TTCS comments on Draft Trinidad and Tobago National Emergency Communications Plan

The Trinidad and Tobago Computer Society has submitted its comments on the National Emergency Communications Plan (TTCS copy of National Emergency Communications Plan) prepared by the Office of Disaster Preparedness and Management (ODPM), in collaboration with Tobago Emergency Management Agency (TEMA) and the Telecommunications Authority of Trinidad and Tobago (TATT)

Read the TTCS comments on National Emergency Communications Plan (PDF ; 223K)

 

Draft Trinidad and Tobago National Emergency Communications Plan published for comments

Source: pixabay.com

The Office of Disaster Preparedness and Management (ODPM), in collaboration with Tobago Emergency Management Agency (TEMA) and the Telecommunications Authority of Trinidad and Tobago (TATT) are inviting comments on the document titled:

National Emergency Communications Plan

Interested persons are asked to submit comments on this document via TATT’s
Public Consultation Comment Submission Form to the following email address [email protected] on or before Monday October 2nd, 2017.

The TTCS is considering a comment on this Plan and a draft will be shared in the near future.

 

 

Trinidad and Tobago’s Draft National ICT Plan 2017 – 2021 (fastforward II) posted for comment

The Ministry of Public Administration and Communications Trinidad and Tobago has drafted the National Information and Communications Technology (ICT) Strategic Plan 2017-2021, which has been dubbed fastforward II

You can view/download the 73 page document from MPAC’s website or direct download the Draft NICT Plan 2017-2021 (PDF ; 2MB) from TTCS’s website.

The TTCS is building a Google document similar as was done for the Trinidad and Tobago Computer Society comments on the Trinidad and Tobago Cybercrime Bill.

One can submit comments on the draft National ICT plan 2017-2021 via an online form on MPAC’s website.

From the executive summary of Fastforward II :

“fastforward II is Trinidad and Tobago’s five-year National Information Communications Technology (NICT) Plan for 2017 to 2021. The result of co-creation, fastforward II is driven by the needs and priorities of the Government, business, and the people of Trinidad and Tobago—as well as the country’s regional and international obligations. The Plan outlines the NICT Agenda, it builds on our past performance in ICT, and it declares a bold vision to see: empowered people, competitive businesses, and transformational government, through ICT…..

…….The Vision of fastforward II is ultimately to support the National Development Strategy 2016–2030, Vision 2030, which outlines the country’s aspiration to attain “first world nation status” by 2030. Whilst supporting Vision 2030, fastforward II is also expected to meet the country’s anticipated social and economic needs. Converging these needs with the potential of ICT, five Strategic Thrusts are proposed to realise the National ICT Vision. They are:

  1. Improving Connectivity
  2. Increasing Human Capacity
  3. Enhancing Public Service Delivery
  4. Fostering Economic Development
  5. Advancing Environmental and Societal Benefit”

 

Trinidad and Tobago Computer Society comments on the Trinidad and Tobago Cybercrime Bill

The Trinidad and Tobago Computer Society (TTCS) has sent their comments on the Trinidad and Tobago Cybercrime Bill (PDF ; 242K) to the Joint Select Committee of the Trinidad and Tobago Parliament on Friday June 16 2017.

View/Read the TTCS comments on the Cybercrime Bill (PDF ; 242K)

Some of the general areas of concern regarding the Cybercrime Bill noted in our comments:

  1. Suppression of free speech and the work of journalists
    It is important to note that many of the clauses in this Bill can be applied to  journalists carrying out their duties, and/or the free speech of private citizens, as well as to persons who are attempting, in the public interest, to report misconduct (aka whistleblowers). In the interest of support of the Fourth Estate as well as the principles of Free Speech enshrined in our Constitution, this Bill requires urgent complementary whistleblower/journalist protection via legislation.
  2. Excessive Penalties
    A number of sections outline penalties of $100,000 to $3,000,000. These are non-trivial amounts that far exceed the penalties in other areas that many would view as more serious – for example drunk driving. We wonder if the concept of proportionality could be incorporated in this act. The quantum of penalties will have chilling effect on the legitimate use of computers and networks, for example, students learning about computer security and security professionals investigating vulnerabilities on behalf of their clients.
  3. Collateral Damage
    The general trend in technology has been to move towards using shared server resources in the cloud. This opens up the possibility that data and equipment in use by accused persons may be simultaneously used by other persons unrelated to the accused and may thus be unduly affected by the shutdown and/or seizure of such equipment and data. Care must be taken to protect those who are not party to the criminal activities of other persons.
  4. Potential for Censorship and Abuse
    In the interest of protecting the rights of citizens, we believe that all requests for access systems and data should be approved by the Judiciary via the application for, and receipt of, a warrant. This judicial warrant would ensure that any potential for abuse by the State, or its agents, would be mitigated.
  5. Self Incrimination
    Several sections of this Bill seem to run afoul of the Constitution’s directive that persons are protected from self incrimination, for example, the requirement that persons unlock their phones or decrypt their data in furtherance of an investigation. This is a dangerous issue and should be reconsidered.
  6. Training
    It is highly likely that the Courts and Trinidad and Tobago Police Service will be called on to deal many cases under this legislation. As such, it is critical that officers of both agencies receive training in some of technical issues surrounding cyber crime. In this regard the TTCS would welcome the opportunity to assist in providing this training and any specialized advice when required.

