I am working on deciding the technology stack for one of health-related application. We are targetting for HIPAA compliance for the same.
Definitely Native is a good option but I am looking for cost-effective option from development as well as maintenance perspective that's why looking into Flutter Framework. It is satisfying most of the functional as well as technical needs.
I need answers of,
Is there anything inside Flutter framework itself which is not compliant with Hippa?
Any challenges that I can't see at this moment but people have faced in compliance?
Popular third parties not to be used like Firebase, Crashlytics etc? Definitely, at the time of adding new package we will do analysis then we will add it.
Short answer (first bullet): Yes, you can use Flutter in a way that complies with the HIPAA Security & Privacy Rules.
Long Answer (second bullet): You can also use it in a way that violates those rules. At the risk of pedantry, you're asking the wrong question. HIPAA applies to Covered Entities and Business Associates, not to frameworks or applications. A better question is "Is my company HIPAA Compliant?" which means "Have we implemented the 54 safeguards of the Security Rule in a reasonable and appropriate fashion, and are we using and disclosing PHI in ways permissible under the Privacy Rule?"
Third Bullet: If the third party is handling ePHI, they will need to sign a Business Associate Agreement (BAA) - no matter how popular they are. Google's an odd case in that they'll sign a BAA for some, but not all, services. Here's the full list .
I have requirement to store credit card number in iPhone app. How to store the data secure manner. I have looked at keychain. Apart from it, is there anything i can use.
As mentioned above, you should first look into the legality of this, especially with Apple restrictions on what goes in the app store.
That said, I have had to encrypt sensitive information before, and decided to go overboard with AES-256 encryption. Since usernames, passwords and personal data were being sent over a network, it was necessary. I used FBEncrypt for this - it's a great wrapper around CCCrypt.
https://github.com/dev5tec/FBEncryptor
That will allow you to do base-64 encoding and AES-256 encoding, among other things, and it is really convenient. Check it out if you really need it!
This question as stated is difficult to answer. It is up to author(s) of the requirement to determine the level of security needed. They may wish to get some legal advice about what, if any, liability may be incurred for leaking the data.
Once you know the appropriate level of protection, then you can start evaluating solutions. Keychain is good, but there are quite a few encryption options available.
Questions you may want to get answers to besides how to store the number include:
What authentication will be needed to expose the number?
What is the expected lifecycle of the exposed number?
How long can the number stay exposed?
How will the number be purged from memory?
How can the exposed number be used?
Can the number ever be displayed to the user?
Will you allow the number to be copied to the clipboard?
If you want to be serious about protecting information (any information), you need to do some serious design work.
Encryption and the use of SSL/HTTPS seems enough for this case. If you are new to the subj, good general guidelines here: Mobile App Development Tips: How to Ensure Data Security
There are many implementations, e.g. you can use AES256 algorithm mentioned above:
When an app saves a credit card number for the first time, a random
masterKey and initialization vector (IV) are generated. Use them
later for encryption.
A masterSalt is generated and saved locally.
Using plainPassword and masterSalt, a hash (PBKDF2) is calculated.
Using the AES256 algorithm, the calculated hash is used to encrypt
both MasterKey and IV.
Encrypted MasterKey and IV are saved locally.
Decrypt the MasterKey and IV using plainPassword and masterSalt hash
(PBKDF2).
Now, encrypt the data with MasterKey and IV using the AES256 algorithm.
You need to do very serious research into this and not necessarily accept what people on this site say without thorough research and confirmation on your part.
Storing information like credit card info is not something you should implement just based on responses on this site IMO.
If you are serious you need to read, understand and apply the material in the book "Hacking And Securing iOS Applications" to understand what the dangers are and how you can mitigate against them, and how techniques that people say are secure really aren't as secure as you think they might be.
I am building an iPhone app, and I currently need to encrypt a string, store it in a file and be able to decrypt it later. As I understand, I can use symmetric encryption to do this but my key for encryption/decryption can be reversed-engineered. Assymetric encryption can solve this problem but it seems I would need a server to send the data to decrypt with the private key. Does anyone know of a way I can encrypt/decrypt the string securely in a stand-alone app?
Thanks!
As with all matters concerning security, the question is: who are you defending against?
