Improving the Reliability and Resilience of Canada’s Digital Infrastructure

Executive summary

The following set of recommendations were created in response to a request from the Minister of Innovation, Science and Industry to the Canadian Forum for Digital Infrastructure Resilience (CFDIR). The request highlighted the importance of digital infrastructure in all aspects of Canadian economic and social activity. The Minister also noted the important role of the products, services, and infrastructure provided by CFDIR member organizations for both Canada's digital resilience and economy. The Minister's letter was sent November 1, 2022 with a six-month deadline.^{Footnote 1}

The Minister asked for a collaboratively prepared set of recommendations to improve the reliability and resilience of Canada's digital infrastructure. Presented below are:

• The method used to prepare and present our recommendations.
• Our recommendations to improve the reliability and resilience of Canada's digital infrastructure:
  • Three recommendations of a General nature
  • Twelve recommendations to ensure that Canada has Robust Networks and Systems underpinning its digital infrastructure
  • Eight recommendations to ensure that there is Coordinated Planning and Preparation to respond to threats to our digital infrastructure
  • Three recommendations concerning Strengthening Accountability to drive for resilience by our digital infrastructure stakeholders

Recommendations table

Introduction

CFDIR is Canada's private-public forum through which industry and key federal partners work together to improve policy regarding digital infrastructure resilience. This document presents recommendations from CFDIR's industry representatives to inform the Minister of Innovation, Science and Industry regarding what steps should, as priorities, be taken to enhance Canadian digital infrastructure resilience.

In the summer of 2022, millions of Canadians experienced first-hand the difficulty of technological disruption during the Rogers outage^{Footnote 2} and Hurricane Fiona. These events – during which millions of Canadians were without access to critical Internet technology, businesses were unable to accept payments and host customers, and government services were rendered inaccessible – demonstrated the urgency to improve resilience.

Digital infrastructure resilience ensures that the digital infrastructure technologies in Canadian society work at an acceptable level despite disruptions due to events such as extreme weather, human error, cyber-attacks. As the technological landscape is complex and ever-changing, achieving resilience is no simple feat. Digital infrastructure resilience is critical to support a trusted and thriving digital economy and society. From the individuals interacting with technology every day, to the companies that develop, deploy, protect, harden, monitor and sell the technology, to the government framing of regulatory and other policies, all stakeholders have active roles to play in supporting the resilience of the digital infrastructure ecosystem.

Achieving widespread digital infrastructure resilience requires a comprehensive understanding of the relevant technologies, how they operate, and how they interact with each other and with different stakeholders. Because these technologies, and the standards which they are expected to meet, are almost wholly developed by the ICT industry, industry's voice in this effort is critical.

Methodology

The Canadian Forum for Digital Infrastructure Resilience is a consensus-based and action-oriented public-private collaboration that was formed to enhance understanding of, and recommend improvements to, the resilience of Canadian critical digital infrastructure. Innovation, Science and Economic Development Canada (ISED) established CFDIR in 2020, in part to support Canada's National Strategy for Critical Infrastructure (CI). Under this strategy, ISED is the lead federal department for the information and communication technology (ICT) sector. CFDIR brings together key federal partners and industry to improve digital infrastructure resiliency.

CFDIR working groups are industry-led and comprise participants from CFDIR member organizations. The working groups undertake agreed-upon projects. Working group focus areas have included:

• Cloud Resilience
• Quantum Readiness
• Supply Chain Assurance
• Internet Resilience
• Internet of Things (IoT)

Definitions of digital infrastructure, critical services, reliability and resilience can be problematic, if one goes beyond the high level. What digital infrastructure is in scope, and does it include everything that is connected anywhere? Which services, beyond 911, are considered critical? How does one measure reliability or resilience for that digital infrastructure and for those critical services given that failures may be hard (e.g., complete outage) or soft (e.g., slow response time), widespread (e.g., national) or localized (e.g., neighbourhood or cell tower), long-lasting or momentary, and so on.

