Thanks, PekkaDisclosing shared CA resourcesI’m looking for the CA's 
human/material resources that are shared with third parties (irrelevant to 
ownership), in your response I see only the names of three companies.The audit 
reportYou explained that "Audit covered all relevant company parts under "Telia 
Company AB" including "Telia Finland Oyj". I still can't understand why this 
fact is hard to understand.", the problem here is that we need a single legal 
entity as the CA cooperates with other PKI participants - these roles must be 
disclosed clearly (no matter who owns what).If Telia Finland Oyj is the CA, 
then all others, including Telia Company AB, should be PKI participants. You 
need to disclose this. In the meantime the audit report states:"Telia makes use 
of external registration authorities for subscriber registration activities, as 
disclosed in Telia's business practices. Our procedures did not extend to the 
controls excercised by these external registration authorities."So, we have two 
different audit scenarious here:a) as the audit report is issued to the CA 
known as Telia Company AB, then the other PKI participants  - Telia Finland Oyj 
and Cygate AB need to be audited according to their roles.b) in case if Telia 
Finland Oyj is audited as the CA, then the other two PKI participants - Telia 
Company AB and Cygate AB need to be audited according to their roles.Again, 
this has nothing to do with ownership relationship.Separation of CP and CPS 
provisionsYou explain that "There are no requirements to specifically separate 
CP and CPS texts.", according to RFC content of these two documents should be 
different. I’m ok with the combined document CP/CPS (but not content!) - I 
can’t see which part of combined document should be considered CP. At least 
section/page numbers could help.Audit scopeSorry, I cant accept your arguments, 
see The audit report above.********************To sum-up, obviousely we are in 
a loop, I don’t see any reason to change my opinion (see 2021-12-29 
email).Thanks,M.D.Sent from my Galaxy
-------- Original message --------From: "[email protected]" 
<[email protected]> Date: 1/4/22  16:54  (GMT+02:00) To: 
[email protected] Cc: "[email protected]" <[email protected]>, 
"[email protected]" <[email protected]>, Ryan Sleevi <[email protected]>, 
"[email protected]" <[email protected]> Subject: Re: 
FW: RE: Public Discussion: Inclusion of Telia Root CA v2 >>"CA Resources have 
been clearly identified above to be located in Finnish "Telia Finland Oyj" and 
in Swedish "Cygate AB".>Sorry, could you point us to specific URL's with page 
numbers?"Above" in my comment refers to this discussion where I have disclosed 
in very detailed level how the three legal entities are involved: "Telia 
Finland Oyj", "Cygate AB", "Telia Company AB". On the other hand on CPS chapter 
1.3.1 we clearly say: "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)." >>"Auditors have audited all 
related CA operations annually based on publicly disclosed Telia CP/CPS.">"all 
related CA operations" is not sufficient: as noted earlier, its not clear which 
legal entity is the CA - the references I provided were on behalf of Telia 
Company AB, however applicant of this request is Telia Finland Oyj - from CA 
operations point of view these should be two different (independent) entities 
(no matter who owns what).The new root has O value "Telia Finland Oyj" meaning 
that it is the legal entity responsible of it. CPS also states it clearly like 
seen in my previous comment. Audit covered all relevant company parts under 
"Telia Company AB" including "Telia Finland Oyj". I still can't understand why 
this fact is hard to understand. >Besides, we don't know which  [parts of CPS] 
constitute the CP. If you disclose this clearly, then we'll see what criteria  
auditors have  checked.There are no requirements to specifically separate CP 
and CPS texts. Auditors used our combined CP/CPS in their audit like stated in 
audit reports. So they have audited both CP and CPS. Audit report is stating 
also which CP/CPS version was used.>>"Audit scope in audit reports has been 
legal entity "Telia Company AB (Telia)" that is the main company. This audit 
scope covers both mentioned affiliate legal entities practically participating 
into Telia CA processes.">But we need audit reports issued to Telia Finland 
Oyj, which should be the only "main company". We don't care who owns Telia 
Finland Oyj unless the CA shares its operational resources with third parties 
(including owners). In all other cases, let's forget about Telia Company AB. 
:)Audit report based on Telia CP/CPS was using wording "Telia Company AB's ... 
CA operations in Finland and Sweden" in case when CP/CPS is stating that legal 
entity responsible is "Telia Finland Oyj". This should make it clear to 
everybody that "Telia Finland Oyj" was audited. >>"We can ask auditors to add 
all three company names in the future audit reports if it makes audit results 
clearer.">I'm afraid this is misunderstanding - the CA under this request 
should be a clearly disclosed legal entity (ownership is out of scope here). If 
the CA operations rely on other party's (e.g. owner's, affiliate's etc.) 
material or human resources, you need to disclose those shared resources and 
have auditors do appropriate check ups. If this information already exist, 
please give us  specific references.This is just semantic nonsense. In my 
previous comments I made it clear above that the responsible legal entity 
"Telia Finland Oyj" (and also Telia CA parts in Sweden) have been audited. We 
can ask auditors to write this more closely into the next reports if more 
detailed description is necessary.>>"I think the used audit criteria and 
locations (Finland and Sweden) are clearly stated in the audit reports.">OK, if 
you think so, just indicate specific audit report pages.In both these links 
(=our audit 
reports)...https://support.trust.telia.com/download/CA/Telia-2020-2021-WebTrust-Auditor-Report-WTBR-20210628.pdfhttps://support.trust.telia.com/download/CA/Telia-2020-2021-WebTrust-Auditor-Report-WTCA-20210628.pdf...
