On Monday, October 9, 2017 at 7:57:31 PM UTC+1, Kathleen Wilson wrote:
> Here's what is currently in the bug...
> https://bugzilla.mozilla.org/show_bug.cgi?id=1405862
> ~~
> As per Bug #1403549 the PSCProcert certificate will be removed from Mozilla’s 
> Root Store due to a long list of problems and the way that PROCERT responded 
> to those problems (and to previous CA Communications). For details about the 
> problems, see Bug #1391058 and https://wiki.mozilla.org/CA:PROCERT_Issues
> 
> The purpose of this bug is to record the action items that PROCERT must 
> complete before their certificate may be included as a trust anchor in 
> Mozilla’s Root Store again.
> 
> PROCERT may apply for inclusion of a new certificate[1] following Mozilla's 
> normal root inclusion/change process[2], after they have completed all of the 
> following action items.
> 
> 1. Provide a list of changes that the CA plans to implement to ensure that 
> there are no future violations of Mozilla's CA Certificate Policy and the 
> CA/Browser Forum's Baseline Requirements. The list must be provided in this 
> bug, and accepted by Mozilla as reasonable remediation.
> 
> 2. Implement the changes, and update their CP/CPS to fully document their 
> improved processes.
> 
> 3. Provide a reasonably detailed[4] public-facing attestation from a licensed 
> auditor[3] acceptable to Mozilla that the changes have been made. This audit 
> may be part of an annual audit.
> 
> 4. Provide auditor[3] attestation that a full performance audit has been 
> performed confirming compliance with the CA/Browser Forum's Baseline 
> Requirements. This audit may be part of an annual audit.
> 
> 
> Notes:
> [1] The new certificate (trust anchor) may be cross-signed by the removed 
> certificate. However, the removed certificate may *not* be cross-signed by 
> the new certificate, because that would bring the concerns about the removed 
> certificate into the scope of the new trust anchor.
> [2] Mozilla's root inclusion/change process includes checking that 
> certificates in the CA hierarchy comply with the CA/Browser Forum's Baseline 
> Requirements.
> [3] The auditor must be an external company, and approved by Mozilla.
> [4] “detailed” audit report means that management attests to their system 
> design and the controls they have in place to ensure compliance, and the 
> auditor evaluates and attests to those controls. This assertion by management 
> - and the auditor's independent assessment of the factual veracity of that 
> assertion - will help provide a greater level of assurance that PROCERT has 
> successfully understood and integrated the BRs.
> ~~
> 
> I could add a comment to the bug saying:
> ~~
> To be clear…
> 
> - This PSCProcert certificate will be removed, and the CA has to re-apply for 
> inclusion of the new certificate through Mozilla’s application process as 
> described here:
> https://wiki.mozilla.org/CA/Application_Process#Process_Overview
> However, the CA must not re-apply until all of the listed actions have been 
> completed, related documents provided in this bug, and resulting 
> documents/audits approved by Mozilla in this bug.
> 
> - Action #3 must not start until Action #1 and Action #2 are done, and the 
> resulting documents approved by Mozilla in this bug.
> 
> - As with all root inclusion applications, the new CA hierarchy, processes, 
> issued certificates, CP/CPS, BR Self Assessment, and audits must fully comply 
> with Mozilla’s Root Store Policy and the CA/Browser Forum’s Baseline 
> requirements. Otherwise, there will be further delay.
> ~~
> 
> Does that make it clear enough that this is not something to be rushed? 
> And that the items each need to be approved by Mozilla in the bug?
> 
> I'm not fond of the idea of stating time delays up front, when our 
> application process is by-design very slow and cumbersome already. (Just ask 
> the CAs who have been waiting for over a year for the discussion of their 
> root inclusion/update requests to start.)
> 
> I think the "get it right or face delay" concept is already a standard part 
> of our application process.
> 
> Action #3 already requires an audit statement about the changes. 
> 
> I'm not comfortable with the idea of having an auditor report to Mozilla and 
> not the applicant, because I would suspect that might require some 
> contractual agreements and/or NDAs, and I do not sign contractual agreements 
> or NDAs with CAs.
> 
> Thanks,
> Kathleen

Hi Kathleen,

I think there be a comment relating to whether PROCERT is allowed/disallowed to 
cross-sign their new root CA with another CA.

James
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