Art. 9 GeBüV, Timestamps and DCF 77

Bad news for operators of systems which use the DCF 77 signal for time stamping. According to Art. 9, the following requirements apply when working with changeable memories:

Art. 9 Permissible information carriers

1 For the retention of records are permissible:

  1. ..
  2. changeable information carriers, if:

technical procedures are used which guarantee the integrity of the stored information (e.g. digital signature procedures),

the time at which the information is stored is verifiable in an unforgeable manner (e.g. by “time stamp”)

These requirements are to be understood cumulatively. The timestamp is enormously important, because it can be used to prevent data from being subsequently changed and saved with an old date. Fulfilling this requirement is almost only possible if the timestamp comes from a trusted source (e.g. Time Stamping Provider). Consequently, this means that the time itself must come from a trusted source, which the provider or the client uses to create the timestamp. In many cases, the DCF77 signal is used for this purpose. Unfortunately, it now appears that this source can be duped by simple means. The technical article by Compass employee Reto Schaedler shows how this attack works.

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