The proposed law aims to overhaul rules governing the way the authorities can access people's communications.
The US-based firm has passed on its thoughts to a parliamentary committee scrutinising the legislation.
It
focuses on three issues: encryption, the possibility of having to hack
its own products, and the precedent it would set by agreeing to comply
with UK-issued warrants.
The Home Secretary Theresa May said last month that the proposed powers were needed to fight crime and terror.
Monday
was the final deadline for written evidence to be received by the
committee scrutinising the draft legislation. It is expected to report
in February 2016.
Blocking a backdoor
Apple's submission to the committee runs to eight pages.
The first issue raised is encryption.
Apple designs some of its products - including iMessage - using a technique called end-to-end encryption.
This
means only the sender and recipient of a message can see it in an
unscrambled form. The company itself cannot decrypt the contents.
This is something that law enforcement agencies have complained about.
Apple
says that ensuring the security and privacy of customer's information
against a range of malicious actors - such as criminals and hackers - is
a priority.
Current legislation demands that companies take
reasonable steps to provide the contents of communications on production
of a warrant, but that has not been interpreted as requiring firms to
redesign their systems to make it possible.
The government had
briefed at the time that the bill was published that the legislation did
not constitute any change to existing legislation.
But Apple
appears to be concerned that the bill's language could still be
interpreted more expansively and force the creation of a so-called
"backdoor" to provide the authorities with access.
Apple argues
that the existence of such a backdoor would risk creating a weakness
that others then might exploit, making users' data less secure.
"A key left under the doormat would not just be there for the good guys. The bad guys would find it too," the company says.
It notes it still provides metadata - data about a communication
- when requested, but not the actual content.
Overseas warrants
A second area of concern relates to the issue of "extra-territoriality".
Existing
British legislation - and the bill - maintain that companies need to
comply with warrants for information wherever they are based and
wherever the data resides.
The government argues this is vital when criminals and terrorists often use communications
platforms based in other countries.
US
companies have long resisted extra-territoriality on the basis that if
they accept they are obliged under UK law, then they fear other
countries - they often point to Russia and China - will simply demand
the same right, and that such assertions may conflict with the privacy
laws of the countries in which the data is held.
There have been
discussions - led by former British Ambassador to Washington Sir Nigel
Sheinwald - to try to come to some form of agreement between the US, UK
governments and Silicon Valley to overcome some of the concerns and
facilitate better sharing of data.
Hacked customers
A third concern from Apple relates to the provisions of the bill relating to "equipment interference".
This
refers to a range of techniques used by police and intelligence
agencies, which extend from hacking into devices remotely to interfering
with the hardware itself.
This is one way around the spread of
encryption and is one of the areas of activity - along with bulk data
collection - that the UK state has been doing for some time but is
aiming to be more transparent about.
Apple's concerns relate to the possibility that it could be ordered
to hack products belonging to its customers and to do so in secret.
"The
bill as it stands seems to threaten to extend responsibility for
hacking from government to the private sector," the company's submission
states.
Stretched laws
Aspects of these issues have been voiced by Apple and other companies before.
But one of the key concerns about the new legislation is that it contains ambiguities.
Previous
laws, such as the 1984 Telecoms Act, were stretched and expanded in
secret to carry out acts that the public knew little about.
The stated aim of the current bill is to improve transparency and accountability.
Apple may well be hoping that it can force the government to clarify what is really intended and possible.
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