Over on DataBreaches.net, I’ve previously reported on a misconfigured uKnowKids database that left children’s information exposed without any login authentication required. That incident, and their horrid incident response, raised other questions for me, though, about the extent to which kids whose parents have not signed up for the tracking/monitoring service have any privacy rights that may be violated. So I’m cross-posting my post from today in hopes some readers will think about this issue.
There’s an update to uKnowKids’ breach disclosure, here. They assert that their analysis shows only one IP address – presumably researcher Chris Vickery’s – downloaded any data from their misconfigured database. They do not name the provider responsible for security the database. According to their statement, the misconfigured instance of the database occurred on December 29, 2015.
Of note, they provide a breakdown of vulnerable personal information in the exposed database (they make no mention of proprietary information in this context):
|Summary Data||Unique Child Profiles|
|Parent Email Addresses||243||–|
|Child Email Addresses||–||–|
|Credit Card Payment Information||–||–|
|Data Channel Passwords||–||–|
|Mobile Image URLs||1,068,250||1,086|
|Social Network Image URLs||905,791||670|
|Social Network Posts||413,629||856|
|Social Network Tags||6,026||233|
|Social Network Contacts||47,766||273|
One question that has not yet been discussed in the context of this breach is whether in the process of collecting and storing information on tracked/monitored children, whether uKnowKids collects and stores information about those children’s friends and contacts without those children’s knowledge and without their parents’ consent. How many, if any, of the tracked children’s friends and contacts had their pictures and details exposed online because of uKnowKids’ security failure? There were reportedly 1,352 unique child profiles in the misconfigured database. But how many children, total, had information about or from them, or their images, in that database?
I asked Chris Vickery whether there were other kids’ data in the exposed database. Chris answered:
The images did indeed appear to show pictures of friends and kids that are *probably* not the directly monitored child. The most common situation appeared to be John taking pictures of John’s friends on John’s own
phone… not necessarily Jane sending a selfie to John.
So I put two question to uKnowKids:
… did uKnowKids collect and store information about those children’s friends and contacts without those children’s knowledge and without their parents’ consent?
How many, if any, of the tracked children’s friends and contacts had
their pictures and/or messages and/or details exposed through uKnowKids’ failure to secure the MongoDB installation?
uKnowKids’s response to my questions was, in large part:
I also want to emphasize what uKnowKids actually does. We simply aggregate information that belongs to parents, and then make that exact information available to that same parent in a dashboard. We do not have access to any information that does not already belong to that parent. Please refer to our Terms of Service for detailed information about who is legally allowed to use our service as well as their relationship to the information they authorize to uKnowKids to aggregate for them in their uKnowKids dashboard.
So I went back to their TOS, which states, in relevant part:
You are the Legal Owner of the Linked Accounts
You warrant and represent to us that you own the Linked Accounts. Specifically, although Linked Accounts may be established in the names and using credentials for your minor children, you warrant and represent to us that you are the legal owner of all Linked Accounts and you have the legal authority to connect the Linked Accounts to the Services. You agree that it is your sole responsibility to ensure that all accounts used by your children that you wish to monitor are set up as Linked Accounts. Additionally, you agree that various laws may apply to the monitoring of Linked Accounts and that it is your sole responsibility to ensure compliance with any such laws and that uKnow.com expressly disclaims any duty or obligation to do so.
So uKnowKids is aggregating/acting on behalf of a parent who has claimed that they own the linked account being monitored, and all records from that account are therefore the parent’s. While their language and disclaimers may protect them from liability, it still leaves me with some questions.
Does COPPA, Section 5 of the FTC Act, or any other federal statute protect the privacy and security of information or details of other children who interact with the to-be-tracked child in modes that they believe are private communications?
Could inadequately secured images of these non-to-be-tracked children and their messages stored in uKnowKids’ database (if that is confirmed to have happened) violate any federal law?
Yes, I’m asking you all to think of the kids. The other kids. The ones whose parents have no idea uKnowKids may be aggregating and storing information or images concerning their children and is exposing it to other adults who claim to own the accounts.
if uKnowKids or the FTC would like to respond to these questions, I’d be happy to post an update.