The comments were put together by the TTCS based on

Many thanks to the contributors who helped with reviewing and commenting on the bill. For those interested in discussing and sharing ideas about computing, related technologies and related social issues are discussed, do join our announcement mailing list.

TTCS near final draft comments on the Trinidad and Tobago Cybercrime Bill 2017

The Trinidad and Tobago Computer Society (TTCS) has posted a near final draft version of its comments on the Cybercrime Bill 2017 based on the discussions from the Trinidad and Tobago Computer Society lime on Wednesday June 7 2017, comments from subscribers on the TTCS announcement mailing list and a followup TTCS F2F meeting on Tuesday June 13 2017, online comments received following the posting of the TTCS draft comments on the Trinidad and Tobago Cybercrime Bill 2017 on Tuesday June 13 and a online TTCS conference call on Thursday June 15 2017.

With the deadline of Friday June 16 for submission of comments to the Joint Select Committee of the Trinidad and Tobago Parliament , you can view and comment on the Google document of the TTCS near final draft comments on the Cybercrime Bill 2017 – you do not need a Google account to comment on the document.

View/Comment TTCS near final draft comments on Cybercrime Bill 2017

TTCS draft comments on the Trinidad and Tobago Cybercrime Bill 2017

screenshot showing part of the TTCS draft comments on Cybercrime Bill

The Trinidad and Tobago Computer Society (TTCS) has posted a first draft of its comments based on the discussions from the Trinidad and Tobago Computer Society lime on Wednesday June 7 2017, comments from subscribers on the TTCS announcement mailing list and a followup TTCS meeting on Tuesday June 13 2017.

With the deadline of Friday June 16 for submission of comments to the Joint Select Committee of the Trinidad and Tobago Parliament , you can view and comment on the Google document of the TTCS draft comments on the Cybercrime Bill 2017 – anyone can comment on the document directly – you do not need a Google account.

Comments are welcomed.

View/Comment TTCS draft comments on Cybercrime Bill 2017

 

 

Cybercrime Bill 2017

The Cybercrime Bill 2017 was introduced in the House of Representatives by the Attorney General of Trinidad and Tobago Honourable Faris Al-Rawi on May 6 2017.

The purpose of the Cybercrime Bill, 2017 is to provide for the creation of offences related to cybercrime and for other related matters in Trinidad and Tobago and if passed would repeal the Computer Misuse Act 2000

View/Download:

 

 

ICT-related Laws and Policies in Trinidad and Tobago

These series of posts on the Trinidad and Tobago Computer Society’s website documents the various Information and Communication Technology (ICT) related laws and policies that have been introduced and/or proposed in Trinidad and Tobago either in the Trinidad and Tobago Parliament or by various Government ministries, and the Telecommunications Authority of Trinidad and Tobago (TATT) since 1999.

The Trinidad and Tobago Computer Society has commented on many of these policies and links to our comments have also been provided.

Furthermore. we have also linked to local copies of policies that have disappeared with the removal and/or redesign of government websites over time.

ICT Related Laws and Policies sorted by Year

2018

2017

2016

2015

2014

2013

2012

2011

2010

2009

2008

2006

2005

2004

2003

2001

2000

How laws are passed in Trinidad and Tobago

(This is a layperson’s understanding of the process. A lot of information was obtained from the Trinidad and Tobago Parliament’s website.)

Laws are introduced and passed in the Parliament of Trinidad and Tobago which consists of the President of Trinidad and Tobago and two bodies, a House of Representatives and a Senate. The House of Representatives has forty one (41) elected representatives of the constituencies in Trinidad and Tobago. The Senate has 31 senators appointed by the President, sixteen on the advice of the Prime Minister ; six on the advice of the Leader of the Opposition; and nine Independents appointed by the President.

Proposed laws are introduced in either in the House of Representatives or in the Senate as a Bill (Note: certain types of Bills known as “Money Bills” cannot be introduced in the Senate) . The Bill is debated and after a vote, is passed with or without amendments. This Bill (as passed) is then introduced in the other chamber of Parliament where it is similarly debated, possibly amended and voted on.

If there are no amendments to the Bill in the second chamber, then the Bill is passed.

If there are amendments to the Bill in the second chamber, the amendments have to be voted by the chamber where the Bill was first introduced.

Once the Bill in its final form has been approved by both the House of Representatives and the Senate, the Bill as passed becomes an Act. Depending on the the legislation, the Act comes into effect on the Date of Assent, and/or when proclaimed by the President.

