On a Collision Course: How Domain Name Collision Could be Your Biggest Security Threat

by Snell & Wilmer

We are barely a month into 2014 and one of the news stories that is likely to be most memorable for the year is the Target security breach that resulted in upwards of 70 million customers’ personal information being disclosed. Data and other security breaches are fast becoming a critical issue for any organization that handles third party data.

One of the biggest threats to your company’s data and information technology security may be a problem known as “domain name collision” which can result in your internal data being disseminated on a public network. A “domain name collision” occurs when an attempt to locate an internal address used in a private network results in an inadvertent query on the public Internet.

For example, assume your company’s accounting department has an internal network, and it was set up with the extension of “.money” (as opposed to “.com”). Your accounting department has the records for all of your clients stored on this network with each client’s records stored at a separate extension ending with “.money” (i.e. client Smith would have records on your internal network at http://smith.money”). Until now, you never worried that queries for extensions ending in “.money” would end up anywhere but on your internal network as the “.money” extension was never used for any public networks.

The situation described above is about to change drastically. The Internet Corporation for Assigned Names and Numbers (ICANN) recently unveiled a new program, known as the “New gTLD Program,” making thousands of new generic top level domain extensions (gTLDs) available to the public. Now, instead of being limited to the traditional extensions of .com, .edu, .biz, etc., the Internet is about to expand to include thousands of new top level domain name extensions thanks to the New gTLD Program. Individuals and organizations are in the midst of an application process at ICANN to operate approximately 1,700 new gTLDs. Thus, the amount of top level domain extensions is about to grow exponentially.

What this means is that companies with internal networks that use extensions previously thought to be private could find their sensitive confidential information on a public network because the extension they have been using is now a public gTLD. In the example above, the .money extension used by the accounting department might suddenly query a different server when the .money extension becomes public. This could result in the loss of data on the company’s private network.

Unfortunately, traditional computers and servers are not the only devices that could be affected by domain name collisions. Any device, (such as a networked television, a dialysis machine, a networked printer, etc.) that queries a network could be affected by this issue.

ICANN is aware of the problem and recently undertook a study and other proactive action to assess the risk in order to assist the public in dealing with the domain name collision issue. While ICANN was able to take certain actions to help mitigate the risk of domain name collisions occurring, the possibility of domain name collisions occurring in the wake of the new gTLD program is still significant, and proactive steps should be taken to mitigate this risk within your organization.

The good news is that we are several months away from the new gTLDs going live. This should give your organization time to prepare for the myriad of new gTLDs and take action now to avoid a possible data loss. There are numerous steps that can be taken from both a technical and legal standpoint. For instance, on the technical front, you can closely monitor the new gTLDs and their applicants, and amend your internal network is set up accordingly. From a legal standpoint, revising customer Terms of Use and other agreements to address the issue of domain name collision and limiting liability may be prudent. Further, if a plan is not already in place, a comprehensive plan to address a data breach could also significantly reduce your liability in the event of a data breach caused by domain name collision.


DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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