On Fri, Mar 20, 2020 at 4:07 PM Kathleen Wilson via dev-security-policy <
dev-security-policy@lists.mozilla.org> wrote:

> My question: What should "location" mean in the above requirement?
>

The WebTrust Practitioner Guidance offers a reasonable definition:
https://www.cpacanada.ca/en/business-and-accounting-resources/audit-and-assurance/overview-of-webtrust-services/practitioner-qualification-and-guidance

CA Processing Locations
All reports issued should list the city, state/province (if applicable),
and country of all physical locations
used in CA operations. This includes data center locations (primary and
alternate sites), registration
authority locations (for registration authority operations performed by the
CA), and all other locations
where general IT and business process controls that are relevant to CA
operations are performed.


> For example, if a CA happens to have two facilities in the same city
> that should be audited, how can the audit statement clearly indicate if
> all of that CA's facilities were audited without providing the exact
> physical addresses?


We're primarily interested in making sure that the auditor examined /both/
facilities for the appropriateness of controls. ETSI's lack of rigorous
methodology leaves a lot to be desired here, but it's not difficult to
disambiguate by indicating something like
"Facility 1 in City, State, Country" vs "Facility 2 in City, State, Country"
or
"Primary Facility in City, State, Country" vs "Disaster Recovery Facility
in City, State, Country"

(adjusted as appropriate)
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