Andrew. 

Thank you for the review, comments and questions on TrustCor's policy 
documents.  

We are in the process of reviewing your comments and formulating a response to 
each.  We will provide our response and updates before EOB Tuesday, August 
15th, published to this discussion list.

Have a great weekend,

Neil Dunbar,
TrustCor CA Administrator

> On 10 Aug 2017, at 23:54, Andrew R. Whalley via dev-security-policy 
> <dev-security-policy@lists.mozilla.org> wrote:
> 
> Greetings,
> 
> I have reviewed TrustCor's CP and CPS (both at version 1.3.1) and made the
> following notes:
> 
> *CP* (http://www.trustcor.ca/resources/cp.pdf)
> 
> 1.6.3
> 1.6.4
> Nit:
> Section 1.1 says that "Sections which do not apply to TrustCor CA, or where
> TrustCor CA makes no authoritative statement, will have either the text “No
> stipulation” or “Not Applicable”." but these sections are just blank.
> 
> 3.3.1
> "Level 2 Client certificates - demonstration of a pre-shared key and OTP
> validation as described in Section 3.2.3 is sufficient to allow re- key."
> however section 3.2.3 makes no mention of pre-shared key and OTP validation.
> 
> 4.4.2 Publication of the certificate by the CA
> Note that is at odds with any future CT requirement.
> 
> 6.1.5
> "OCSP responses may respond using the SHA-1 hash if the request used
> SHA-1," Signing of OCSP responses with SHA1 is prohibited by the BRs
> (section 7.1.3) after 1st Jan 2017 - though section 7.1.3 does state that
> TrustCor does not, and never has, used SHA-1 as a component of any
> signature algorithm on a certificate.
> 
> 6.1.6
> This section references version 1.3.0 of the BRs, which date from 2015.
> 
> *CPS* (http://www.trustcor.ca/resources/cps.pdf)
> 
> 1.4.1
> The maximum validity of the different certificate types, while within
> what's allowed by the BRs, aren't consistent with the limits specified in
> section 6.3.2 of the CP (e.g. 12 months vs 398 days).
> 
> 2.2
> https://catest1-revoked.trustcor.ca/ is not resolving.
> https://catest1-expired.trustcor.ca/ is not resolving.
> https://catest2-revoked.trustcor.ca/ is not resolving.
> https://catest2-expired.trustcor.ca/ is not resolving.
> 
> 2.2.1
> Commitment to make incident reports public - very good.
> (Note that at the moment
> https://www.trustcor.ca/resources/issuance-incidents/ currently just
> redirects to the home page)
> 
> 3.2.2.4.7
> Presuming "TrustCor will the authoritative DNS servers" should be "TrustCor
> will *query* the authoritative DNS servers"
> 
> 3.2.2.8
> Fail shut CAA - good
> 
> 3.2.6
> While it's good that TrustCor will publish cross-signed certificates it
> issues to other CAs, my understanding of section 3.2.6 of the BRs is that
> it requires cross certifications that a CA obtains from other CAs (i.e.
> where it is the Subject of the cert) to be published.
> 
> 4.9.1.1
> Even though section 4.9.2 states that a subscriber can request revocation
> of their certificate, 4.9.1.1 does not list a subscriber request as a
> reason for revocation.
> 
> 4.9.1.2
> I would like to hope that there are technical, not just business, controls
> in place to limit the actions an "insufficiently aware staff member" could
> perform.
> 
> 7.1.2.2
> Section 7.1.2.2 of the BRs states "certificatePolicies - This extension
> MUST be present and SHOULD NOT be marked critical." for Subordinate CA
> Certificates, however this section implies that certificatePolicies is only
> specified for Enterprise Subordinate CAs.
> 
> 7.1.2.3
> For the Secure Mail profiles, the subjectAlternativeName is defined as
> containing an "emailAddress". Should this not be rfc822Name?
> 
> 7.1.2.4
> It seems odd that this section references itself and 7.1.2.5.  Where these
> meant to be 7.1.2.2 and 7.1.2.3?
> 
> The CP requires the subject key identifier and authority key identifier
> extensions, but these are not specified in the cert profiles in the CPS.
> 
> 7.1.6.3
> This seems at odds with 7.1.2.2 of the BRs.
> 
> Those comments aside, I found both documents clear, well written, and they
> provided sufficient detail to assess the policies in place.
> 
> Many thanks,
> 
> Andrew
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