Hello Cynthia,
Our last post was intended to respond to the question immediately above it with 
regard to why the revoked certificate showed a revocation reason of 'cessation 
of operations' rather than 'compromise.'  Additional information regarding what 
we are doing to ensure certificates are revoked within 24 hours of receipt of 
notice that a certificate is compromised can be found in the bug report:  
https://bugzilla.mozilla.org/show_bug.cgi?id=1640310
Daniela Hood
GoDaddy



Daniela Hood
GoDaddy | Compliance Manager
[https://email-sig.gd-resources.net/img/godaddy-logo-outline.png]
+16026881766
Gilbert, Arizona, United States
dxh...@godaddy.com<mailto:dxh...@godaddy.com>


From: Cynthia Revström <m...@cynthia.re>
Sent: Wednesday, June 3, 2020 1:52 PM
To: Daniela Hood <dxh...@godaddy.com>
Cc: r...@sleevi.com; dev-security-policy@lists.mozilla.org
Subject: Re: GoDaddy: Failure to revoke certificate with compromised key within 
24 hours

Notice: This email is from an external sender.


Hi Daniela,

Sorry if I am missing something, but what do you mean by "incorrect revocation 
reason"?
The first sentence in the email sent to you by Sandy sounds pretty clear to me 
"Request you revoke the all certificate associated with this
compromised key".

Also I don't see how any of what you have said you have done would help to 
prevent it from taking over 24h again, could you please elaborate?

- Cynthia

On Wed, Jun 3, 2020 at 8:13 PM Daniela Hood via dev-security-policy 
<dev-security-policy@lists.mozilla.org<mailto:dev-security-policy@lists.mozilla.org>>
 wrote:
Hello all,

We appreciate the concerns and your questions to this thread. GoDaddy takes 
such issues very seriously and recognize the importance to the industry and 
health of the ecosystem.

​In the case where the user selected the incorrect revocation reason, we 
identified the error shortly before it was reported as part of a standard 
review. We reviewed the error with the user and corrected it the same day, per 
our procedure. Upon reviewing with the user, we identified an opportunity to 
enhance our process through additional visual cues to enable the agent to 
perform a final review prior to committing a revocation. Additionally, our 
process includes team calibrations where prior errors are used as training 
opportunities for the entire team. We also include any areas that have changed 
or where we notice an increased instance of errors in our annual training 
program. All of these efforts in combination help us to keep the instance of 
errors down and address situations as they arise.

We hope this information helps address concerns regarding this error.

Thank you,

Daniela Hood
GoDaddy


-----Original Message-----
From: dev-security-policy 
<dev-security-policy-boun...@lists.mozilla.org<mailto:dev-security-policy-boun...@lists.mozilla.org>>
 On Behalf Of Daniela Hood via dev-security-policy
Sent: Friday, May 29, 2020 9:16 PM
To: 'r...@sleevi.com<mailto:r...@sleevi.com>' 
<r...@sleevi.com<mailto:r...@sleevi.com>>
Cc: 
dev-security-policy@lists.mozilla.org<mailto:dev-security-policy@lists.mozilla.org>
Subject: RE: GoDaddy: Failure to revoke certificate with compromised key within 
24 hours

Notice: This email is from an external sender.



GoDaddy acknowledges the inquiry and we will work to have a response to the 
community by Wednesday, June 3rd.


Daniela Hood
GoDaddy | Compliance Manager
[https://email-sig.gd-resources.net/img/godaddy-logo-outline.png]
+16026881766
Gilbert, Arizona, United States
dxh...@godaddy.com<mailto:dxh...@godaddy.com><mailto:dxh...@godaddy.com<mailto:dxh...@godaddy.com>>


From: Ryan Sleevi <r...@sleevi.com<mailto:r...@sleevi.com>>
Sent: Friday, May 29, 2020 7:52 AM
To: Daniela Hood <dxh...@godaddy.com<mailto:dxh...@godaddy.com>>
Cc: 
dev-security-policy@lists.mozilla.org<mailto:dev-security-policy@lists.mozilla.org>
Subject: Re: GoDaddy: Failure to revoke certificate with compromised key within 
24 hours

Notice: This email is from an external sender.


Thank you for your update.

This does not appear to answer the questions raised. I would appreciate if 
GoDaddy shared a more meaningful response, in line with addressing the concerns 
Nick raised, as well as the outstanding matters on the bug.

