Implementing the UK Integrated Review: building ethical campaigns to defend UK interests against hostile information operations in the Grey Zone

Introduction

The Integrated Review describes itself as a guide for action for those responsible for aspects of national security and international policy across government, including in departments that would not previously have been considered part of the national security community. As the Review concludes ‘responding to state threats can no longer be viewed as a narrow “national security” or “defence” agenda. We must bring together the elements of our work across this Strategic Framework at home and overseas, and all the instruments available to government, in an integrated response.’ Like all high-level strategies, in order to deliver its aims there will have to be coordinated funded programmes of action that engage all the relevant stakeholders in concrete, practical ways in an integrated effort to achieve the common aim.

One of those areas where an integrated response is needed following the Integrated Review is the effective countering of hostile information operations directed against the UK and our allies. There are many relevant activities relating to information operations mentioned at different points in the Integrated Review. They will need bringing together so that each contributor can see how their efforts support the strategic information objective and can be conducted in ways that manifest the values that the Review wishes to support. To that end, this note suggests a high-level simplification.

Such a framework would assist the fleshing out of the new Performance and Planning Framework and the work of the Evaluation Taskforce to check that progress is being made. It would contribute to wider public understanding of how the different actions contemplated fit together and complement each other. Such a framework would also make it easier to manage the inevitable ethical issues that will arise in taking a pro-active stance on information and relevant offensive cyber operations and add reassurance that the programmes will be delivered in accordance with the values set out in the Integrated Review including the need to uphold the rules-based international order. That there is such a need for ethical consideration to be built into the conduct of information operations reflects the important fact that as the former head of the National Cyber Security Centre, Ciaran Martin, has observed: ‘the modern digital domain is a place of social interaction, information exchange, debate, and very, very large-scale commerce. Whatever the legitimate concerns about online harms, it remains, overwhelmingly, a domain of peaceful social and economic activity… the fundamental point is that the domain of operations and the domain of peaceful activity are inseparable’.

that blends four types of protective activity:

1. Intelligence gathering and assessment to identify and attribute potential and actual cyber harms,
2. Encouraging an educated set of Internet users across the UK who apply sound cyber hygiene and passive defences based on authoritative professional cyber security advice from the National Cyber Security Centre (NCSC),
3. Conducting an active intelligence-led defensive effort by the NCSC with the critical national infrastructure, spotting vulnerabilities, proactively monitoring networks, blocking attacks and bad websites and sharing information on threats and responses across the public, private and not-for-profit sectors,
4. Mounting, when necessary, covert offensive efforts, capable of imposing difficulty and cost on those engaged in online terrorist activity, cyber-crime and digital espionage and intellectual property theft.

The same broad classification can be used to define four strategic campaigns to achieve the overall goal of countering the threat of subversive information activity from overseas directed against the British public and those of our allies, including attempts at election interference.

Four Strategic Campaigns to Counter Subversion

Strategic Campaign 1. Detect. Lead Department. Cabinet Office (NSC Staff). The Integrated Review calls for the building of seamless systems to detect malicious activity and act with industry on cyber threat information at scale and pace. As part of this wider effort there will need to be enhanced capability to detect and attribute malign information activity directed at the UK in cyberspace as well as in open conventional and web media, including disinformation and malinformation, malicious web presence and amplification through sock puppets and bots. Given that the potential target of such hostile subversive activity is the British public itself the intelligence lead should be with the Security Service assisted by GCHQ and SIS and SO15, and with the Electoral Commission when activity that could be related to elections is detected. A Joint Analysis and Attribution capability is essential and must be a priority task for the Joint State Threats Assessment Team that is already located in Thames House, alongside the Joint Terrorist Analysis Centre (JTAC) given the likelihood of continuing hostile information activity by terrorist groups that JTAC continues to report on. International cooperation with close allies and through multilateral groups such as the G7 will be important to this campaign.