CFDIR's practical view is that critical services are those that Canadians depend upon for their livelihood, well-being and security. The digital infrastructure in scope includes at least those assets that provide such services. Reliability is the degree to which our digital infrastructure is protected from failure. Resilience is the degree to which our digital infrastructure protects critical service to users and is rapidly restored to operation when failures do occur. Canadians expect their digital infrastructure to have sufficient reliability and resilience so that their livelihood, well-being, and security are not threatened by digital infrastructure failures whatever the cause.

While cyber security is an immensely important aspect of resilient digital infrastructure, most of the recommendations from CFDIR do not specifically address cyber security. Cyber security is inherent in some topics – most notably quantum readiness, which is all about proactive responses to an impending cyber threat to digital infrastructure. CFDIR has, to this point, not attempted to comprehensively address the cyber security of digital infrastructure, and defers to the recommendations of Public Safety Canada, CSE/CCCS, and others, who provide leadership on cyber security.

The recommendations in this document were provided by CFDIR's working groups and collated by a CFDIR team, the Canadian Cyber Resilience Working Group. Following a rigorous review and approval process involving all CFDIR members, our recommendations are presented and discussed below under four headings – General Recommendations and the three categories of ISED's Telecommunications Reliability Agenda – robust networks and systems, coordinated planning and preparedness, and strengthening accountability.^{Footnote 3}

• Robust Networks and Systems (RNS) Recommendations

  These are recommendations that will identify and address the digital infrastructure elements required to support Canadian digital infrastructure resilience. Digital infrastructure resilience depends on the appropriate design and construction of hardware and software systems of the underlying communication, processing, and storage assets. Digital infrastructure resilience can be enhanced to a great degree through a combination of redundancy and diversity in network interconnections, reducing the risk of disruption due to network failure or cyberattack.

•  Coordinated Planning and Preparedness (CPP) Recommendations

  These are recommendations that outline how we prepare for and rapidly recover from inevitable failures. Robust Networks and Systems are necessary but not sufficient to ensure digital infrastructure resilience. Twenty-first century digital infrastructure is a complex system of systems with components that rapidly evolve. Moreover, the threats to digital infrastructure are diverse and rapidly evolving. Consequently, digital infrastructure failures are inevitable. Preparing for such events can allow services to recover rapidly despite the failure of parts of the system – a key measure of resilience.

• Strengthening Accountability (SA) Recommendations

  Recommendations of this type relate to reporting or maturity models that allow us to assess how well we are doing and what we ought to share within or between industries and their stakeholders (e.g., users, the general public, government, regulators) to educate others and ensure that our digital infrastructure is resilient and reliable from a full lifecycle perspective.

  Data and reporting are essential if we are to know that networks and systems are robust as well as whether our planning and preparedness is effectively dealing with the threats to our digital infrastructure. Accountability begins with knowing how well that infrastructure is performing, when issues arise, and how failures are addressed in a timely manner. 

In some instances, recommendations may span multiple categories. We have endeavoured to group recommendations based on their primary focus without trying to constrain the recommendations as provided by industry.

Recommendations

General recommendations

G 1: Cabinet position responsible for ensuring government-wide coherence and action on cyber security policy and technology goals

Today, cyber security responsibilities in the Federal Government are distributed across at least 12  departments and agencies^{Footnote 4}. Creating coherence across government to ensure that all departments operate with a unity of effort and purpose is essential to fostering digital resilience. These coordinated efforts must span policy and program development, procurement and the use of approval and funding powers to foster and ensure that actions and activities lead to outcomes that are cybersecure and resilient.

Canada's international counterparts have similar bodies that can serve as a frame of reference. For example, the US appointed its first White House National Cyber Director in July 2021 to serve as the President's principal advisor on cyber security^{Footnote 5}; the UK has a Parliamentary Under Secretary of State for Digital and Broadband who is responsible for cyber security and cyber security skills^{Footnote 6}; and Australia created a standalone cyber minister in June 2022.^{Footnote 7}

Recommendation: The minister should ask Cabinet to consider the creation of a Cabinet position, taking the best aspects of each of the above models, would send a strong signal that Canada is serious about cyber security and digital resilience.

