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As a response to the COVID-19 pandemic digital contact tracing has beenproposed as a tool to support the health authorities in their quest todetermine who has been in close and sustained contact with a person infected bythe coronavirus. In April 2020 Google and Apple released the Google AppleExposure Notification (GAEN) framework, as a decentralised and more privacyfriendly platform for contact tracing. The GAEN framework implements exposurenotification mostly at the operating system layer, instead of fully at theapp(lication) layer. In this paper we study the consequences of this approach.We argue that this creates a dormant functionality for mass surveillance at theoperating system layer. We show how it does not technically prevent the healthauthorities from implementing a purely centralised form of contact tracing(even though that is the stated aim). We highlight that GAEN allows Google andApple to dictate how contact tracing is (or rather isn't) implemented inpractice by health authorities, and how it introduces the risk of functioncreep.

A Critique of the Google Apple Exposure Notification (GAEN) Framework