On Wed, 1 Sep 2021 14:21:47 -0700 (PDT)
Brett L <[email protected]> wrote:

> Hi Andrew,
>
> Thank you for the questions and checking on details. 
> 
> We removed the option to use the DNS operator exception from our
> secondary CA platform on 2021-05-13 (60 days before the ballot
> changes went into effect, see timeline below). Our primary CA
> platform has never used it.
> 
> In May, we conducted our annual CPS review and prepared several
> updates including the one that removed the exception from Section
> 4.2.4. It was not published earlier because the update was bundled
> together with other changes in one revision.
> 
> We did not file an incident because removal of the DNS operator
> exception was identified and acted upon well ahead of the deadline.
> The CPS update was also started before SC46 became effective. We
> regret it was not published prior to the effective date. 

The inaccurate CPS is a compliance violation, even if the DNS
operator exception was not in use.

This is the same basic scenario as
<https://bugzilla.mozilla.org/show_bug.cgi?id=1706967> - in that case,
GTS' domain validation practices were compliant with the BRs, but GTS'
CPS did not accurately reflect GTS' practices.

It's troubling to see a recurrence of that scenario, and your email
doesn't provide much of an explanation how this happened.

1. Why was the CPS change not published in May given that
<https://bugzilla.mozilla.org/show_bug.cgi?id=1706967> made clear the
importance of having an accurate CPS?

2. When SC46 was merged into the BRs, did the automation described in
<https://bugzilla.mozilla.org/show_bug.cgi?id=1706967#c11> create an
internal ticket for it?  If not, why not?  If it did, how did GTS respond
to the ticket and why did the response not detect the CPS non-conformance?

Regards,
Andrew

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