  We study the exchange interaction and the subsequent collective behavior of
magnetic impurities embedded in a disordered two-dimensional (2D) helical
metal. The exchange coupling follows a statistical distribution whose moments
are calculated to the lowest order in $\left(p_F\ell\right)^{-1}$, where $p_F$
is the Fermi momentum of itinerant electrons and $\ell$ is the mean free path.
We find that i) the first moment of the distribution decays exponentially, and
ii) the variance of the interaction is long-range, however, it becomes
independent of the orientation of the localized magnetic moments due to the
locking between spin and momentum of the electrons that mediate the
interaction. As consequence, long-range magnetic order tends to be suppressed,
and a spin glass phase emerges. The formalism is applied to the surface states
of a three-dimensional (3D) topological insulator. The lack of a net magnetic
moment in the glassy phase and the full randomization of spin polarization at
distances larger than $\ell$ excludes a spectral gap for surface states. Hence,
non-magnetic disorder may explain the dispersion in results for photoemission
experiments in magnetically-doped topological insulators.