G 2: Skills, talent and training

The Information and Communications Technology Council^{Footnote 8} and the CD Howe Institute^{Footnote 9} both report on the digital and technical skill shortage facing the Canadian labour market. The importance of having a digital infrastructure workforce that is both scaled and skilled cannot be overstated. 

The availability and ability of that workforce could be improved through actions that address the following:

1. Across career stages: Digital infrastructure skilling is required for current and future students in higher education as well as for those currently in the workforce who require upgrading.
2. Technical, operations, lines of business, legal, human resources, procurement, senior management, board of directors, policy makers: Digital infrastructure skilling or readiness goes far beyond technology and extends across entire organizations as they establish or augment “digital cultures” for their operations. The decreased time to market for innovation creates a digital disruption that extends to the lines-of business, legal, human resources, management, and more. Skilling must occur across the business to ensure organizational alignment.
3. Common curriculum, mainstream: There is currently no standardized curriculum for cloud computing, supply chain, quantum readiness and other digital infrastructure resilience topics across Canadian educational communities. Digital infrastructure curriculum should be standardized across the country, emphasizing security, privacy, and resilience. Furthermore, it should be “mainstreamed” (rather than included only as electives) in Computer Science, Software Engineering, Electrical Engineering, Computer Engineering and similar programs.
4. Immigration and clearances: Given the talent deficit, Canada should improve immigration processes for newcomers with digital infrastructure skills. Since many vacant positions in the digital infrastructure sector require security clearances, the government should streamline and accelerate clearance processes for new Canadians with those skills. 

Recommendation: Government, industry and academia work together on a priority basis to develop and implement an aggressive plan to ensure that Canada has at its disposal the talent pool needed to build, install, upgrade, maintain and protect Canada's digital infrastructure.

G 3: Maintaining and leveraging CFDIR

CFDIR is a forum for ensuring that resilience is continuously considered, designed, implemented, and maintained in Canada's digital infrastructure. It is a relatively new forum but has already brought together many ICT companies and thought leaders, and its working groups are actively working to improve the resilience of Canada's digital infrastructure. The Government should avoid creating additional groups or forums with a similar mandate and ensure that the role of CFDIR is recognized within all relevant departments.

Recommendation: ISED should continue its strong support CFDIR and leverage CFDIR work as much as possible.

Robust networks and systems recommendations

RNS 1: Resilience requirements for broadband funding programs

Recommendation i: All governments should require applicants seeking support from broadband funding programs to demonstrate how their proposed investments in broadband infrastructure would enhance the resilience of broadband networks. This applies to funding programs such as ISED's program Connect to Innovate: Rural and Remote, and programs offered by the CRTC, and the Ministry of Indigenous Affairs.

Recommendation ii: The federal government should ensure that regional ISPs have access to transport services to the nearest Internet exchange point (IXP) to increase their resilience. This can be achieved by providing transport directly to critical infrastructure services like Domain Name Servers (DNS) resolution. 

Recommendation iii: The federal government, for the next round of Universal Broadband Fund applications and any future broadband funding programs should consider how transport to regional ISPs is supported in the funding program; how the resilience of the Internet connection to the regional ISP is achieved; how to ensure that there are no single points of failure in the provisioned Internet access; and how to ensure there is sufficient capacity in terms of Internet transit and transport services.

RNS 2: Incumbent ISPs' transport network leasing

Many Canadian Internet Service Providers (ISPs) interconnect with only one upstream provider, often physically located far away from the ISP's area of operation. This single interconnection is a potential single point of failure that leaves that ISP vulnerable to outages suffered by their upstream provider. Sometimes the lack of alternative interconnect options is due to the upstream network providers refusing to sell transport connectivity to other providers or to Internet Exchange Points served by other providers.

Recommendation: The Minister should request that the CRTC initiate a public proceeding to determine the extent of the refusal of some upstream providers (notably large incumbent ISPs) to sell affordable transport to smaller ISPs, and if there are regulatory or other means to remedying the situation.

