Thank you, Pekka

At least the audit reports in the Repository require password. Please
advise.

Thanks,
M.D.


On Thu, Dec 16, 2021, 09:44 [email protected] <
[email protected]> wrote:

> All other Telia CA public documentation is here:
> https://cps.trust.telia.com.  If you think that something is missing
> specify what. All links in Ben's initial announcement look good to me.
> There are no unnecessary password protections.
>
> tiistai 14. joulukuuta 2021 klo 19.51.31 UTC+2 [email protected] kirjoitti:
>
>> Thank you, Pekka
>>
>> Before we can continue our discussion, could you please add any other
>> documents relevant to this request? Make sure the documents are not
>> password protected.
>>
>> I’ve been relying on the documents listed in Ben's initial announcement.
>>
>> Thanks,
>> M.D.
>>
>>
>> Sent from my Galaxy
>>
>>
>> -------- Original message --------
>> From: "[email protected]" <[email protected]>
>> Date: 12/14/21 16:01 (GMT+02:00)
>> To: [email protected]
>> Cc: "[email protected]" <[email protected]>, "
>> [email protected]" <[email protected]>
>> Subject: Re: FW: RE: Public Discussion: Inclusion of Telia Root CA v2
>>
>> >You clarified that Telia CA is a group function of virtual Telia CA team
>> from many Telia affiliates, in the meantime Mozilla accepts only real CA
>> with disclosed locations that were "included in the scope of the audit or
>> should have been included in the scope of the audit, whether the inspection
>> was physically carried out in person at each location, and which audit
>> criteria were checked (or not checked) at each location".
>>
>> I don't understand your statements above that we are not real or not
>> disclosed our locations or audit criteria. Telia CA is a real CA under
>> Telia Finland Oyj which is affiliate company of Telia Company AB. This is
>> clearly disclosed in our CPS 1.3.1 using this wording: "The CA operating in
>> compliance with this CPS is Telia CA. The legal entity responsible of Telia
>> CA is Finnish company “Telia Finland Oyj” (BusinessID 1475607-9). Telia
>> Finland Oyj is part of Swedish company “Telia Company AB” (BusinessID
>> 5561034249)." Also our annual Webtrust audits clearly states that both
>> countries have been in the audit scope. E.g. the last Webtrust report is
>> using this wording: "... in providing its SSL and non-SSL Certification
>> Authority (CA) services in Finland and Sweden, throughout the period 1
>> April 2020 to 31 March 2021, Telia has: -disclosed its SSL ...". The Full
>> Webtrust audit reports are available at links below. Auditors have every
>> year visited physically both countries since 2005 to verify our all our
>> operations. Also audit criteria (Webtrust and its versions) is clearly
>> stated in our audit reports.
>>
>> >a) Is this audit material available somehere?
>>
>> Yes, latest:
>> https://support.trust.telia.com/download/CA/Telia-2020-2021-WebTrust-Auditor-Report-WTCA-20210628.pdf,
>>
>> https://support.trust.telia.com/download/CA/Telia-2020-2021-WebTrust-Auditor-Report-WTBR-20210628.pdf
>>
>> >The documents provided under this request show that Telia Company AB is
>> a PKI participant whose roles/responsibilities within the CA are not
>> disclosed. I’d suggest in your answers to focus on Telia Company AB CA/RA
>> functions/responsibilities rather than ownership details - BRs and Mozilla
>> policy do not assume any privileges for owners, affiliates or groups - CA’s
>> operational independence must be ensured and respected not only by its
>> affiliates (including owners) but also by its own company management.
>>
>> I don't understand. All participants, locations and audit reports are
>> disclosed on our public web pages Telia Certificate Services Repository
>> <https://cps.trust.telia.com/>. Both RAs were included in the audits
>> like explained above. Swedish RA may not be directly mentioned in CPS but
>> none of our competitors is listing all their RA teams either. All our CA/RA
>> employees are internal Telia persons. Telia Company AB hasn't any real
>> CA/RA role, instead it is the owner of Telia Finland Oyj and thus
>> indirectly owner of Telia CA. Audit reports show how all our CA/RA
>> processes in all locations have passed audits with only minor deviations.
