The Federal Government Offers a Case Study in Bad Email Tracking

The U.S. government sends a lot of emails. Like any large, modern organization, it wants to “optimize” for “user engagement” using “analytics” and “big data.” In practice, that means tracking the people it communicates with—secretly, thoroughly, and often, insecurely.

Granicus is a third-party contractor that builds communication tools to help governments engage constituents online. The company offers services for social media, websites, and email, and it boasts of serving over 4,000 federal, state, and local agencies, from the city of Oakland to the U.S. Veterans Administration to HealthCare.gov. In 2016, the company merged with GovDelivery, another government-services provider. It appears that parts of the federal government have been working with GovDelivery, now Granicus, since at least 2012. Last October, we took a closer look at some of the emails sent with Granicus’s platform, specifically those from the whitehouse.gov mailing list, which used the GovDelivery email service until very recently. The White House changed its email management platform shortly after we began our investigation for this article. However, several other agencies and many state and city governments still use Granicus as their mailing list distributors.

The emails we looked at, sent to subscribers of the Whitehouse.gov email list in October 2018, happen to be an exemplary case study of everything wrong with the email tracking landscape, from unintentional and intentional privacy leaks to a failure to adhere to basic security standards.

Not only does Granicus know exactly who is opening which email and when, but in the emails we studied, all of that information is sent without encryption by default, so network observers can see it too. Ironically, even the White House’s Privacy Policy is hidden behind one of the tracking links.

How does it work?

We inspected an email from the White House’s “1600 Daily” newsletter sent October 22, 2018. The email uses two common methods to monitor user behavior: pixel tracking and link tracking. We’ll break them down one at a time, using examples from the email itself to illustrate how those methods work in the common case. In addition, we’ve written guidelines for users, email clients, and email providers to protect against these techniques.

Pixel Tracking

Today, almost all emails are sent and read in HTML. An HTML email is treated much like a static web page, with text formatting, custom fonts, and, most importantly, embedded images. When you open an email, your computer or phone needs to load each image from the Internet, which means, depending on the email client you use, your device might send a request to the server that hosts the image.

In emails, a tracking pixel is an “image” included for the purpose of tracking you. It’s usually small (1 by 1 pixel) and invisible. Trackers will often tag on a bunch of extra identifying information to the end of the “image” URL. For instance, they often include information about which email was opened and which email address it was originally sent to. In the White House newsletter I received, the tracking pixel looks like this:

When you open the email, your email client (like Thunderbird or Apple Mail) might send a request to the URL above. As you can see, it points to links.govdelivery.com, a domain owned by Granicus. The biggest part of the URL is the enid parameter, a base64-encoded string. If we decode my email’s enid, we can read the information that’s sent to the third party:

Every time I open this email, my device sends Granicus my email address and a unique identifier for the email that I opened. Granicus knows exactly who I am, which email I’m reading, and when I opened it—and potentially, so might a network observer.

Link Shims

The email also uses link shimming, the practice of obfuscating URLs in emails for tracking purposes, to track which links you click on. (Link shimming, and link tracking more generally, is commonly used on the web by search engines and social media companies.) Take a look at a sample link from the newsletter. When rendered by your email client, it looks like this:

By inspecting the source code, we can see that the blue text above actually points to the following URL:

The first part of the link, in yellow, is nearly identical to the tracking pixel URL we saw before. The redirect URL, in green, points to the article you intended to click. UTM parameters, in blue, allow whitehouse.gov to collect more contextual information about your click.

That mess will take you on a brief visit to govdelivery.com before being redirected to whitehouse.gov, the location of the real press release. Once again, the redirect sends Granicus the enid data, including information about who you are and where you’re coming from. These data, combined with the pixel data from above, allow Granicus to offer “subscriber segmentation” services to its customers (i.e. the government). According to its website, customers can filter individual subscribers by their “targeted message” activity, including whether they received, opened, or clicked a specific email message within a given time frame.

Privacy or Security: Choose None

It’s frustrating enough that the government has been using a third-party service to surreptitiously monitor who opens emails they send, what they click on, when, and from where. What’s worse, in several of the emails we looked at, the tracking is performed over an unencrypted connection using HTTP. This means that all the requests made to Granicus are legible to anyone who could eavesdrop on your connection. If you open one of the emails on unsecured WiFi at an airport or a coffee shop, anyone could be able to monitor your activity and collect your email address.

Perhaps more concerning, using an unencrypted connection allows Internet service providers (ISPs) to collect that sensitive information no matter where you are. Thanks to recent deregulation, ISPs are now legally permitted to sell data about their customers—which could include your email address, political preferences, and information about which government agencies you interact with. Normally, HTTPS protects sensitive information from ISPs’ prying eyes. But in this case, not only can Granicus see which email user clicks on which links; anyone on the network, including the ISP, can too.

The practice of link shimming poses a subtle security risk as well: it makes users more susceptible to phishing. If users are led to click links that look like garbage, they are much more likely to be duped into clicking links from less-than-reputable sources. 91% of cyber attacks start with a phishing email, including many attacks on the government itself. That means that training users to trust insecure, illegible links to unrecognizable domains is a serious problem.

To top it all off, Granicus’s emails are often sent without STARTTLS, a basic protection against passive dragnet surveillance. That means the emails travel around the Internet backbone without encryption, which is just another channel where data about you and your interests may be exposed to snoops on the network. (We recently launched STARTTLS Everywhere to make email delivery more secure.)