If you are trying to prevent the casual thief (or script kiddie) from reading an encrypted string, using the built-in iOS cryptographic services, such as the Keychain, can provide adequate-to-good security. Obviously the strength of the security will hinge in part on various factors beyond your control (notably, what sort of password lock, if any, the user has configured for the device).
The next level up would be symmetric encryption using a symmetrically encrypted key (i.e. one protected by a user passphrase). As #lukas noted, of course in principle this can be cracked, but from a practical standpoint if the user chooses a sufficiently strong passphrase for a sufficiently large key, a casual to intermediate-level attacker will be effectively thwarted.
If, on the other hand, you need to keep secrets, as Bruce Schneier would say, not from your kid sister but from major world governments, these approaches are likely to be insufficient, and you will have to explore other options, including but not limited to storing the string in multiple locations, using multiple keys, and multiple factors of authentication.
The lead Apple reference for all this (save the last option) is the Secure Coding Guide, which has references at the end of the opening page to the other more specific programming guides (covering, e.g., the Keychain and Cryptographic Services). I also heartily recommend Graham Lee's Professional Cocoa Application Security. If you want a theoretical foundation, the gold standard is Schneier's Applied Cryptography.
This basic question is asked pretty constantly on Stackoverflow. The answer is that you cannot obfuscate yourself to security against your own customers, and you should never spend excessive money trying. I recommend the following links to find the many previous discussions:
Best practices for iOS applications security
Secure https encryption for iPhone app to webpage
From the above you will find several more links. But the final answer is that you are likely trying to solve the wrong problem, and the problem you think you want to solve is unsolvable.
Does anyone know of a way I can encrypt/decrypt the string securely in a stand-alone app?
No. If someone have the physical access to the data it can be cracked. Make a webservice to solve the problem.
Have you considered using Keychain Services?
Its quite annoying sometimes when you have no authentic sources to confirm if particular tasks can be done using iPhone Available (Public) APIs. Whats the preferred way of finding it out?.
Shall we go through iPhone documented APIs,
Ask senior developers ( which i dont prefer, you should not depend on others too much and theres no surety about their opinions ).
Mail Apple ( by the way they offer only 2 technical calls/yr :) ,
Any other ideas?
what do u people suggest?
Thanks Guys!
The public APIs are documented on developer.apple.com in the iOS Reference Library.
However, the only absolutely authentic source on whether their use is acceptable is to submit an app and have it reviewed. Apple just added a review board if you with to appeal a review ruling, so that may be the new last word (unless you get the executive staff's attention (e.g. SJ)).
If you wish more facts before submitting an app, there are a few sites which show which types of apps are being accepted and rejected, and if so, for what given reason. However past acceptance of a type of app is not a precedent or guarantee for any future policy.
If you wish to try interpreting their rules and guidelines yourself, they are available as part of the Developer iOS Standard Agreement.
The Developer support people who answer technical question usually cannot answer review or approval questions, except to point you at the proper API documentation. (The reason may be that these are often legal, corporate policy or marketing questions, not technical questions.)
You can look at official review process from Apple here:
https://developer.apple.com/appstore/resources/approval/guidelines.html
Step 1 : Check the API.
Step 2 : If can't find an way in the API (may be you are looking at wrong API), use Google to find out whether it can be done or not.
Step 3 : If you can't be sure using Google, then ask SO.
IMO, Asking Apple is never an option.
I'm uploading a binary for the first time. iTunes Connect has asked me:
Export laws require that products containing encryption be properly authorized for export.
Failure to comply could result in severe penalties.
For further information, click here.
Does your product contain encryption?
I use https://, but only via NSURLConnection and UIWebView.
My reading of this is that my app doesn't "contain encryption," but I'm wondering if this is spelled out anywhere. "Severe penalties" doesn't sound pleasant at all, so "I think that's right" is a bit sketchy... an authoritative answer would be better.
Thanks.
UPDATE: Using HTTPS is now exempt from the ERN as of late September, 2016
https://stackoverflow.com/a/40919650/4976373
Unfortunately, I believe that your app "contains encryption" in terms of US BIS even if you just use HTTPS (if your app is not an exception included in question 2).