RNS 3: Improving peering policies for better Internet resiliency

Major Internet Exchange Points have been established to enable ISPs in Canada to exchange internet traffic (which is referred to as “peering”). However, most of Canada's large incumbent ISPs will not peer openly in existing IXPs, to the detriment of smaller ISPs who may already have established a presence in these IXPs. That is, the incumbent ISPs would rather serve Canadian organizations as customers than directly peer with them at an IXP. 

As a result of the efforts of these incumbent ISPs, which carry most of Canada's traffic, to avoid Canadian IXPs, the bulk of Canadian consumer-to-consumer traffic and consumer-to-enterprise traffic is routed by Canada's incumbents via the US (and US IXPs) rather than through Canada. The performance of some services in Canada, such as private web conferencing and the like, is impeded by traffic being routed north-south rather than east-west, meaning that Canadian consumers as well as smaller Canadian ISPs are disadvantaged.

Recommendation: CFDIR should initiate a conversation with the Canadian Security Telecommunications Advisory Committee (CSTAC) about how to improve the relationship between the Canadian IXPs and incumbent ISPs with the goal of:

• Encouraging a more permissive peering policy by those ISPs and a gradual transition to keeping more traffic in Canada.
• Peering with any critical infrastructure networks that are present at the IXP so they can rapidly begin to exchange traffic in these IXPs with all IXP members in the event of an outage.

RNS 4: Prioritizing competition and diversity of facilities providers

The continued expansion of telecommunications and cable network facilities enhances the redundancy, and therefore the resilience, of the Canadian Internet. Competition among facilities providers that results in a diverse array of providers building and operating their networks is integral to the redundancy and resilience of Canada's Internet.

Recommendation: The Canadian Radio-television and Telecommunications Commission and Innovation, Science and Economic Development Canada should continue to support and create favourable conditions for competition among network operators for key Internet facilities, including but not limited to back-haul, transport and last-mile.

RNS 5: Upstream Internet network provider bill of materials

Just as a construction company can list the materials and components used to build a structure for the structure's owner, ISPs providing network access in Canada should be required to make available, on demand, a list of their upstream Internet network providers. This would allow Canadian consumers and enterprises to better understand the components that make up their Internet access, to identify and mitigate against potential single point of failure, and to assist in determining their own level of Internet access resilience. This requirement would increase transparency and awareness of the Internet network access dependencies, resulting in improved decision-making and risk management for consumers and enterprises.

Recommendation: ISPs providing network access in Canada should be required to make available to customers, on demand, a list of their upstream Internet network providers.

RNS 6: Updating Internet transit procurement based on 2023 Internet standards

According to APNIC Labs, the Government of Canada does not require certain key standards and protocols for its Internet access deployments. APNIC Labs provides research, measurement, and technical reports on the use of certain key Internet standards and protocols, such as IPv6, DNSSEC and RPKI ROA validation (The Canadian Government operates its networks using autonomous number AS2675):

• https://stats.labs.apnic.net/ipv6/AS2675
• https://stats.labs.apnic.net/dnssec/AS2675
• https://stats.labs.apnic.net/roa/AS2675

Recommendation: The Government of Canada should review its requirements for Internet transit procurement and ensure that its own networks and those of critical infrastructure providers conform to the most current standards and best practices.

This review should consider items such as the following:

• Support for full dual-stack IPv4 and IPv6 transit for protocol redundancy.
• That transit capabilities include peering arrangements with relevant Canadian IXPs who have an appropriately permissive peering policy.
  • For example, peering with critical infrastructure providers inside Canada.
  • At a minimum, peering with DNS providers like .CA, .COM, and root servers.
• That Internet service providers:
  • List their upstream Internet network providers to assist in understanding their level of redundancy and resiliency.
  • Have service level agreements covering availability and quality of service for both IPv4 and IPv6 traffic.
  • Adopt best practices, such as MANRS, BCP38 (Network Ingress Filtering), DNSSEC validations, RPKI.
  • Demonstrate commitment to ongoing implementation of key Internet standards, protocols, technologies, and best practices as they advance.