 

TTCS comments on “Towards the Treatment of Over The Top (OTT) services” policy document submitted to Telecom Authority of Trinidad and Tobago

tatt-pdf-image-of-towards-the-treatment-of-ott-services

 

The Trinidad and Tobago Computer Society (TTCS ; http://ttcs.tt/) has submitted its comments on the Telecommunications Authority of Trinidad and Tobago (TATT) document “Towards the treatment of Over The Top Services”

The TTCS comments can be viewed at TTCS-comments-on-TATT-Towards-the-treatment-of-OTT-services-public-July20-2015 (PDF ; 369K)

A general comment:

“For the past two decades, TATT has presided over a telecommunications sector which has experienced significant and ongoing growth for all commercial actors. The TATT “light touch” approach is one of the main factors contributing to the success of the sector. The status quo, as facilitated by TATT, should be maintained as the market can and will continue to innovate in the provision of value added services as it has already done for the benefit of clients, consumers, service providers and the country as a whole.

The TTCS fears that any change in the status quo *at the present time* will lead to a stifling of innovation and lead to significantly reduced domestic competition overall.

The treatment of Over The Top (OTT) services is *fundamentally* a Network Neutrality (NN) issue. Once the Telecommunications Authority makes a final decision on where it stands
regarding NN/zero rating of services, its way forward on topics such as OTT becomes much less complex and simple to execute. Over the top services (OTT) can be broad enough to
apply to any service provided over the Internet as a whole, or any future network. If TATT is to consider competition described by providers as “unfair,” then Zero Rated services should also be considered by the Authority in greater detail.

Attempting to make a final decision on OTT without any final decision on NN issues may needlessly complicate the country’s future regulatory landscape, and create precedents
which may limit future regulatory agility and sector innovation and growth. One of the realities of a competitive marketplace is that service providers must innovate constantly or else perish.

The TTCS believes that any regulator should have no vested interest in stifling future sources of innovation in order to preserve revenue streams for service providers. More significantly, any request by service providers that TATT *must* intervene in the regulatory environment in order  to mitigate any loss or potential loss of revenue as a result of technological changes in the sector misunderstands the responsibility of a regulator for the entire sector, and not just one part of it. Increased and differentiated competition and innovation in the telecoms space is to be encouraged, not stifled.

The Trinidad and Tobago Cyber Security Agency Bill, 2015

The Trinidad and Tobago Cyber Security Agency Bill, 2015 was introduced as the same time as the Cybercrime Bill 2015 by the Minister of National Security Brigadier General Carlton Alfonso on May 1 2015.

It seeks to establish a the Trinidad and Tobago Cyber Security Agency (TTCSA) to act as a national point of contact for all cyber security related concerns and other related matters. The functions of the TTCSA are to:

(a) act as the national point of contact for all cyber security related matters;

(b) establish a national computer incident response team to be known as the “Trinidad and Tobago Cyber Security Incident Response Team” (hereinafter referred to as “TT-CSIRT”);

(c) refer matters to the police, where evidence of an offence under the  Cybercrime Act, 2015 comes to its knowledge;

(d) prepare, review and update periodically and in any event at least annually, a national cyber security strategy and prepare such plans as are necessary for the successful implementation of such strategy;

(e) collaborate with the relevant public body in the collection of relevant information which would facilitate the analysis of current and emerging risks, including those risks which could produce an impact on the resilience and availability of data communications networks and on the authenticity, integrity
and confidentiality of the information accessed and transmitted through such
networks;

(f) provide advice on cyber security related matters, including situational awareness information, to the Minister, the Trinidad and Tobago Police Service or such other competent national bodies as are necessary;

(g) enhance cooperation between different actors operating in the field of cybersecurity by holding consultations with, interalia, various industries, universities, public sector bodies and private sector and civil society bodies;

(h) contribute to the awareness raising, and the availability of, current, objective and comprehensive information on cybersecurity by, inter alia, promoting exchanges of current best practices, including methods of alerting users and facilitating cooperation and collaboration between public and private sector initiatives.

(i) develop and publish standards for products and services on cyber security;

(j) establish and publish baseline cyber security requirements and standards for
various sectors including operators of critical infrastructures;
(k) conduct research and development in the area of cyber security and identify critical research and development needs, gaps and emerging trends for future research;

(l) promote the development of training and education programmes including the accreditation and certification of cyber security academic programmes;

(m) advise the Minister on research in the area of cyber security as well as on the effective use and adoption of risk preventative technologies;

(n) promote risk assessment activities, interoperable risk management solutions and studies on cyber security management solutions within public and private sector bodies;

(o) collaborate with the relevant public body in the provision of educational guidelines to the national community, as to the appropriate use of the national network infrastructure;

(p) establish internal and joint procedures between the public and private sectors  to manage the incidents and mitigate the threats associated with them;

(q) provide appropriate strategic insights to policy and decision-makers and public bodies in order to strengthen the national network infrastructure;

(r) develop a National Cyber Security Contingency Plan;

(s) coordinate cyber security exercises; and

(t) express independently its own conclusions and orientations and give advice on matters within its scope and objectives.

The Bill lapsed with the end of the Parliamentary session on June 17 2015.