3 weeks have passed and no comments have been made on this inclusion
request. Meanwhile, I have requested and received additional information
from GlobalSign confirming that this root certificate has been included in
their BR audits back to its creation [1], in compliance with section 7.1 of
version 2.6 of the Mozilla Root Store Policy.

I intend to approve this request.

I am now closing this discussion. Any further follow-up should be added
directly to the bug [2].

- Wayne

[1] https://bugzilla.mozilla.org/attachment.cgi?id=8992927
[2] https://bugzilla.mozilla.org/show_bug.cgi?id=1390803


On Mon, Jul 16, 2018 at 2:28 PM Wayne Thayer <[email protected]> wrote:

> Reminder: this request will complete the 3-week minimum discussion period
> on Thursday. If you have any comments on this request, please post them
> before July 19th.
>
> On Thu, Jun 28, 2018 at 12:16 PM Wayne Thayer <[email protected]> wrote:
>
>> This request is for inclusion of the GlobalSign Root CA - R6 as
>> documented in the following bug:
>> https://bugzilla.mozilla.org/show_bug.cgi?id=1390803 This is an RSA-4096
>> / SHA-384 root that GlobalSign states “…will replace older, expiring roots
>> that have smaller key sizes in the future.”
>>
>> * BR Self-Assessment:
>> https://bugzilla.mozilla.org/attachment.cgi?id=8941595
>>
>> * Summary of Information Gathered and Verified:
>> https://bug1390803.bmoattachments.org/attachment.cgi?id=8962928
>>
>> * Root Certificate Download URL:
>> http://secure.globalsign.com/cacert/root-r6.crt
>>
>> CP/CPS:
>> ** CP:
>> https://downloads.globalsign.com/acton/attachment/2674/f-0b47/1/-/-/-/-/GlobalSign_CP_v5.8.pdf
>> ** CPS:
>> https://downloads.globalsign.com/acton/attachment/2674/f-0b46/1/-/-/-/-/GlobalSign_CA_CPS_v8_8_RELEASED.pdf
>>
>> * This request is to turn on the Websites and Email trust bits. EV
>> treatment is requested.
>> ** EV Policy OID: 2.23.140.1.1
>>
>> Test Websites:
>> ** https://valid.r6.roots.globalsign.com/
>> ** https://revoked.r6.roots.globalsign.com/
>> ** https://expired.r6.roots.globalsign.com/
>>
>> * CRL URL: http://crl.globalsign.com/root-r6.crl
>>
>> * OCSP URL: http://ocsp2.globalsign.com/rootr6
>>
>> Audit: Annual audits are performed by BDO and Ernst & Young according to
>> the WebTrust for CA, BR, and EV audit criteria.
>> * WebTrust: https://cert.webtrust.org/SealFile?seal=2287&file=pdf
>>
>> * BR:
>> ** April 1, 2016 - March 31, 2016:
>> https://bug1390803.bmoattachments.org/attachment.cgi?id=8980269 (EY -
>> clean)
>> ** April 1, 2016 - March 31, 2017:
>> https://downloads.globalsign.com/acton/attachment/2674/f-08b8/1/-/-/-/-/GlobalSign-WTBR-Indp-Accountant-Report-and-Mgmt-Assertion-FINAL-2017.pdf
>> (BDO - qualified)
>> ** April 1, 2017 - September 18, 2017:
>> https://downloads.globalsign.com/acton/attachment/2674/f-0960/1/-/-/-/-/GlobalSign-WTEY-Indp-Assurance-Report-FINAL-2017.pdf
>> (EY - clean)
>>
>> * EV: https://cert.webtrust.org/SealFile?seal=2288&file=pdf (BDO - clean)
>>
>> I’ve reviewed the CP and CPS, BR Self Assessment, and related information
>> for the GlobalSign Root CA - R6 inclusion request that is being tracked in
>> this bug and have the following comments:
>>
>> ==Good==
>> * While this root was created in 2014, it does not appear to have been
>> used beyond issuing test certificates.
>> * The CP and CPS state “GlobalSign CA expressly forbids the use of
>> chaining services for MITM (Man in the Middle) SSL/TLS deep packet
>> inspection.“
>> * I found GlobalSign’s CP and CPS well structured and easy to understand
>> (despite the fact that some sections, such as 3.2.2.4 and 3.2.2.5 fail to
