Internet-Draft CFBL Address Header June 2021
Benecke Expires 31 December 2021 [Page]
Workgroup:
Network Working Group
Internet-Draft:
draft-benecke-cfbl-address-header-00
Published:
Intended Status:
Experimental
Expires:
Author:
J. Benecke
CleverReach GmbH & Co. KG

Complaint Feedback Loop Address Header

Abstract

This document describes a method to allow a mail sender to specify a complaint feedback loop address as an email header and how a mail receiver can use it. This document also defines the rules for processing and forwarding such a complaint. The motivation for this arises out of the absence of a standardized and automated way to provide a complaint feedback loop address to mailbox providers. Currently, providing and maintaining such an address to a mailbox provider is a manual and time-consuming process.

Status of This Memo

This Internet-Draft is submitted in full conformance with the provisions of BCP 78 and BCP 79.

Internet-Drafts are working documents of the Internet Engineering Task Force (IETF). Note that other groups may also distribute working documents as Internet-Drafts. The list of current Internet-Drafts is at https://datatracker.ietf.org/drafts/current/.

Internet-Drafts are draft documents valid for a maximum of six months and may be updated, replaced, or obsoleted by other documents at any time. It is inappropriate to use Internet-Drafts as reference material or to cite them other than as "work in progress."

This Internet-Draft will expire on 31 December 2021.

Table of Contents

1. Introduction and Motivation

Since a long time there is a way to forward manual complaints back to e.g. a broadcast marketing list operator. The mailbox provider provides a so-called feedback loop [RFC6449]. This feedback loop is being used to give e.g. operators of broadcast marketing lists feedback about resulting complaints from their marketing mailings. Those complaints are based on manual user interaction e.g. IMAP movement to "Junk".

As described in [RFC6449] the registration for such a feedback loop needs to be done manually by a human at any FBL provider he wants to receive complaints from. Which can be quite time-consuming if there are new feedback loops rising up, or the mail sender wants to add new ip addresses or DKIM domains. Besides, a manual process isn't well suitable and/or doable for smaller mailbox providers.

The change of such a complaint address e.g. due to an infrastructure change is another problem. Due to this manual process the mail sender needs to go through all providers again and delete his existing subscriptions and re-signup with the new complaint address.

This document addresses this problem with a new email header. It extends the described complaint feedback loop recommendations in [RFC6449] with an automated way to provide the complaint feedback loop address to mail receiver.

Mail senders can add this header and willing mailbox provider can use this header to forward the generated report to the provided complaint address. The mail sender just needs to add a email header and isn't required to signup manually at every feedback loop provider. Another benefit would be the mailbox provider doesn't need to develop a manual registration process and verification process.

A new email header has been chosen over a new DNS record in favour to be able to easily distinguish between multiple broadcast marketing list operators / mail senders, without the intervention of its users or administrators. For example, if a company uses multiple sending systems, each system can set this header on their own, without the need of a change that has to be done by its users or administrators. On the side of the mailbox provider, there is no need to do an additional DNS query to get the complaint address.

This document has been created with GDPR and other data-regulation laws in mind and to address the resulting problems in providing an automated complaint feedback loop address, as the email may contain personal data.

Summarised this document has following goals:

2. Definitions

The keywords "MUST", "MUST NOT", "REQUIRED", "SHALL", "SHALL NOT", "SHOULD", "SHOULD NOT", "RECOMMENDED", "NOT RECOMMENDED", "MAY", and "OPTIONAL" in this document are to be interpreted as described in BCP 14 [RFC2119] [RFC8174] when, and only when, they appear in all capitals, as shown here.

The keyword "FBL" in this document is the abbreviation for "feedback loop" and will hereafter be used.

The keyword "CFBL" in this document is the abbreviation for "complaint feedback loop" and will hereafter be used.

The keyword "MBP" in this document is the abbreviation for "mailbox provider" and will hereafter be used.

3. Requirements

3.1. Complaining about an email

The email (sent by mail sender/broadcast marketing list operator) about which a complaint should be sent MUST have at least one valid [DKIM] signature, which covers the From-Header [MAIL] domain. The email about which a complaint should be sent MUST be aligned as specified in [DMARC]. The Complaint-FBL-Address header MUST be covered by the signature, it MUST be included in the "h=" tag of the valid DKIM-Signature header field.

