On Friday, September 15, 2017 at 10:56:11 AM UTC+1, Inigo Barreira wrote:
> > 
> > > Those tests were done to check the CT behaviour, there was any other
> > testing of the new systems, just for the CT. Those certs were under control 
> > all
> > the time and were lived for some minutes because were revoked inmediately
> > after checking the certs were logged correctly in the CTs. It´s not a mis-
> > issuance by means of we didn´t know what happened, we had to investigate,
> > etc. It was not a good practice and I can´t excuse for that, but it was not
> > related to the regular issuance procedure as someone suggested. We
> > provided a report in which indicated all that happened and what we did to
> > not happen this again, updating the EJBCA roles permissions.
> > 
> > 1) Why didn't StartCom build a test hierarchy?
> 
> Considering that we were distrusted, that we didn´t reapply for inclussion, 
> that CT is only required by Chrome and it´s not included in the Mozilla 
> policy (even we were requested that all of our certs had to be CT logged) nor 
> required by Firefox, that those certs were under our control all the time and 
> lived for some minutes because were revoked inmediately, at that time, when 
> we did it, we didn´t expect this reaction for sure.
> 
> Of course if we had known it we hadn´t done it and for sure had built a test 
> hierarchy but there´s nothing we can do now. Only wanted to state that those 
> certs were under our control all the time, and lived for some minutes because 
> were revoked after the test. There were not any other testing of any other 
> nature directly in the production system
> 
> > 2) Why didn't StartCom use the TestTube CT log for testing CT?
> 
> We tried to check and test the same behaviour before going live with the CT 
> logging, so followed the requirements to use 3 logs, one google and one 
> non-google, for the EVs and this is what we did. We used the same settings we 
> had before the distrust using the startcom log and the google ones (pilot and 
> rocketeer).

Hi Inigo,

I'm just trying to get everything straight, cleared up and then we can move on.

I found all of your answers very concerning in the way you've conducted 
testing. I thought that all CAs must have some type of test hierarchy in place 
to test new software, requirements and etc before going live but from the 
answers you've given, StartCom neglected this in favour to test as you go along 
and deal with the problems using a live CA hierarchy. All this feels very 
amateurish and doesn't give me the any confidence at all that your CA is proven 
itself to be a trustworthy part of this infrastructure.

I recommend to Mozilla to require StartCom to start again fresh. 

1. Build a test hierarchy. Test the software and etc to industry guidelines.
2. Build a new production hierarchy (including new HSMs, keys, roots, etc.) and 
then re-apply for inclusion into the Mozilla root program.
3. Once approved then you can cross-sign your roots with another CA.

While this is happening. You can resell certificates from other CAs and build 
up trust in the industry which will benefit you in the long term I feel.

James
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