RNS 7: Documenting the state of multiple concurrent Internet connection solutions

Stakeholders should work together to develop a guide for multi-homing Internet solutions. A business or even a residence is “multi-homed” when it has concurrent Internet connections from more than one ISP. Multi-homing is a very complicated topic and solutions diverge based on resiliency requirements.

Such a guide could include information on the different types of multi-homing solutions available for different types of users (e.g., home, small business, enterprise), the pros and cons of each solution, and recommendations for choosing the right solution based on individual needs and requirements. Cost is an important factor to include in each of the scenarios. The guide should document the various options available to automate the switchover from the primary to the backup connection to eliminate downtime.

The development of the guide would involve experts in the field, such as network engineers, ISPs, and government representatives, to share their knowledge and experiences. They could also conduct surveys and research to better understand the current state of multi-homing Internet solutions in Canada and identify gaps in knowledge or areas where more information is needed.

Once the guide has been developed, it could be disseminated through various channels, such as online resources, training programs, and workshops, to ensure that individuals and organizations have access to the information they need to make informed decisions about their Internet solutions.

Recommendation: Industry should create a guide to multi-homing Internet solutions and ensure that it is disseminated.

RNS 8: Adopting international standards and best practices

Canada lags in the adoption of compliance standards for a number of areas of digital infrastructure, such as cloud services, IoT, supply chain and quantum computing. The federal government's specification of bespoke requirements for suppliers not only adds friction to any service delivery initiative, these Canada-unique requirements add cost and technical debt. Financial services, the energy sector, transportation and other regulated critical infrastructure participants have embraced international standards such as ISO, SSE SOC, Cloud Security Alliance and others to demonstrate sufficiently high levels of assurance for the adoption of these services in their communities. 

Recommendation: The Government of Canada should move to adopt international standards and clearly communicate which standards it supports in procuring cloud services and other digital infrastructure. The Government of Canada should consider existing standards from the US and EU. The Government of Canada should also actively participate in international standards development activities for those standards that are adopted.

RNS 9: Supporting national resilient connectivity

Canada's critical infrastructure, including digital infrastructure, has a significant north/south dependency. There are many vital points in Canada where damage arising from environmental or other causes to one location could significantly impact a variety of critical services at a regional or wider scale. Often there is a bias on a particular modality of communication. This may change due to the priorities of the local telecom providers and their infrastructure ambitions. 

Recommendation: The Government of Canada should look to increase geographic route diversity from east to west within Canada for critical digital infrastructure, considering a portfolio of communications media, including fibre, wireless (4G, 5G, Whitespace WiFi) and LEO Satellite to support resilience.

RNS 10: Financial incentives for resilience

Resilience often requires additional investment as failsafe, redundant, duplicative paths and employees are required to ensure continued operation of services under difficult conditions. 

Recommendation: The Government of Canada should consider incentives for organizations to improve their resilience to failures in their primary provider's network.

RNS 11: Designating or creating a critical infrastructure (CI) network provider

Many of Canada's CI providers rely upon the public Internet provided by an ISP. In the event of a major Internet disruption at their ISP, a CI provider could fall back to a designated Critical Infrastructure Network Provider to maintain connectivity between CI systems that are key to providing critical services.

Recommendation: The Government of Canada should evaluate the feasibility and benefits of designating or creating a trusted Critical Infrastructure Network Provider operating such an emergency CI backbone. Designated CI providers must connect to this CI backbone, using a zero-trust architecture.

RNS 12: Interdependency of national digital infrastructure systems

There is a growing interdependency among the systems comprising Canada's digital infrastructure. It is therefore difficult to understand how our digital infrastructure normally operates, and extremely difficult to anticipate the impact of failures. The issue should not be ignored.

Recommendation: The Government of Canada, with industry collaboration, should build a comprehensive program to understand and manage the interdependent deployment of the technological systems that make up Canada's digital infrastructure. Such a program should begin with the systems that are relied on by Canada's CI sectors. This program could consider, among other things, the need for post-quantum cryptography-safe (PQC) and quantum-safe technologies and should include meaningful input and support from all of Canada's CI sectors.