On Tue, June 24, 2014 10:39 am, Kurt Roeckx wrote:
>
>  Should we mandate that the audit should also audit the procedures?
>
>  In my opinion the audit should:
>  - Check that the CPS complies with all the requirements
>  - Check that the CPS is being followed.

Well, "Check that the CPS is being followed" is a bit of a can of worms.

There's the sampling audit, that ensures, "historically", that the issued
certificates have followed the CPS.

However, if an auditor does not also perform some observation that the CPS
is being followed (e.g.: by having the CA demonstrate the various
technical controls being followed), then a CA that has issued no
certificates is, from an audit coverage perspective, indistinguishable
from a CA with no technical controls.

So I think we need both - the sampling (historical) and some practical
demonstration.

>
>  I would also like that the software they use should enforce as
>  much as possible and not rely on humans to check things that can
>  be automated.  That however does not mean it should only be
>  checked by the software.
>
>  I would also like clear rules on what happens when we detect that
>  they do not follow the requirements.
>
>
>  Kurt
>

Agreed.

As it stands, I'm surprised that the controls in place that led to the
issues Erwann detected were sufficient to satisfy the requirements of
Sections 3.9 and 6.1 of the WebTrust "Principles and Criteria for
Certification Authorities 2.0", which is part of the basis of evaluating
the requirements of the "SSL Baseline Requirements Audit Criteria V1.1"

At a minimum, it seems like this CA should be moved to the back of the
queue for discussion, since it's clear that it's not yet in compliance
with the Mozilla policy.

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