If the message isn't properly aligned, nor it does have the required header coverage by [DKIM], the MBP SHOULD NOT send a report email.

This ensures that only reports are sent to the complaint address that are based on an authenticated email.

3.2. Report email

The report email (sent by MBP to mail sender) MUST have a valid [DKIM] signature and MUST cover the From-Header [MAIL] domain.

If the message does not have the required valid [DKIM], the mail sender SHOULD NOT process this email.

It is highly RECOMMENDED that the mail sender does further plausibility checks.

4. Implementation

4.1. Mail senders

A mail sender that wishes to receive complaints about their mailings MUST place a Complaint-FBL-Address in the message. The mail sender MAY place a Feedback-ID header in the message out of various reasons.

The receiving complaint FBL address, placed in the message, MUST accept [ARF] compatible reports. It is highly RECOMMENDED processing these ARF reports automatically and unsubscribe the complaining receivers.

The mail sender MUST take action to address the described requirements in Section 3.

4.2. Mailbox provider

An MBP MAY process the complaint and forward it to the complaint FBL address.

If the MBP wants to process the complaints and forwards it, he MUST query the Complaint-FBL-Address header.

An [ARF] compatible report MUST be sent when a manual action has been taken, e.g. when a receiver marks a mail as spam, by clicking the "This is spam"-button in any web portal or by moving a mail to junk folder, this includes also IMAP/POP3 movements. The MBP SHOULD NOT send any report when an automatic decisions has been made, e.g. spam filtering.

The MBP MUST validate and take action to address the described requirements in Section 3.

5. Complaint report

The complaint report (sent by MBP to mail sender) MUST be an [ARF] report. The report MUST contain at least the Message-ID [MAIL] or the header "Feedback-ID" of the complaining email.

The MBP MAY omit all further headers and/or body to comply with any data-regulation laws.

It is highly RECOMMENDED that, if used, the Feedback-ID includes a hard to forge component such as an [HMAC] using a secret key, instead of a plain-text string.

6. Header Syntax

6.1. Complaint-FBL-Address

The following ABNF imports fields, WSP, CRLF and addr-spec from [MAIL].

fields /= cfbl-address

cfbl-address = "Complaint-FBL-Address:" 0*1WSP "<" addr-spec ">" CRLF

6.2. Feedback-ID

The following ABNF imports fields, WSP, CRLF and atext from [MAIL]. It imports ALPHA and DIGIT from [RFC5234].

fields /= feedback-id

feedback-id = "Feedback-ID:" 0*1WSP fid CRLF

fid = 1*(atext | ":")

7. Security Considerations

This section discusses possible security issues, and their possible solutions, of a complaint FBL address header.

7.1. Attacks on the FBL address

As any other email address, a complaint FBL addresses can be an attack vector for malicious emails. The complaint FBL addresses can be for example flooded with spam. This is an existing problem with any existing email address and isn't newly created by this document.

The broadcast marketing lists operator/mail sender must take appropriated measures. One possible countermeasure would be a rate limit on the delivering IP. However, this should be done with caution, the normal FBL email traffic must not be impaired.

7.2. Enumeration attacks / provoking unsubscription

A malicious person can send a bunch of forged ARF reports to a known complaint FBL addresses and try to guess a Message-ID/Feedback-ID. He might try to do a mass-unsubscription of a complete marketing list. This is also an already existing problem with the current FBL implementation.

The receiving broadcast marketing lists operator/mail sender must take appropriated measures.

As a countermeasure it is recommended that the Message-ID and, if used, Feedback-ID uses a hard to forge component such as an [HMAC] using a secret key, instead of a plain-text string, to make an enumeration attack impossible.

If it is impossible for the broadcast marketing lists operator/mail sender to use a hard to forge component, the broadcast marketing lists operator/mail sender should take measures to avoid enumeration attacks.