Quote from FAQ on iTunes Connect:
"How do I know if I can follow the Exporter Registration and Reporting (ERN) process?
If your app uses, accesses, implements or incorporates industry standard encryption algorithms for purposes other than those listed as exemptions under question 2, you need to submit for an ERN authorization. Examples of standard encryption are: AES, SSL, https. This authorization requires that you submit an annual report to two U.S. Government agencies with information about your app every January.
"
"2nd Question: Does your product qualify for any exemptions provided under category 5 part 2?
There are several exemptions available in US export regulations under Category 5 Part 2 (Information Security & Encryption regulations) for applications and software that use, access, implement or incorporate encryption.
All liabilities associated with misinterpretation of the export regulations or claiming exemption inaccurately are borne by owners and developers of the apps.
You can answer “YES” to the question if you meet any of the following criteria:
(i) if you determine that your app is not classified under Category 5, Part 2 of the EAR based on the guidance provided by BIS at encryption question. The Statement of Understanding for medical equipment in Supplement No. 3 to Part 774 of the EAR can be accessed at Electronic Code of Federal Regulations site. Please visit the Question #15 in the FAQ section of the encryption page for sample items BIS has listed that can claim Note 4 exemptions.
(ii) your app uses, accesses, implements or incorporates encryption for authentication only
(iii) your app uses, accesses, implements or incorporates encryption with key lengths not exceeding 56 bits symmetric, 512 bits asymmetric and/or 112 bit elliptic curve
(iv) your app is a mass market product with key lengths not exceeding 64 bits symmetric, or if no symmetric algorithms, not exceeding 768 bits asymmetric and/or 128 bits elliptic curve.
Please review Note 3 in Category 5 Part 2 to understand the criteria for mass market definition.
(v) your app is specially designed and limited for banking use or ‘money transactions.’ The term ‘money transactions’ includes the collection and settlement of fares or credit functions.
(vi) the source code of your app is “publicly available”, your app distributed at free of cost to general public, and you have met the notification requirements provided under 740.13.(e).
Please visit encryption web page in case you need further help in determining if your app qualifies for any exemptions.
If you believe that your app qualifies for an exemption, please answer “YES” to the question."
It's not hard to get approval for your app the proper way. SSL (HTTPS/TLS) is still encryption and unless you are using it just for authentication, then you should get the proper approval. I just received approval, and my app is in the store now for something that uses SSL to encrypt data traffic (not just authentication).
Here is a blog entry I made so that others can do this the proper way.
apple itunes export restrictions
Short answer: Yes, but you don't have to do anything
I was searching the web for this for some hours. Actually it is pretty easy and you can verify this in itunes connect:
1. All you have to do
If your app uses only HTTPS or uses encryption only for authentication, tokens, etc., there is nothing you have to do, just include
<key>ITSAppUsesNonExemptEncryption</key><false/>
in your Info.plist and you are done.
2. Verification
You can verify this in itunes connect.
select your app
chose features
chose encryption
click "+"
follow the dialog
for https or authentication the answer is yes and yes
In any case you should of course read yourself carefully through the dialog.
A very helpful article can be found here:
https://www.cocoanetics.com/2017/02/itunes-connect-encryption-info/
I asked Apple the very same question and got the answer (from a Sr. Export Compliance Specialist), that "sending information over https is forcing the data to go through a secure channel from SSL, therefore it falls under the U.S. Government requirement for a CCATS review and approval." Note that it doesn't matter that Apple has already done this for their SSL implementation, but for the government, if you USE encryption that is the same (to them) as you would've coded it yourself. I also updated our blog (http://blog.theanimail.com) since Tim linked to it with updates and details on the process. Hope that helps.
All of this can be very confusing for an app developer that's simply using TLS to connect to their own web servers. Because ATS (App Transport Security) is becoming more important and we are encouraged to convert everything to https - I think more developers are going to encounter this issue.
My app simply exchanges data between our server and the user using the https protocol. Seeing the words "USES ENCRYPTION" in the disclaimers is a bit scary so I gave the US government office a call at their office and spoke to a representative of the Bureau of Industry and Security (BIS) http://www.bis.doc.gov/index.php/about-bis/contact-bis.
