Federal Communications Commission: Vulnerability Disclosure Program

Introduction

The Federal Communications Commission (FCC) is committed to ensuring the security of the American public by protecting their information. This policy is intended to give security researchers clear guidelines for conducting vulnerability discovery activities and to convey our preferences in how to submit discovered vulnerabilities to us.

This policy describes what systems and types of research are covered under this policy, how to send us vulnerability reports, and how long we ask security researchers to wait before publicly disclosing vulnerabilities.

We encourage you to contact us to report potential vulnerabilities in our systems.

Authorization

If the FCC determines that you made a good faith effort to comply with this policy during your security research, we will consider your research to be authorized, we will work with you to understand and resolve potential issues quickly, and the FCC will not recommend or pursue legal action related to your research. Should legal action be initiated by a third party against you for activities that were conducted in accordance with this policy, we will make this authorization known.

1 “In the context of [the Cybersecurity and Infrastructure Security Agency’s Binding Operational Directive 20-01], “good faith” means security research conducted with the intent to follow an agency’s [Vulnerability Disclosure Policy (VDP)] without any malicious motive; [the FCC] may evaluate an individual’s intent on multiple bases, including by their actions, statements, and the results of their actions. In other words, good faith security research means accessing a computer or software solely for purpose of testing or investigating a security flaw or vulnerability and disclosing those findings in alignment with the VDP. The security researcher’s actions should be consistent with an attempt to improve security and to avoid doing harm, either by unwarranted invasions of privacy or causing damage to property.” Additional information on what is meant by good faith can be found at https://cyber.dhs.gov/bod/20-01/#what-does-the-directive-mean-by-good-faith.

Guidelines

Under this policy, “research” means activities in which you:

• Notify us as soon as possible after you discover a real or potential security issue.
• Make every effort to avoid privacy breaches, degradation of user experience, disruption to production systems, and destruction or manipulation of data. In the event you encounter personally identifiable information during your testing, you will immediately cease testing and notify the FCC.
• Only use exploits to the extent necessary to confirm a vulnerability’s presence. Do not use an exploit to compromise or exfiltrate data, establish command line access and/or persistence, or use the exploit to pivot to other systems.
• Provide us a minimum of 90 day’s to resolve the issue before requesting to publicly disclose the report.
• Do not submit a high volume of low-quality reports.

Once you’ve established that a vulnerability exists or encounter any sensitive data (including personally identifiable information, financial information, or proprietary information or trade secrets of any party), you must stop your test, notify us immediately, and not disclose this data to anyone else.

Test methods

The following test methods are not authorized:

• Network denial of service (DoS or DDoS) tests or other tests that impair access to or damage a system or data (Such as Brute Force Testing).
• Physical testing (e.g. office access, open doors, tailgating), social engineering (e.g. phishing, vishing), or any other non-technical vulnerability testing.