Strategic Campaign 2. Deflect. Lead department: DCMS, with Home Office. The objective of this campaign should be to increase societal resilience in the UK to all forms of disinformation. One strand is the promise in the Integrated Review of a new regulatory framework under the Online Safety Bill and a media literacy strategy, overseen by DCMS. Another is the existing government Counter Disinformation and Media Development programme that can use the output of joint intelligence analysis to understand and expose the disinformation threat including hostile subversive activities intended to drive a wedge into existing divisions to exacerbate tensions within democratic society. Relevant too is the proposed legislation in the Queen’s Speech to counter hostile State activity including a Foreign Influence Registration scheme.

and contribute to bilateral capacity-building programmes for priority partners overseas. This could include a new awareness campaign to helping the public recognise how the world of social media and ad tech works thus reducing vulnerability to hostile propaganda, disinformation and conspiracy thinking. There are important lessons to learn from the success of the campaign to protect the 2020 US presidential election, run by Chris Krebs heading the US Cybersecurity and Infrastructure Security Agency. The UK Department for Education, with the devolved administrations, should be tasked to develop programmes to teach critical thinking and safe online behaviour from an early age in schools.

Strategic Campaign 3 Defend. Lead department Home Office. The Integrated Review proposals to revise existing offences to deal more effectively with the espionage threat and create new offences to criminalise other harmful activity such as covert influence operations conducted by, and on behalf of, foreign states and to introduce a form of UK foreign agent registration scheme will all help defend against subversion. The NCSC should expand their existing active defence cyber initiatives protecting the government domain (.gov.uk) to other sub-domains within (.uk) such as (.ac.uk). The NCSC should work with Cloud providers to promote comparable degrees of protection for their UK users. The existing cross-government Counter-Disinformation Unit should pro-actively ensure very rapid rebuttal of fake news stories that affect UK interests as part of the coordinated effort. BBC World Service, identified in the Integrated Review as a soft power strength, should be funded sufficiently to allow them to continue robust independent broadcasting of the British voice overseas.

Strategic Campaign 4 Deter. Lead department Cabinet Office. The Integrated Review describes the targeted, responsible offensive cyber capability the UK is building through the National Cyber Force. Offensive operations should be conducted when necessary to raise the cost and difficulty to our adversaries of conducting information operations against us, as well as other forms of cyber-attack and espionage, recognising that these tools of coercion and interference can also be used in ‘hybrid’ combination with more traditional hard power methods. Such counter-subversion activity has to be integrated with the Defending Democracy programme already under way. Offensive operations can be led by the National Cyber Force, under the command of Strategic Command in accordance with the Integrated Operating Concept 2025, supported by the Security and Intelligence Agencies. But strategic direction from government will be needed, such as could be provided from an interdepartmental committee of the NSC chaired by the Cabinet Office.

Ethical Principles to Apply to Counter-Subversion Operations

UK information activity will involve vigorously putting over the UK side of any story. There are likely to be direct and indirect audiences for our messaging given the global reach of digital communications.

• The target audiences – those the UK most wishes to reach directly with its messaging.
• The rest of the world, especially in the global South, whose view of the UK and what we stand for vis a vis our competitors will be influenced both by what we say and how we say it and whether we are being seen to exercise our part of responsible stewardship of the digital environment.
• Our domestic publics, whom we need to continue to support our policies and processes and whom we must not inadvertently mislead by our overseas messaging.

Those planning and conducting strategic campaigns along the four lines set out in this paper should operate according to well accepted ethical principles, whether the campaigns involve technical operations in cyberspace, the use of Artificial Intelligence capabilities or the direct conduct of rebuttal and other overt information activity intended to influence target audiences. Oversight arrangements involving the Parliamentary Intelligence and Security Committee and the Investigatory Powers Commissioner can help provide public and international assurance that in respect of covert activity ethical and legal standards are being upheld in accordance with the Integrated Review’s goal of supporting the rules based international order. The work of all four strategic campaigns outlined above on information operations should be drawn on contribute to the wider international discussion of norms of responsible behaviour in cyberspace.

