To Ron, Ben, et. al.:

The primary purpose of having a third party sign a certificate is to 
provide assurance that an organization (in code signing) or server (in 
server certs) is what it claims to be.  In this case, a trusted third party 
provides the assurance through its registration process and Certificate 
Policy (CP) and Certificate Practice Statement (CPS) that the root CA 
imposes on those organizations.

However, in the case of the trustworthiness of the log entries, there are 
two issues:

First, the validity of the time stamp.  I always advise my clients to have 
a Corporate Policy that establishes standard time throughout the 
organization.  I also advise that the time utilized be traceable to an 
internationally recognized time source such as those provided by NIST.  I 
will gladly send my generic Time Standard Policy V2.0 and associated Time 
Standard Procedure V1.0 to those that write me directly.  If enough people 
request it, I'll send it as an attachment to an email to the mailing 
list.  I just converted the documents to PDF files for this purpose.

Second, the integrity of the information that is being logged.  By time 
stamping and signing the information as each log record (or audit trail) is 
produced, a mechanism has been put in place to demonstrate the integrity of 
the information.  I always advise my clients that quality assurance testing 
plays a major role in the security process.  Security metrics should be 
developed and quality assurance tests should be devised that demonstrate 
that a system prior to its deployment and also periodically during its 
deployment is performing as expected.  Tests can easily be designed to 
demonstrate that a specific event does indeed produce the expected log 
record/audit trail and that each entry is properly time stamped and signed 
by the system.  To support the digital signing process, an organization can 
establish its own root CA provided it also prepares appropriate CP/CPS 
documents (these are legal documents and should be developed with the 
assistance of corporate counsel) plus establishes the necessary formal 
security policies, practices, and procedures (SPPPs) regarding 
(cryptographic) key management (KM).  Again, the SPPPs should contain 
information pertaining to the security metrics by which compliance can be 
validated.  As before, quality assurance tests should be devised that can 
produce measurable feedback that KM is being complied with both prior to 
production role out and then periodically afterwards.

An organization that has formally documented SPPPs and can repeatedly 
demonstrate compliance to them, I believe has provided evidence of the 
trustworthiness of those log record/audit trail entries.  In such a 
situation, I do not believe that a third party CA is necessary to ensure 
trustworthiness.

Respectfully;
Marc Mandel
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