>> Auditors also verify all locations and roles of all trusted persons.
>> Company management assertions show that Telia Company Management is behind
>> Telia CA. Our CP/CPS documents describe our processes in very detailed
>> level. I think that different Telia company roles and responsibilities
>> should be already clear but if any more responsibility description is
>> required I'm happy to provide such.
>>
>>
>> >b) according to RFC 3647 BRs and Mozilla policy require CP and CPS,
>> while this root has CPS only, correct?
>>
>> Incorrect. Our disclosed CP/CPS is both at the same time. Chapter 1.2
>> clearly states: "This CPS is also a CP for Telia OV, DV and Seal
>> certificates.". In many CP/CPS chapters there is at first more general CP
>> description and then below how Telia CA has implemented such things.
>>
>> >you explained that its a Telia group function with two participants
>> Telia Finland Oyj and Cygate AB, however based on 1) and the documents
>> provided under this request, this CA has at least three PKI participants
>> whose roles/responsibilities need to be disclosed.
>>
>> I don't understand what would be the third Telia CA/RA participant you
>> are referring. Telia Company AB's role as the owner has been already
>> covered in my previous comments. I don't think owner is any real CA/RA
>> role. The only real (functional) roles belong to Telia Finland Oyj which
>> has the legal responsibility of Telia CA and of the Finnish RA team and
>> Cygate AB which has the legal responsibility of our Swedish RA team.
>>
>> >you explaned that "We use affiliate like BR defines it", sorry, but this
>> is misunderstanding - in BRs affiliate is used in specific CA/RA operation
>> contexts, so please be as specific as possible, what is the role of the
>> affiliate you mentioned earlier - Telia Lithuania (legal name AB Telia
>> Lietuva)?
>> Telia Lithuania AB has no role in Telia CA/RA processes. Clear enough?
>> They may be using Telia certificates there thus having "relying party" role.
>>
>> tiistai 14. joulukuuta 2021 klo 11.55.37 UTC+2 [email protected]
>> kirjoitti:
>>
>>> Thanks, Pekka
>>>
>>>
>>>
>>> 1) How/if Telia Company AB is (Sweden) involved in Telia Finland Oyj’s
>>> CA/RA operations?
>>>
>>> you clarified that Telia CA is a group function of virtual Telia CA team
>>> from many Telia affiliates, in the meantime Mozilla accepts only *real*
>>> CA with disclosed locations that were "*in**cluded in the scope of the
>>> audit or should have been included in the scope of the audit, whether the
>>> inspection was physically carried out in person at each location, and which
>>> audit criteria were checked (or not checked) at each location*".
>>>
>>> a) Is this audit material available somehere?
>>>
>>> The documents provided under this request show that Telia Company AB is
>>> a *PKI participant* whose roles/responsibilities within the CA are not
>>> disclosed. I’d suggest in your answers to focus on Telia Company AB
>>> CA/RA functions/responsibilities rather than ownership details - BRs
>>> and Mozilla policy do not assume any privileges for owners, affiliates or
>>> groups - CA’s operational independence must be ensured and respected not
>>> only by its affiliates (including owners) but also by its own company
>>> management.
>>>
>>>
>>> b) according to RFC 3647 BRs and Mozilla policy require CP and CPS,
>>> while this root has CPS only, correct?
>>>
>>>
>>> 2) does "Telia CA Policy Management Team" mean Telia Finland Oyj?
>>>
>>> you explained that its a Telia group function with two participants
>>> Telia Finland Oyj and Cygate AB, however based on 1) and the documents
>>> provided under this request, this CA has at least three PKI participants
>>> whose roles/responsibilities need to be disclosed.
>>>
>>>
>>> 3) what is "affiliate" in terms of specific CA/RA functions?
>>>
>>> you explaned that "We use affiliate like BR defines it", sorry, but this
>>> is misunderstanding - in BRs affiliate is used in specific CA/RA operation
>>> contexts, so please be as specific as possible, what is the role of the
>>> affiliate you mentioned earlier - Telia Lithuania (legal name AB Telia
>>> Lietuva)?