Conflicting Reports

After beginning our investigation on October 22, we reached out to both the White House and Granicus for comment regarding their privacy and security practices. The White House didn’t reply, but we did receive a response from Granicus Chief Product Officer Bob Ainsbury:

The private information of both Granicus govDelivery users and govDelivery subscribers is secure. Any claim to the contrary is a very serious allegation and completely inaccurate. ...

Further, email addresses cannot be identified through HTTP connections. All HTTP requests made for the purposes of tracking are transmitted in unrecognizable data and do not allow users’ private information to be compromised at any time.

The claim that the HTTP requests are secure and “do not allow users’ private information to be compromised” is, as we’ve shown above, demonstrably false. The data Granicus transmits are not encrypted, but encoded in base64, which can be decoded by literally anyone.

Furthermore, the company claimed that:

Granicus govDelivery is one of the few email platform providers that has adopted the highest level of data security standards necessary to deliver digital communications for government agencies. That security standard is FedRAMP, which requires platform providers to:

  • encrypt all traffic with FIPS 140-2 validated encryption modules, utilizing TLS 1.1 or higher ...

Its continued use of HTTP for email tracking and failure to support STARTTLS for in-transit email encryption indicate that Granicus has not adopted encryption anywhere near “across the board” when it comes to users’ private information. In that context, the reference to “utilizing TLS 1.1” for “all traffic” is baffling, as we have seen evidence the company continues to use unencrypted HTTP for many of its emails.

Schrödinger’s Trackers

In a strange coincidence, it appears that the White House’s newsletter, “1600 Daily,” ceased using Granicus as its service provider on October 30, 2018, two days before we reached out for comment. It now uses MailChimp for email analytics. MailChimp performs similar types of tracking, using invisible pixels to track email opens and link shims to track clicks, but the company does employ industry-standard security practices like HTTPS. The new tracking pixels are a little more compact, but just as potent:

An example of a tracking pixel from a more recent “1600 Daily” newsletter, which sends information to Mailchimp’s list-manage.com domain (in orange) over HTTPS (in blue) contianing a custom tracking string (in yellow)

According to the Privacy Policy, the White house still uses pixels and link shims to collect “automatically generated email data” from subscribers, including:

A list of “automatically generated email data” the White House collects, according to https://www.whitehouse.gov/privacy-policy/

Other government agencies still use Granicus, such as the Department of Veterans Affairs’ “My HealtheVet” newsletter, the Social Security administration, and HealthCare.gov Alerts. These mailing lists all perform the same kinds of link shimming and pixel tracking we observed in the original White House emails. Some of the emails we've received from Granicus use HTTPS connections to perform tracking, but others still use insecure HTTP. And the company still does not support outbound server-to-server email encryption with STARTTLS.

Moreover, Granicus’s response, included in full below, shows that it doesn’t understand what “secure” means in the context of sensitive user data. Government agencies should be asking some hard questions about how they continue to handle our information.

Protect Your Users; Protect Yourself

Techniques like pixel and link tracking are extremely common and have been around for decades, and it’s unfortunately rare to see them being used responsibly. If you’re a sender, we implore you to think before you track.

Unfortunately, many federal agencies still use Granicus' services, dubious security and all. These agencies should drop GovDelivery in favor of more ethical, more secure analytics, and evaluate how much information they really need to collect to fulfill their missions. Although the White House is no longer using Granicus, it, too, performs extensive tracking on subscribers to its lists. And the only way it offers to opt out is to unsubscribe.

As a user, there’s no fool-proof way to opt-out of leaky email tracking, but there are ways to practice good email hygiene and prevent most forms of it. At the end of the day, the most effective way to avoid the tracking is to follow the White House’s advice and unsubscribe. Just be aware that the “unsubscribe” link is tracked, too.

On November 1, 2018, we reached out to Granicus to request a comment on the company's use of email tracking in services to the U.S. government. The company's response, attributed to Bob Ainsbury, Chief Product Officer at Granicus, is included in its entirety here:

The private information of both Granicus govDelivery users and govDelivery subscribers is secure. Any claim to the contrary is a very serious allegation and completely inaccurate. Granicus govDelivery is one of the few email platform providers that has adopted the highest level of data security standards necessary to deliver digital communications for government agencies. That security standard is FedRAMP, which requires platform providers to:

  • encrypt all traffic with FIPS 140-2 validated encryption modules, utilizing TLS 1.1 or higher
  • provide two-factor authentication to all customers
  • conduct monthly security scans, providing the results to the FedRAMP JAB for review on a monthly basis
  • conduct an annual penetration test and audit of controls to ensure compliance.

Like the world’s other leading email platforms – including several other email systems used at the White House - we do use pixels to track open rates and link shims to track click rates. This is an industry standard that has been in use for over 20 years. It’s used by virtually every major commercial and public sector communicator to track simple email opens and link clicks. It is worth noting, that Granicus govDelivery is configurable, allowing customers to turn off activity capture. 

Further, email addresses cannot be identified through HTTP connections. All HTTP requests made for the purposes of tracking are transmitted in unrecognizable data and do not allow users’ private information to be compromised at any time.

Granicus is committed to the privacy and security for over 4,000 government clients and the citizens who subscribe to receive digital messages using our software, which is why we’ve made the investment to remain FedRAMP, ISO 27001 and GDPR compliant. Privacy and security are our highest and most important priorities at Granicus.


Wednesday 9th January 2019 11:40 pm

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