7.3. GDPR and other data-regulation laws

Providing such a header itself doesn't produce a data-regulation law problem. The resulting ARF report, that is sent to the mail sender by the MBP, may conflict with a data-regulation law, as it may contain personal data.

This document already addresses some parts of this problem and describes a data-regulation law safe way to send a FBL report. As described in Section 5, the MBP may omit the complete body and/or headers and just sends the required fields. Nevertheless, each MBP must consider on their own, if this implementation is acceptable and complies with the existing data-regulation laws.

As described in Section 5, it is also highly RECOMMENDED that the Message-ID and, if used, the Feedback-ID includes a hard to forge component such as an [HMAC] using a secret key, instead of a plain-text string. See Section 9.3 for an example.

Using HMAC, or any other hard to forge component, ensures that only the mail sender has knowledge about the data.

8. IANA Considerations

8.1. Complaint-FBL-Address

The IANA is requested to register a new header field, per [RFC3864], into the "Permanent Message Header Field Names" registry:

Header field name: Complaint-FBL-Address

Applicable protocol: mail

Status: experimental

Author/Change controller: Jan-Philipp Benecke <jpb@cleverreach.com>

Specification document: this document

8.2. Feedback-ID

The IANA is requested to register a new header field, per [RFC3864], into the "Permanent Message Header Field Names" registry:

Header field name: Feedback-ID

Applicable protocol: mail

Status: experimental

Author/Change controller: Jan-Philipp Benecke <jpb@cleverreach.com>

Specification document: this document

9. Examples

For simplicity the DKIM header has been shortened.

9.1. Simple

Email about the report will be generated:

Return-Path: <sender@mailer.example.com>
From: Awesome Newsletter <newsletter@example.com>
To: me@example.net
Subject: Super awesome deals for you
Complaint-FBL-Address: <fbl@example.com>
Message-ID: <a37e51bf-3050-2aab-1234-543a0828d14a@mailer.example.com>
Content-Type: text/plain; charset=utf-8

This is a super awesome newsletter.

Resulting ARF report:

Feedback-Type: abuse
User-Agent: FBL/0.1
Version: 0.1
Original-Mail-From: sender@mailer.example.com
Arrival-Date: Tue, 23 Jun 2020 06:31:38 GMT
Reported-Domain: example.com
Source-Ip: 192.0.2.1

------=_Part_240060962_1083385345.1592993161900
Content-Type: text/rfc822; charset=UTF-8
Content-Transfer-Encoding: 7bit

Return-Path: <sender@mailer.example.com>
From: Awesome Newsletter <newsletter@example.com>
To: me@example.net
Subject: Super awesome deals for you
Complaint-FBL-Address: <fbl@example.com>
Message-ID: <a37e51bf-3050-2aab-1234-543a0828d14a@mailer.example.com>
Content-Type: text/plain; charset=utf-8

This is a super awesome newsletter.
------=_Part_240060962_1083385345.1592993161900--

9.2. GDPR safe report

Email about the report will be generated:

Return-Path: <sender@mailer.example.com>
From: Awesome Newsletter <newsletter@example.com>
To: me@example.net
Subject: Super awesome deals for you
Complaint-FBL-Address: <fbl@example.com>
Message-ID: <a37e51bf-3050-2aab-1234-543a0828d14a@mailer.example.com>
Feedback-ID: 111:222:333:4444
Content-Type: text/plain; charset=utf-8

This is a super awesome newsletter.

Resulting ARF report contains only the Feedback-ID:

Feedback-Type: abuse
User-Agent: FBL/0.1
Version: 0.1
Original-Mail-From: sender@mailer.example.com
Arrival-Date: Tue, 23 Jun 2020 06:31:38 GMT
Reported-Domain: example.com
Source-Ip: 192.0.2.1

------=_Part_240060962_1083385345.1592993161900
Content-Type: text/rfc822-headers; charset=UTF-8
Content-Transfer-Encoding: 7bit

Feedback-ID: 111:222:333:4444
------=_Part_240060962_1083385345.1592993161900--

9.3. GDPR safe report with HMAC

Email about the report will be generated:

Return-Path: <sender@mailer.example.com>
From: Awesome Newsletter <newsletter@example.com>
To: me@example.net
Subject: Super awesome deals for you
Complaint-FBL-Address: <fbl@example.com>
Message-ID: <a37e51bf-3050-2aab-1234-543a0828d14a@mailer.example.com>
Feedback-ID: 3789e1ae1938aa2f0dfdfa48b20d8f8bc6c21ac34fc5023d63f9e64a
       43dfedc0
Content-Type: text/plain; charset=utf-8

This is a super awesome newsletter.

