Vulnerability Disclosure Policy

This is the Water Services Regulation Authority (Ofwat) Security Vulnerability Disclosure Policy.
We recommend reading this disclosure policy document fully before you report any vulnerabilities. This helps ensure that you understand the policy, and act in compliance with it.
We actively endorse and support working with the research and security practitioner community to improve our online security.
Ofwat welcomes investigative work into security vulnerabilities, carried out by well-intentioned and ethical security researchers. We are committed to:

  • Investigating and resolving security issues in our platform and services thoroughly
  • Working in collaboration with the security community

This document explains how Ofwat works with the security research community to improve our online security.
Please note that this document does not provide any form of indemnity for any actions if they are either in breach of the law or of this policy. It does not provide an indemnity from Ofwat or any third party.

Scope

This disclosure policy applies only to vulnerabilities in Ofwat services under the following conditions:

  • to be ‘in scope’ vulnerabilities must be original, previously unreported, and not already discovered by internal procedures
  • volumetric vulnerabilities are not in scope – meaning that simply overwhelming a service with a high volume of requests is not in scope
  • reports of non-exploitable vulnerabilities, or reports indicating that our services do not fully align with “best practice”, for example missing security headers, are not in scope
  • TLS configuration weaknesses, for example ‘weak’ cipher suite support or the presence of TLS1.0 support, are not in scope

Bug bounty

We do not offer a paid bug bounty programme. We will, however, make efforts to show our appreciation to security researchers who take the time and effort to investigate and report security vulnerabilities to us according to this policy wherever we can.

Reporting a vulnerability

If you have discovered something you believe to be an in-scope security vulnerability, first you should check the above details for more information about scope, then email Ofwat Security. ([email protected])
In your email, include details of:

  • The website or page where the vulnerability can be observed
  • A brief description of the type of vulnerability, for example an ‘XSS vulnerability’.

Your report should provide a benign, non-destructive, proof of concept wherever possible. This helps to ensure that the report can be triaged quickly and accurately. It also reduces the likelihood of duplicate reports, or malicious exploitation of some vulnerabilities, such as sub-domain takeovers.
Alternatively, report issues to the National Cyber Security Centre (NCSC). More information about how to do this is available on the NCSC vulnerability-reporting page.

What to expect

After you contact Ofwat Security the team will triage the reported vulnerability, and respond as soon as possible to let you know whether further information is required, whether the vulnerability is in or out of scope, or is a duplicate report. If remediation work is necessary, it is assigned to the appropriate Ofwat teams or supplier(s).
Priority for bug fixes or mitigations is assessed by looking at the impact severity and exploit complexity. Vulnerability reports might take some time to triage or address. You are welcome to enquire on the status of the process, but should avoid doing so more than once every 14 days. The reason is to allow our teams to focus on the reports as much as possible.
When the reported vulnerability is resolved, or remediation work is scheduled, the Security & Privacy team will notify you.
You are invited to give us feedback on the disclosure handling process, the clarity and quality of the communication relationship, and of course the effectiveness of the vulnerability resolution. This feedback will be used in strict confidence to help us improve our processes for handling reports, developing services, and resolving vulnerabilities.

Guidance

Security researchers must not:

  • Access unnecessary amounts of data. For example, 2 or 3 records is enough to demonstrate most vulnerabilities, such as an enumeration or direct object reference vulnerability
  • Use high-intensity invasive or destructive technical security scanning tools to find vulnerabilities
  • Violate the privacy of Ofwat users, staff, contractors, services or systems. For example by sharing, redistributing and/or not properly securing data retrieved from our systems or services
  • Communicate any vulnerabilities or associated details using methods not described in this policy, or with anyone other than their assigned Ofwat security contact
  • Modify data in Ofwat systems or services which does not belong to the researcher
  • Disrupt Ofwat services or systems
  • Social engineer, ‘phish’ or physically attack Ofwat staff or infrastructure
  • Disclose any vulnerabilities in Ofwat systems or services to 3rd parties or the public
  • Require financial compensation in order to disclose any vulnerabilities outside of a declared bug bounty reward structure (such as holding an organisation to ransom)

The last point, about not notifying vulnerabilities to 3rd parties (a party other than yourself and Ofwat) is not intended to stop you notifying a vulnerability to 3rd parties for whom the vulnerability is directly relevant.
An example would be where the vulnerability being reported is in a software library or framework. The point is that details of the specific vulnerability as it applies to Ofwat must not be referenced in such reports. For clarification about whether or when you can notify 3rd parties, contact Ofwat Security.
We ask you to delete securely any and all data retrieved during your research as soon as it is no longer required or within 1 month of the vulnerability being resolved, whichever occurs first.
If at any time you are unsure if your intended or actual actions are acceptable, contact Ofwat Security.

Legalities

This policy is designed to be compatible with common good practice among well-intentioned security researchers. It does not give you permission to act in any manner that is inconsistent with the law, or which might cause Ofwat to be in breach of any of its legal obligations, including but not limited to (as updated from time to time):

  • The Computer Misuse Act (1990)
  • The General Data Protection Regulation 2016/679 (GDPR) and the Data Protection Act 2018
  • The Copyright, Designs and Patents Act (1988)
  • The Official Secrets Act (1989)

Ofwat affirms that it will not seek prosecution of any security researcher who reports any security vulnerability on an Ofwat service or system, where the researcher has acted in good faith and in accordance with this disclosure policy.

Feedback

If you wish to provide feedback or suggestions on this policy, contact Ofwat Security. The policy will naturally evolve over time; your input is welcome and will be valued to ensure that the policy remains clear, complete, and relevant.