(Submitted by Overseas Security Advisory Council) Digital contact-tracing mobile applications have become a useful mitigation tool for countries and private-sector organizations alike in the fight against COVID-19. South Korea and Singapore were among the first to deploy a digital version of contact tracing, a key reason those countries have experienced relatively few coronavirus cases. In the United States, such measures have fallen largely to tech companies, resulting in a rare partnership between Apple and Google to develop contact-tracing technology that will operate on both iOS and Android phones. However, other countries have implemented apps that raise serious security concerns for private sector operators. This report looks at the issue as a whole, and examines its implications in two key countries for OSAC members. Using Contact Tracing Applications While governments and major companies work to create and monitor tracing apps, private sector organizations have also begun acquiring mobile applications and wearable devices to track and stop the spread of coronavirus in the workplace. PricewaterhouseCoopers (PwC), which is building its own contact tracing app, noted that nearly a quarter of chief financial officers they surveyed plan to evaluate the technology as part of an office reopening strategy. A recent survey of 300 OSAC members received similar results; 22% of respondents noted that their organization was considering the use of contact tracing mobile applications to identify and track possible COVID-19 infections, with another 3% reporting that their organization was already using these applications. These responses were highest in Asia, where almost 30% of respondents reported either considering or currently using contact tracing mobile applications. As organizations consider mandating these technologies in the workplace, many questions arise such as whether participation actually makes employees safer (or just feel so), if apps are legal and appropriate to deploy and mandate for employees, and if the technology will work as advertised in the field. The legality and appropriateness of mandated digital contact tracing in the workplace is likely to differ by country and organization. Also, organizations may need more time and experience to fully understand how well the technology will work, and how it will impact employee safety. Regardless, the mandated use of these technologies present cybersecurity and privacy concerns that can and should be examined before considering or committing to any new platform. GPS vs Bluetooth The two primary forms of digital contact tracing mobile applications are those that rely on GPS and those that use Bluetooth. GPS-based apps, such as those in South Korea and Israel, are the most intrusive on privacy, since they track and communicate user locations and movements to a centralized source (like the government). They can pinpoint potential locations of exposure, as well as the phones of the users who appear to have been in close contact with an individual. Meanwhile, those that rely on Bluetooth technology, like the apps in Singapore and Australia, can tell you when you might have been exposed to COVID-19, but they are more decentralized and will not tell a user where or to whom they were exposed. Privacy advocates prefer the latter for these reasons. Some legal experts argue that the optimal design for private-sector organizations from a privacy point of view leverages Bluetooth technology without giving the employer access to the server containing the information. Companies Behind the Apps In addition to understanding the technical backbone on which these applications rest, organizations should also consider the developers and their track records with cybersecurity and privacy issues. There is a wide variety of companies seeking to develop this technology and earn their share of what may prove to be a lucrative market moving forward. These include all types of organizations, from traditional business software and professional services companies like PwC and Salesforce, to technology startups and cyber intelligence firms. According to Reuters, at least eight surveillance and cyber-intelligence companies are attempting to sell re-purposed spy and law enforcement tools to track COVID-19 and enforce quarantines. Executives at four of those companies said they are piloting or in the process of installing products to counter coronavirus in more than a dozen countries in Latin America, Europe, and Asia. One of the more controversial companies in this group is the Israel-based cyber intelligence firm, NSO Group. The surveillance software-developer is currently being sued by WhatsApp for allegedly helping governments hack 1,400 targets, to include activists, journalists, diplomats, and state officials using its signature software, Pegasus. The company also faces another lawsuit in which it is accused of supplying software to the Saudi Arabian government, which allegedly used it to spy on the journalist Jamal Khashoggi before his murder. While these platforms, which largely rely on GPS location data, have primarily marketed to governments, organizations interested in employing digital contact tracing tools within their facilities and workforce should also be wary of clandestine technologies traditionally used for surveillance. Beyond the damage that such technologies could cause to an organization’s business image or employee trust, they could also present significant data privacy concerns, depending on how the data is collected, stored, and accessed. Organizations should also monitor which countries are adopting these more privacy-invasive technologies, as countries more predisposed to dissent suppression and other digital authoritarian practices could easily abuse then. Two Significant Case Studies OSAC has received inquiries from the private sector regarding digital contact tracing apps that host governments are mandating for employees. According to MIT Technology Review’ COVID-19 Tracing Tracker, 25 countries currently have significant automated contact tracing efforts in place, and five of those countries (Bahrain, China, India, Qatar and Turkey) mandate use of tool . Two case studies address how mandated use might impact U.S. private-sector employees operating in the world’s two most populous countries. China Color-Coded Health Passes China has rolled out a color-coded health system based on travel history and contact tracing to monitor new COVID outbreaks. While downloading the app is not mandatory, the health code is necessary to enter public places such as public transportation, residential compounds, hospitals, workplaces, or schools, or to travel domestically. If an individual…