>>>
>>>
>>> Thanks,
>>> M.D.
>>>
>>> Sent from my Galaxy
>>>
>>>
>>> -------- Original message --------
>>> From: "[email protected]" <[email protected]>
>>> Date: 12/13/21 08:34 (GMT+02:00)
>>> To: [email protected]
>>> Cc: "[email protected]" <[email protected]>
>>> Subject: Re: FW: RE: Public Discussion: Inclusion of Telia Root CA v2
>>>
>>> 1) How/if Telia Company AB is (Sweden) involved in Telia Finland Oyj’s
>>> CA/RA operations?
>>>
>>> The main company “Telia Company AB” is the owner of the other Telia
>>> organizations (aka companies aka subsidiaries aka affiliates). Telia
>>> Finland Oyj and Cygate AB are such subsidiaries. Within Telia Company
>>> group, each subsidiary is responsible for running the operations. Telia
>>> Finland Oyj is the legal entity running Telia CA operations. Telia
>>> employees from many Telia companies may belong to group functions that
>>> create systems for the whole Telia group. E.g. Telia CA is a group function
>>> so that persons in virtual Telia CA team come from many Telia affiliates
>>> and thus from many countries. Complex but big enterprises may work like
>>> this. To simplify a bit you can say that Telia Finland is running Telia CA
>>> using resources from many Telia affiliates. And all is owned by Telia
>>> Company AB. All Telia CA employees belong legally to one of the Telia
>>> affiliates.
>>>
>>>  2) does "Telia CA Policy Management Team" mean Telia Finland Oyj?
>>>
>>> Telia CA Policy Management team is also a Telia group function like
>>> described above. Currently it has members from “Telia Finland Oyj” and
>>> “Cygate AB”.
>>>
>>>  3) what is "affiliate" in terms of specific CA/RA functions?
>>>
>>> We use affiliate like BR defines it: “*Affiliate*: A corporation,
>>> partnership, joint venture or other entity controlling, controlled by, or
>>> under common control with another entity, or an agency, department,
>>> political subdivision, or any entity operating under the direct control of
>>> a Government Entity.” Resources to run CA/RA come from several Telia
>>> affiliates but CA belongs legally to Telia Finland Oyj. One RA belongs to
>>> and is run by Telia Finland Oyj and the other belongs to Cygate AB.
>>> maanantai 13. joulukuuta 2021 klo 0.28.41 UTC+2 [email protected] kirjoitti:
>>>
>>>> Forwarding to the list
>>>>
>>>>
>>>>
>>>> Sent from my Galaxy
>>>>
>>>>
>>>> -------- Original message --------
>>>> From: md <[email protected]>
>>>> Date: 12/8/21 17:02 (GMT+02:00)
>>>> To: "Lahtiharju, Pekka" <[email protected]>, Ben Wilson <
>>>> [email protected]>
>>>> Cc: "Liimatainen, Mika A." <[email protected]>, "Gholami,
>>>> Ali" <[email protected]>
>>>> Subject: RE: Public Discussion: Inclusion of Telia Root CA v2
>>>>
>>>> Good day, Pekka
>>>>
>>>> Let’s focus on information directly relevant to this CA. As you already
>>>> explained, "Telia" is just a trademark used by Telia Finland Oyj, which is
>>>> the CA - a legal entity behind this  root inclusion request.
>>>>
>>>> You have also clarified that Telia Finland Oyj has two (undisclosed)
>>>> RAs and a number of so called affiliates. We still need to understand:
>>>>
>>>> 1) How/if Telia Company AB is (Sweden) involved in Telia Finland Oyj’s
>>>> CA/RA operations?
>>>>
>>>> 2) does "Telia CA Policy Management Team" mean Telia Finland Oyj?
>>>>
>>>> 3) what is "affiliate" in terms of specific CA/RA functions?
>>>>
>>>> Thanks,
>>>> M.D.
>>>>
>>>>
>>>>
>>>> Sent from my Galaxy
>>>>
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