Hi Wayne,
thanks for your prompt reaction. I insert my comments below.

El jueves, 29 de noviembre de 2018, 19:01:16 (UTC+1), Wayne Thayer  escribió:
> Questions for OISTE/WISeKey:
> 
> Your plans for new audits will largely cover the requirement that OISTE
> demonstrate compliance with the entirety of our policy. I believe that you
> are asking for "approval" from Mozilla in the form of a "positive
> conclusion" to the public discussion prior to conducting those audits - is
> that correct? If so, I think that is a reasonable request. If the audits
> uncover problems, they can be addressed via our normal processes.

Yes, this is correct. We need to ensure full compliance with the Mozilla 
Program and therefore we'd process to execute the transfer plan only after 
having this approval.

> 
> Section 8.1 also states: "Mozilla MUST be notified of any resulting changes
> in the CA's CP or CPS." Are you able to tell us what those changes will be?
> I am understanding that OISTE would like to have Mozilla's "approval" prior
> to the change taking place, and thus the new CP/CPS taking effect, but I
> think it is reasonable for us to know the specifics of what changes are
> planned prior to ending this discussion period.
> 

Indeed there will be changes in the CP/CPS. I tried to explain this in the 
above request, but I'll provide here more details.

The current CPS is published by WISeKey and integrates the CP for the different 
certificate profiles issued. This CPS is already endorsed by the OISTE Policy 
Approval Authority (PAA), as explained in the first sections of the current 
CPS, because OISTE had always a role in our PKI (e.g. you can see in the Root 
Certificates the OU "OISTE Foundation Endorsed").
 
We already wanted time ago to separate the CPS into different CP and CPS 
documents, and we'll profit this transfer process to do a full refactor of the 
policies and practices documents.

The final picture we envision is:
* OISTE will publish a set of CP documents that regulate the different 
certificate types issued by the trust model. A priori I foresee a CP for 
personal certificates, another CP for SSL certificates and another CP for 
device certificates (IoT). OISTE will play a supervisory role to grant 
permission to a subordinate CA to adopt one or more CP and issue such types of 
certificates.
* OISTE will publish a CPS that covers the Root CAs and provides an "umbrella" 
for the whole trust model.
* WISeKey will publish at least one CPS that regulates the operation of the 
Issuing CAs, in accordance to the OISTE CPS and the CP implemented by these 
issuing CAs

Therefore a certificate subscriber will be still affected by the WISeKey CPS, 
as it is now, and our main intent will be that, in terms of "Certification 
practices", for the subscriber there won't be any practical change. It's just 
that, when evaluating our new practices, the readers will need to consider not 
only a single CPS document, but also the CP documents separately.

I think this change will be positive, because a CPS covering different types of 
certificate policies can end up by being complex to read, as it needs to 
contain all possibilities for identity validation, certificate profiles, etc. 
for certificate profiles that can be quite different, in a single CPS document. 
I think the new documentation framework will be clearer and more in line of the 
new best practices and requirements.

BTW, it happens that I'm member of the OISTE PAA, so I'll be personally 
involved in all the changes.

I hope this clarifies the question, but don't hesitate to ask for more 
information.

Regards,
Pedro
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