Resulting ARF report contains only the Feedback-ID:

Feedback-Type: abuse
User-Agent: FBL/0.1
Version: 0.1
Original-Mail-From: sender@mailer.example.com
Arrival-Date: Tue, 23 Jun 2020 06:31:38 GMT
Reported-Domain: example.com
Source-Ip: 192.0.2.1

------=_Part_240060962_1083385345.1592993161900
Content-Type: text/rfc822-headers; charset=UTF-8
Content-Transfer-Encoding: 7bit

Feedback-ID: 3789e1ae1938aa2f0dfdfa48b20d8f8bc6c21ac34fc5023d63f9e64a
       43dfedc0
------=_Part_240060962_1083385345.1592993161900--

10. Acknowledgments

Technical and editorial reviews and comments were provided by colleagues at CleverReach, and the colleagues at Certified Senders Alliance. Legal reviews and comments were provided by the colleagues at the Certified Senders Alliance.

11. References

11.1. Normative References

[ARF]
Shafranovich, Y., Levine, J., and M. Kucherawy, "An Extensible Format for Email Feedback Reports", RFC 5965, DOI 10.17487/RFC5965, , <https://www.rfc-editor.org/info/rfc5965>.
[DKIM]
Crocker, D., Ed., Hansen, T., Ed., and M. Kucherawy, Ed., "DomainKeys Identified Mail (DKIM) Signatures", STD 76, RFC 6376, DOI 10.17487/RFC6376, , <https://www.rfc-editor.org/info/rfc6376>.
[DMARC]
Kucherawy, M., Ed. and E. Zwicky, Ed., "Domain-based Message Authentication, Reporting, and Conformance (DMARC)", RFC 7489, DOI 10.17487/RFC7489, , <https://www.rfc-editor.org/info/rfc7489>.
[MAIL]
Resnick, P., Ed., "Internet Message Format", RFC 5322, DOI 10.17487/RFC5322, , <https://www.rfc-editor.org/info/rfc5322>.
[RFC2119]
Bradner, S., "Key words for use in RFCs to Indicate Requirement Levels", BCP 14, RFC 2119, DOI 10.17487/RFC2119, , <https://www.rfc-editor.org/info/rfc2119>.
[RFC5234]
Crocker, D., Ed. and P. Overell, "Augmented BNF for Syntax Specifications: ABNF", STD 68, RFC 5234, DOI 10.17487/RFC5234, , <https://www.rfc-editor.org/info/rfc5234>.
[RFC8174]
Leiba, B., "Ambiguity of Uppercase vs Lowercase in RFC 2119 Key Words", BCP 14, RFC 8174, DOI 10.17487/RFC8174, , <https://www.rfc-editor.org/info/rfc8174>.

11.2. Informative References

[HMAC]
Krawczyk, H., Bellare, M., and R. Canetti, "HMAC: Keyed-Hashing for Message Authentication", RFC 2104, DOI 10.17487/RFC2104, , <https://www.rfc-editor.org/info/rfc2104>.
[RFC3864]
Klyne, G., Nottingham, M., and J. Mogul, "Registration Procedures for Message Header Fields", BCP 90, RFC 3864, DOI 10.17487/RFC3864, , <https://www.rfc-editor.org/info/rfc3864>.
[RFC6449]
Falk, J., Ed., "Complaint Feedback Loop Operational Recommendations", RFC 6449, DOI 10.17487/RFC6449, , <https://www.rfc-editor.org/info/rfc6449>.

Author's Address

Jan-Philipp Benecke
CleverReach GmbH & Co. KG
Schafjueckenweg 2
26180 Rastede
Germany