The representative asked me about my app and since it passed the "primary function test" in that it had nothing to do with security/communications and simply uses https as a channel for connecting my customer data to our servers - it fell in the EAR99 category which means it's exempt from getting government permission (see https://www.bis.doc.gov/index.php/licensing/commerce-control-list-classification/export-control-classification-number-eccn)
I hope this helps other app developers.
If you use the Security framework or CommonCrypto libraries provided by Apple you do include crypto in your App and you have to answer yes - so simply because libraries were provided by Apple does not take you off the hook.
With regards to the original question, recent posts in the Apple Development Forums lead me to believe that you need to answer yes even if all you use is SSL.
As of September 20th, 2016, registering is no longer required for apps that use https (or perhaps other forms of encryption): https://web.archive.org/web/20170312060607/https://www.bis.doc.gov/index.php/informationsecurity2016-updates
In fact, on SNAP-R you can no longer choose 'encryption registration':
Specifically, they note:
Encryption Registrations no longer required – some of the information
from the registration now goes into the Supp. No. 8 to Part 742
report.
This means you may need to send an annual report to BIS, but you don't need to register and you can note when submitting your app that it is exempt.
Yes, according to iTunes Connect Export Compliance Information screens, if you use built-in iOS or MacOS encryption (keychain, https), you are using encryption for purposes of US Government Export regulations. Whether you qualify for an export compliance exemption depends on what your app does and how it uses this encryption. Attached images show the iTunes Connect Export Compliance Screens to help you determine your export reporting obligations. In particular, it states:
If you are making use of ATS or making a call to HTTPS please note that you are required to submit a year-end self classification report to the US government. Learn more
#hisnameisjimmy is correct: You will notice (at least as of today, Dec 1st 2016) when you go to submit your app for review and reach the Export Compliance walkthrough, you'll notice the menu now states that HTTPS is an exempt version of encryption (if you use it for every call):
I found this FAQ from the US Bureau of Industry and Security very helpful.
encryption
Question 15 (What is Note 4?) is the important point:
...
Examples of items that are excluded from Category 5, Part 2 by Note 4 include, but are not limited to, the following:
Consumer applications. Some examples:
piracy and theft prevention for software or music;
music, movies, tunes/music, digital photos – players, recorders and organizers
games/gaming – devices, runtime software, HDMI and other component interfaces, development tools
LCD TV, Blu-ray / DVD, video on demand (VoD), cinema, digital video recorders (DVRs) / personal video recorders (PVRs) – devices, on-line media guides, commercial content integrity and protection, HDMI and other component interfaces (not videoconferencing);
printers, copiers, scanners, digital cameras, Internet cameras – including parts and sub-assemblies
household utilities and appliances
Simple answers are Yes(App has encryption) and Yes(App uses Exempt encryption).
In my application, I am just opening my company's website in WKWebView but as it uses "https", it will be considered as exempt encryption.
Apple document for more info: https://developer.apple.com/documentation/security/complying_with_encryption_export_regulations?language=objc
Alternatively, you can just add key "ITSAppUsesNonExemptEncryption" and value "NO" in your app's info.plist file. and this way iTunes connect won't ask you that questions anymore.
More info: https://developer.apple.com/documentation/bundleresources/information_property_list/itsappusesnonexemptencryption?language=objc
You can follow these 3 simple steps to verify if your application is exempt or not: https://help.apple.com/app-store-connect/#/dev63c95e436
You may need to submit this annual-self-classification to US gov. For more info: https://www.bis.doc.gov/index.php/policy-guidance/encryption/4-reports-and-reviews/a-annual-self-classification
LOOKS LIKE HTTPS COUNTS
link to "Learn more":
https://www.bis.doc.gov/index.php/policy-guidance/encryption/4-reports-and-reviews/a-annual-self-classification
Just adding my personal interpretation of a very special case:
In my app the user has the option to go to a website themselves or let my app open Safari and Safari will call an HTTPS website. Could be any - own website, article etc etc. I interpret Safari making the actual HTTPS call, not my app and therefore answer the first question with No (or set the flag in the info.plist) and have no requirement to annually report.
If you're not explicitly using an encryption library, or rolling your own encryption code, then I think the answer is "no"