn't been leaked (according to regulations).
- This is usually a key requirement to satisfy Data Leakage Risk owners.
It is very easy to accidentally leak data via Git commits because of Git's append-only nature. For example, within a single pull-request you could have a commit containing a file being added containing some leaked confidential data and then a second commit removing that same file. To a reviewer checking only the "diff" of the codebase, no confidential data has been leaked. However, an attacker could review the commits individually. Commit Squashing fixes this by replacing all the individual commits with a single, final-state commit, at the expense of the historical record of how the project has changed.
Risk owners are likely to want to know that the OSPO has a control around which developers are able to contribute to which projects, and historical evidence to show what has been contributed.
- The integrity of the firewall is preserved - developers are not pushing externally on their own.
- It is easy for the OSPO to track which projects are being worked on and contributed to.
- The usual PR / Review process only shows the latest versions of files. It's possible to include some confidential data in one commit, delete it in a later commit and for the DLP reviewer (and the developers) to not have sight of this as it is reviewed. Nevertheless, the data is still exfiltrated to the external repository and available on the Internet.
- The process is slowed down by the need to have a DLP review. The DLP reviewer takes a lot of responsibility and doesn't really see much benefit for their work. In fact, they are usually slowing down the progress of the project.
- Organising this process involves work to set up scripts and rules to allow incoming and outgoing synchronization (partially ameliorated by tools like GitProxy described below)
2. Personal Machines
Contribution from outside the firewall using personal machines might make sense since the user may not be exposed to confidential information on their personal machines.
This approach could prevent accidental leakage of IP. However, from a risk perspective this means that the firm has less purview over what is being released publically.
Note: In some senses, this is a "default" approach, since some staff working at the firm are almost certainly contributing to open source in this way during their own time.
- Depending upon the situation, the only solution to the open source access problem may be to use a personal laptop or computer to access the necessary projects.
- Since the employee's personal laptop doesn't contain firm-confidential information, there should be nearly zero chance of an accidental data-loss event.
- It may be hard to track the productivity of employees working on external projects in this manner.
- Although it is unlikely that client data is leaked inadvertently, it is possible that operational specifics are exposed in open-source projects this way. For example, if the institution had a particular process for dealing with a certain business situation and this process was codified in an open-source project, it would essentially be made public. Tight boundaries around what is industry-public vs. firm-private need to be drawn.
- Coding in this manner might be in voilation of an employee's contract. Make sure approvals are obtained to avoid this scenario.
- Developers are required to have their own devices (since COVID, this is almost a given)
3. Ephemeral Desktops
Like personal machines, but a vm within your desktop that can access nothing inside the firewall.
- Developers work on the firm's hardware as with developing internal software
- However, when working on Open-Source code, they are able to construct an Ephemeral Environment in a virtual machine.
- They develop the code in the environment, destroying it again when they are finished.
- Changes to open-source code and releases are made in public
- Changes / releases to the open-source software are then brought into the institution to use in the institution's software via the usual open-source channels (e.g. Artifactory)
- Developers are still working on the institutions' hardware.
- It should be possible for the institutions to control and monitor ephemeral environments.
- Developers don't need to worry about accidental data exfiltration - the ephemeral environment contains no data from the institution itself.
- Often, ephemeral environments can be congfigured with the tools the developer needs, reducing set-up time.
- This is an area undergoing significant evolution right now and therefore tools are in their infancy.
- It is still possible for developers to deliberately exfiltrate data this way.
- Depending on the tool and the way it interacts with the user's PC, copy-paste accidental exfiltration might also still be possible.
Some Example Tools
- Try pressing the
.key when viewing a GitHub repo. You'll be taken into an online VS-Code instance where you can edit all of the project's files. This is a simple example of a GitHub ephemeral environment - they support a more involved paid-model version which might be appropriate for your organisation.
- See also: GitPod and CodeAnywhere
- For Java developers, EclipseChe
- Microsoft DevBox