On Friday, May 19, 2017 at 8:42:40 AM UTC-7, Gervase Markham wrote:
> 
> I have passed that document to Kathleen, and I hope she will be
> endorsing this general direction soon, at which point it will no longer
> be a draft.
> 
> Assuming she does, this will effectively turn into a 3-way conversation
> between Symantec, Google and Mozilla, to iron out the details of what's
> required, with the Google proposal as a base. (Which I'm fine with as a
> starting point.)
> 
> Comments are therefore invited on what modifications to the plan or
> additional requirements Mozilla might want to suggest/impose, and
> (importantly) why those suggestions/impositions are necessary and
> proportionate.
> 


Gerv, thank you for all the effort you have been putting into this 
investigation into Symantec's mis-issuances, and in identifying the best way to 
move forward with the primary goal being to help keep end-users safe.

I fully support requiring Symantec to set up a new PKI on new infrastructure, 
and to transition to it in phases, in order to minimize the impact and reduce
the risk for end-users.

I think the general direction is correct, but I think there are a few details 
to be ironed out, such as:

- What validity periods should be allowed for SSL certs being issued in the old 
PKI (until the new PKI is ready)? I prefer that this be on the order of 13 
months, and not on the order of 3 years, so that we can hope to distrust the 
old PKI as soon as possible. I prefer to not have to wait 3 years to stop 
trusting the old PKI for SSL, because a bunch of 3-year SSL certs get issued 
this year.

- Perhaps the new PKI should only be cross-signed by a particular intermediate 
cert of a particular root cert, so that we can begin to distrust the rest of 
the old PKI as soon as possible.

- I'm not sold on the idea of requiring Symantec to use third-party CAs to 
perform validation/issuance on Symantec's behalf. The most serious concerns 
that I have with Symantec's old PKI is with their third-party subCAs and 
third-party RAs. I don't have particular concern about Symantec doing the 
validation/issuance in-house. So, I think it would be better/safer for Symantec 
to staff up to do the validation/re-validation in-house rather than using third 
parties. If the concern is about regaining trust, then add auditing to this.

Thanks,
Kathleen


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