On 28/02/2019 17:48, lcchen.ci...@gmail.com wrote:
1. How your CA first became aware of the problem (e.g. via a problem report 
submitted to your Problem Reporting Mechanism, a discussion in 
mozilla.dev.security.policy, a Bugzilla bug, or internal self-audit), and the 
time and date.

  Ans:
One of our staffs in PKI group was taking samples of the issued certificates 
from crt.sh database for some reasons and found a mis-issued certificate which 
has a test (unregistered) FQDN on February 15, 2019 at 1:55 (UTC). He then 
notified us (Public CA) of the incident. We decide to make an initial 
investigation and found another mis-issued certificate which also has a test 
FQDN on February 15, 2019 at 2:30 (UTC).

2. A timeline of the actions your CA took in response. A timeline is a 
date-and-time-stamped sequence of all relevant events. This may include events 
before the incident was reported, such as when a particular requirement became 
applicable, or a document changed, or a bug was introduced, or an audit was 
done.

  Ans:
Timeline (all times are UTC):
15 February 2019 1:55: Find a mis-issued certificate with a FQDN 
www.raotest.com.tw
15 February 2019 1:59: Revoke the first mis-issued certificate
15 February 2019 2:07:  Public CA starts an action plan and initial 
investigation
15 February 2019 2:17:  Further certificate issuing suspended
15 February 2019 2:30: Find another mis-issued certificate with a FQDN 
publicca.rao.com.tw
15 February 2019 4:10: Initial investigation completed
15 February 2019 4:25: Certificate issuing restarted
15 February 2019 4:40: Hold an investigation meeting

3. Whether your CA has stopped, or has not yet stopped, issuing certificates 
with the problem. A statement that you have will be considered a pledge to the 
community; a statement that you have not requires an explanation.

Ans:
Yes, we had stopped issuing certificates before we investigated and revoked any 
certificate with an unregistered FQDN. We have asked our CA system vendor to 
include an automatic FQDN-checking function in the hotfix which will be 
released not after 30 March 2019 to avoid making the same mistakes.

4. A summary of the problematic certificates. For each problem: number of 
certs, and the date the first and last certs with that problem were issued.

Ans:
Number of certs: 2
      First cert: issued on Nov 12, 2018 at 11:53:02 (UTC)
      Last cert: issued on Jan 29, 2019 at 06:43:59 (UTC)
5. The complete certificate data for the problematic certificates. The recommended way to provide this is to ensure each certificate is logged to CT and then list the fingerprints or crt.sh IDs, either in the report or as an attached spreadsheet, with one list per distinct problem.

Ans:
https://crt.sh/?id=1153958924 with FQDN www.raotest.com.tw
https://crt.sh/?id=940459864 with FQDN publicca.rao.com.tw

6. Explanation about how and why the mistakes were made or bugs introduced, and 
how they avoided detection until now.

Ans:
For the certificate with FQDN www.raotest.com.tw:
One of our RAOs intended to take a screenshot of certificate application 
process for training material in test environment, but she was not aware that 
she is in the formal environment. After the certificate was issued, the RAO 
forgot to revoke it.

For the certificate with FQDN publicca.rao.com.tw:
The same as the former cause, but the mis-issued certificate had been revoked 
immediately without notifying Public CA.

The mistakes have not been detected (even by our internal self-audit) because 
the amount of mis-issued certificates is minor. The RAO involved in this 
incident has been verbally warned and needs to undergo a retraining process in 
accordance with our employment contract.

7. List of steps your CA is taking to resolve the situation and ensure such 
issuance will not be repeated in the future, accompanied with a timeline of 
when your CA expects to accomplish these things.

Ans:
To avoid making the same mistakes, the following steps will newly be introduced:

Step 1. Implementation of a two-stage manual verification by different RAOs. 
Effective 26/02/2019.
Step 2. Implementation of an automatic FQDN-checking function prior to issuing certificates. Effective 30/03/2019.

Step 3. Implementation of a scheduling program to periodically and 
automatically check the newly-issued certificates from our repository. 
Effective 30/05/2019.



How come your Public CA wasn't routinely using the blessed automatic
methods listed in the BRs?  Manual domain ownership or control
validation is supposed to be an exception, not the routine standard
procedure for a general public CA (a private Sub-CA technically
constrained by the parent CA to only issue for domains already
validated as belonging to the Sub-CA owner may rely exclusively on
their internal processes to authorize certificates for any FQDNs
under their own domains, because a public CA can legitimately
validate the customer higher level domain control to issue for FQDNs
under the validated domain).

FQDN existence is not a requirement, only validation that the
certificate applicant has the authority to create and change that
FQDN at will.  For example, automated validation that raotest.com.tw is
a registered domain fully controlled by the applicant would be enough
to give that applicant a certificate for www.raotest.com.tw, even
before that applicant creates www.raotest.com.tw.  Some applicants
may even prefer to obtain certificates before making their FQDN live.

Of cause the fact that a registry such as the one for .com.tw can
create any non-existent domain does not count, because such domains
would generally belong to a 3rd party.


Enjoy

Jakob
--
Jakob Bohm, CIO, Partner, WiseMo A/S.  https://www.wisemo.com
Transformervej 29, 2860 Søborg, Denmark.  Direct +45 31 13 16 10
This public discussion message is non-binding and may contain errors.
WiseMo - Remote Service Management for PCs, Phones and Embedded
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