In particular, this response fails to analyze what went wrong, what has been 
done systemically by GoDaddy to prevent future incidents, and what are 
practices other CAs should consider to prevent similar incidents.

In addition to the outstanding question from Nick, for this sort of response to 
be acceptable at all, more detail is needed:
- What improvements were made, and why?
- What training was done? What was changed? How is the training performed and 
evaluated? Why did the previous training fail to address this? Why is training 
seen as an acceptable answer, given previous training failed? What is done to 
support and monitor compliance to training?
- What changes were made to the system? Why would they address this issue? How 
does that relate to why the issue?

In 2020, publicly trusted CAs should not be expecting that such “incident 
reports”, if this can even be called that, are sufficient. As stewards of the 
trust placed in them by Mozilla and the broader community, and by other root 
stores, substantive and highly detailed, technical responses are expected. The 
goal of these reports is to both simultaneously address concerns caused by the 
failure to adhere to expectations and to help ensure that all CAs have an 
opportunity to learn from and implement similar mechanisms. If the response 
does not have sufficient information to allow for an independent implementation 
of whatever mitigations, and to the same level of assurance, it quite simply is 
not a response that meets expectations. We need to be able to work together, as 
an industry, to move things forward, and that requires complete transparency.

On Thu, May 28, 2020 at 7:55 PM Daniela Hood via dev-security-policy 
<dev-security-policy@lists.mozilla.org<mailto:dev-security-policy@lists.mozilla.org><mailto:dev-security-policy@lists.mozilla.org<mailto:dev-security-policy@lists.mozilla.org>>>
 wrote:
Hello,

We have made improvements on our problem reporting process, provided more 
training to our agents and made changes in our system to assure that such error 
would not happen again. We will keep on working with the community to find 
solutions that could benefit the industry, in hopes to avoid such errors from 
occurring.

Daniela Hood
GoDaddy


-----Original Message-----
From: Nick Lamb 
<n...@tlrmx.org<mailto:n...@tlrmx.org><mailto:n...@tlrmx.org<mailto:n...@tlrmx.org>>>
Sent: Friday, May 22, 2020 4:50 PM
To: 
dev-security-policy@lists.mozilla.org<mailto:dev-security-policy@lists.mozilla.org><mailto:dev-security-policy@lists.mozilla.org<mailto:dev-security-policy@lists.mozilla.org>>
Cc: Daniela Hood 
<dxh...@godaddy.com<mailto:dxh...@godaddy.com><mailto:dxh...@godaddy.com<mailto:dxh...@godaddy.com>>>
Subject: Re: GoDaddy: Failure to revoke certificate with compromised key within 
24 hours

Notice: This email is from an external sender.



On Fri, 22 May 2020 22:48:42 +0000
Daniela Hood via dev-security-policy
<dev-security-policy@lists.mozilla.org<mailto:dev-security-policy@lists.mozilla.org><mailto:dev-security-policy@lists.mozilla.org<mailto:dev-security-policy@lists.mozilla.org>>>
 wrote:

> Hello,
>
> Thank you for all the comments in this thread.  We filed an incident
> report related to the revocation timing that can be followed here:
> https://bugzilla.mozilla.org/show_bug.cgi?id=1640310.  We also
> identified the error in revocation reason as a user error, corrected
> the error and provided feedback to the employee.

In addition to Ryan's concerns about the supposed ambiguity of a pretty clear 
rule in the BRs I am as always interested in what can be learned from incidents 
that might help everybody else.


What mechanism, if any, would have detected this "user error" in the absence of 
a report by a third party to m.d.s.policy ?

Every CA has humans doing stuff, and humans make mistakes. Whether that's a 
Let's Encrypt team member fat-fingering a server configuration or a Symantec 
employee using google.com<http://google.com><http://google.com> rather than a 
Symantec name for a test. But even though it's expected for humans to make 
mistakes, we demand more of the Certificate Authority than we could ask of one 
human.

Where humans are necessary they will make mistakes and so you need compensating 
controls. In this case that might mean reviewing critical work done by humans. 
Depending on volume that might mean a second person looks at every revocation, 
or it might mean a sample is examined once a week for example.

I'd like to see incident reports like this not stop at "user error" for this 
reason. Why wasn't the "user error" caught? What (other than "feedback to the 
employee") prevents it happening again ?


Nick.
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