On Thu, March 19, 2015 4:49 pm, Peter Bowen wrote:
>  For example, based on what you reported and what I saw, the audit
>  report should at a minimum say:
>  E-Guven complies with the Baseline Requirements with the following
>  qualifications:
>  - Some certificates issued do not conform to 9.2.1
>  - Some certificates issued do not conform to 9.2.4(d)
>  - Some certificates issued do not conform to 9.2.5
>  - Some certificates issued do not conform to Appendix A
>
>  Do you think these qualifications are acceptable?
>
>  Thanks,
>  Peter

To be fair (and exceedingly cynical but depressingly realistic), the auditor
  - May not find these certificates during the sampling audit
  - May not use the certificates found as evidence of further misissuance
and thus not examine further
  - May not even check the technical accuracy of these certificates
  - For the certificates they find, require that they simply be revoked

All of which would allow the auditor to indicate a statement that the CA
fully conformed with all applicable policies during the period of time the
audit covers.

The most egregious issue is that last bit - a CA can (in practice, though
not desired) quietly sweep all such misissuance under the rug by allowing
time to remediate the auditor's qualified findings, such that the auditor
issues a glowing report consistent with the manager's assertion that the
CA was fully on the up and up.

The mitigation for such a depressing state of affairs is to require
transparency reporting during disclosure. That is, to require that
auditors list all the issues found (as you did), how many such issues were
found, and what steps the CA took to remediate the issues, all as part of
the public, annual audit report.

It's been talked about before, certainly, but how to best accomplish such
a wording change is unclear, and to get it incorporated into (WebTrust,
ETSI) is another matter.

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