>> align with the BRs).
>> * CPS section 3.2.8 documents email address validation methods in
>> compliance with the new 2.6 version of the Mozilla root store policy
>>
>> ==Meh==
>> * The 2016-2017 BR audit contains two qualifications. One is described as
>> follows:
>>
>> Management discovered a bug that allowed orders that are re-issued with
>> modified domains within the Subject Alternative Name field of the
>> certificate to not include the Key Usage (KU) or Extended Key Usage (EKU)
>> extensions. This occurred between August 29 , 2016 and September 19, 2016.
>> Management noted 68 Certificates were affected, 4 of these are extended
>> validation certificates and 64 are organization validation certificates.
>> Management was not able to revoke all certificates within 24 hours, due to
>> customer requirements.
>>
>> GlobalSign disclosed this problem at the time [1]. The other
>> qualification in the report is related to data backups. GlobalSign had
>> another BR audit conducted later in 2017, resulting in a clean report.
>> * GlobalSign was the subject of 4 misissuance bugs in 2017, as follows.
>> All have been resolved and this root was not involved in any of them.
>> ** Bug 1353833 - GlobalSign: Incapsula issued a certificate for
>> non-existing domain (testslsslfeb20.me)
>> ** Bug 1390997 - GlobalSign: Non-BR-Compliant Certificate Issuance -
>> metadata-only subject fields
>> ** Bug 1393555 - GlobalSign: Non-BR-Compliant Certificate Issuance --
>> double-dots in dnsName
>> ** Bug 1393557 - GlobalSign: Non-BR-Compliant Certificate Issuance -- RSA
>> key smaller than 2048 bits
>> * Minor CP and CPS issues were identified, noted in the bug, and fixed by
>> GlobalSign in the current versions.
>> * CPS section 3.2.7 indicates that GlobalSign uses “any other method” for
>> IP address validation. GlobalSign responded as follows In the bug: The only
>> “any other method” GlobalSign uses is email/phone verification via IANA
>> (ARIN RIPE, APNIC, LACNIC, AFRINIC) IP whois information.
>> * CPS section 3.2.7 indicates that GlobalSign still uses the soon-to-be
>> deprecated method 1 for domain validation. GlobalSign responded as follows
>> in the bug: We still use Method 1 in some cases, and are working to put new
>> processes in place to fully disable Method 1 by August.
>> * Earlier this year, there was a discussion related to forward-dating the
>> notBefore date in a certificate [2] that is valid for 3 years. This was
>> determined not to be a policy violation.
>>
>> ==Bad==
>> * CA generation of SSL key pairs is a Forbidden Practice [3]. Sections
>> 6.2.10 of the CP and CPS state “As of March 1, 2018, GlobalSign does not
>> generate private keys for SSL certificates.“ In the submission of this
>> root, they stated "GlobalSign currently distributes private keys in PKCS#12
>> Files according to our CP/CPS 6.2. We are phasing out this practice, and
>> will cease distributing private keys for SSL certificates in this fashion
>> by the end of March 2018."
>>
>> This begins the 3-week comment period for this request [4].
>>
>> I will greatly appreciate your thoughtful and constructive feedback on
>> the acceptance of this root into the Mozilla CA program.
>>
>> - Wayne
>>
>> [1] https://cabforum.org/pipermail/public/2016-October/008511.html
>> [2]
>> https://groups.google.com/d/msg/mozilla.dev.security.policy/kkHWPJAi-Tg/nrZX7CIABAAJ
>> [3]
>> https://wiki.mozilla.org/CA/Forbidden_or_Problematic_Practices#Distributing_Generated_Private_Keys_in_PKCS.2312_Files
>> [4] https://wiki.mozilla.org/CA/Application_Process
>>
>
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