There are six ethical principles derived from the Just War tradition that underpins international humanitarian law that can help identify where ethical questions will have to be addressed and answered:

• Right intention – ensuring that the UK is always acting for defensible motives and with integrity, taking especial care over the effect on domestic audiences of covert information operations that are intended to influence international opinions unattributably
• Proportionality – keeping the ethical risks being run in line with the seriousness of the harms that UK operations are intended to mitigate, with a case-by-case justification that balances the value of the operation against the ethical risks involved.
• Right authority – the greater the ethical risk, the higher the level of command authority that should be required, thus providing proper accountability for decisions, oversight and an audit trail of who agreed to what – essential to defend reputations when operations become the subject of public debate, as they are occasionally bound to these days when secrets tend not to stay secret for very long.
• Discrimination – the ability to assess the potential for offensive activity (and the operation of defensive systems) to cause harm to individuals or property not foreseen or not tackled during development – particularly if defensive operations have to be conducted swiftly and with great agility using machine learning systems to disrupt servers and networks carrying hostile material. Information operations intended to influence directly those involved in conducting hostile operations against us should avoid harm to family members or other innocent individuals.
• A reasonable prospect of success – requiring operational planners to be able to provide a substantiated justification why they think an operation will contribute to achieving the desired authorized effect, in ways that are sufficiently targeted and not indiscriminate. This will require sufficient effort to be devoted to post-operational analysis of the effect of information activity that has been carried out in order to build up an evidence base.
• Finally, necessity – just because the UK can do it does not mean the UK should. The moral obligation rests on those planning and authorizing information operations that carry ethical risk to consider whether there is any reasonable prospect of achieving the authorized end at lesser risk.

Taken together, knowing that activity is being judged against these principles should provide International and domestic reassurance that the UK is exercising its right to defend itself from hostile activity in ways consistent with our values and commitment to the rule of law in accordance with the strategic objective of the Integrated Review that

Maintaining Trustworthiness

Being seen to be trustworthy is a vital part of reaching all three audiences described in the preceding section, and of being taken seriously. Trustworthy means showing a record of behaviour that demonstrates integrity, consistency, reliability and truthfulness. BBC World Service is a prime example of a service to which target audiences listening in defiance of their own government’s censorship laws, as well as a vast global audience, trust to provide reliable information. It is feared by dictators which is why they harass its staff and try to block with jamming, firewalls and splinternets to keep out unwelcome news and opinions. It is a public service broadcaster that does not charge for its output and an important part of this strategic campaign should be to develop proposals with like-minded nations to incentivise commercial media operations to operate a market in trust, and to promote standards and regulation that will support that objective (as is beginning to happen with international discussions following the Christchurch Call to eliminate terrorist and extremist content online).

A lesson learned in the work of the Political Warfare Executive during the Second World War and subsequently applied in the work of the Information Research Department (IRD) of the Foreign Office during the Cold War is that

During the Cold War for example IRD helped expose the Soviet Gulag through publicising the writings of dissidents smuggled out of the Soviet Union. Although the hand of IRD and the secret intelligence that guided it was hidden, the content of the information being spread was truthful. The experience of the British Army in Northern Ireland in the 1970s reinforced this lesson that maintaining media credibility (today, a global online media) is essential and that allowing suggestions that the UK sanctions attempts at ‘black propaganda’ (what today would be termed promoting ‘fake news’) makes strategic success harder to achieve.

Conclusion

Effective countering of external subversion involves harnessing very different kinds of activity by many different departments and agencies and outside bodies each with their own priorities to a common set of goals. The Integrated Review includes many of the activities that will need to be involved but does not describe how such synergy can be delivered. The four strategic campaigns outlined above would provide a framework for constructing counter-subversion strategy.

not as some might see it handicapping our efforts. That is because the essence of defending ourselves against subversion is to engage in information operations whose very purpose is to influence the minds and actions of others.

Professor Sir David Omand GCB is a Visiting Professor in the Department of War Studies at King’s College London. He is a former Director of GCHQ, Permanent Secretary at the Home Office, and Security and Intelligence Coordinator in the Cabinet Office. He is the author of several books, the most recent of which is How Spies Think: Ten Lessons in Intelligence (London: Penguin Viking, 2020).

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