 on the first KPMG page in the first paragraph KPMG auditor has written this 
text: "Telia Company AB's ... CA operations in Finland and Sweden". Then later 
on the same page they state which Webtrust criteria was used. I can't 
understand how anybody may miss seeing company, locations or criteria that was 
used. To understand that legal entity behind Telia CA is "Telia Finland Oyj" 
and that it is affiliate to "Telia Company AB" you have to read also CP/CPS 
1.3.1.tiistai 4. tammikuuta 2022 klo 13.02.41 UTC+2 [email protected] 
kirjoitti:Thanks, Pekka"Your comment is  again full of inaccurate claims and 
accusations without any evidence."I understand your frustration - we have 
different knowledge what Telia Company AB is - unfortunately you are limited to 
ownership and company reports, but the reality is completely different."This 
conversation is about Telia CA Root application to Mozilla and your unclear 
SK/Eidas/QS comments are not related to this at all."Correct, in my last 
comment I responded to Ryan's questions. Don't mix this up with my previous 
comment about Telia Finland Oyj's Root inclusion request, ok?"Telia Company AB 
is by no means any "high risk" applicant."Quoting out of context is one well 
known methods. If you read carefully, I explained why this is a high risk 
application."Semi-government company": Telia Company is a normal private 
company".Semi-government means a hibrid entity partly owned by Government 
(~40%).https://www.teliacompany.com/en/investors/share-related-information/shareholdings/"CA
 Resources have been clearly identified above to be located in Finnish "Telia 
Finland Oyj" and in Swedish "Cygate AB".Sorry, could you point us to specific 
URL's with page numbers?"Auditors have audited all related CA operations 
annually based on publicly disclosed Telia CP/CPS.""all related CA operations" 
is not sufficient: as noted earlier, its not clear which legal entity is the CA 
- the references I provided were on behalf of Telia Company AB, however 
applicant of this request is Telia Finland Oyj - from CA operations point of 
view these should be two different (independent) entities (no matter who owns 
what).Besides, we don't know which  [parts of CPS] constitute the CP. If you 
disclose this clearly, then we'll see what criteria  auditors have  
checked."Audit scope in audit reports has been legal entity "Telia Company AB 
(Telia)" that is the main company. This audit scope covers both mentioned 
affiliate legal entities practically participating into Telia CA processes."But 
we need audit reports issued to Telia Finland Oyj, which should be the only 
"main company". We don't care who owns Telia Finland Oyj unless the CA shares 
its operational resources with third parties (including owners). In all other 
cases, let's forget about Telia Company AB. :)"We can ask auditors to add all 
three company names in the future audit reports if it makes audit results 
clearer."I'm afraid this is misunderstanding - the CA under this request should 
be a clearly disclosed legal entity (ownership is out of scope here). If the CA 
operations rely on other party's (e.g. owner's, affiliate's etc.) material or 
human resources, you need to disclose those shared resources and have auditors 
do appropriate check ups. If this information already exist, please give us  
specific references."I think the used audit criteria and locations (Finland and 
Sweden) are clearly stated in the audit reports."OK, if you think so, just 
indicate specific audit report pages.Thanks,M.D.Sent from my Galaxy-------- 
Original message --------From: "[email protected]" 
<[email protected]> Date: 1/4/22  08:50  (GMT+02:00) To: 
[email protected] Cc: "[email protected]" <[email protected]>, 
"[email protected]" <[email protected]>, 
"[email protected]" <[email protected]>, "[email protected]" 
<[email protected]>, Ryan Sleevi <[email protected]> Subject: Re: FW: RE: 
Public Discussion: Inclusion of Telia Root CA v2 Your comment is  again full of 
inaccurate claims and accusations without any evidence. Again: SK ID Solutions 
is not an affiliate of Telia Company AB (check annual report that is listing 
affiliates). Telia CA has nothing to do with them. This conversation is about 
Telia CA Root application to Mozilla and your unclear SK/Eidas/QS comments are 
not related to this at all. I wonder how long this kind of hostile discussion 
is tolerated by Mozilla.-"High Risk": Telia Company AB is by no means any "high 
risk" applicant. Telia CA has been a normal Root CA already more than 15 years 
without any security related issues in any of annual audit results. All BR 
rules have been followed during that time. Only minor technical deviations have 
ever been identified. Recently Telia also joined to CAB Forum work 
also.-"Semi-government company": Telia Company is a normal private company. 
Check https://www.teliacompany.com/en: Founded in 1853. The share is listed at 
Nasdaq Stockholm and Nasdaq Helsinki. Approximately 490,000 shareholders. 
20,800 employees. Net sales SEK 89,191 million.-"The problem here is that the 
CA resources need to be clearly identified and audited": CA Resources have been 
clearly identified above to be located in Finnish "Telia Finland Oyj" and in 
Swedish "Cygate AB". The full CA organization and system has been audited 
annually in both countries and in both companies. Auditors have got exact 
person details who belong to Telia CA and audit has been focused on those 
persons and their legal entities and how they implement Telia CA.-"the 
discussion is about CA operations not ownership"I agree. Auditors have audited 
all related CA operations annually based on publicly disclosed Telia 
CP/CPS.-"the subject of audit should be a legal entity, not a country"Audit 
scope in audit reports has been legal entity "Telia Company AB (Telia)" that is 
the main company. This audit scope covers both mentioned affiliate legal 
entities practically participating into Telia CA processes.-"CA/Browser Forum 
Baseline Requirements Audit Report 2021 (15 pages). In this report there is no 
reference to Telia Finland Oyj."In audit reports there is reference to main 
company "Telia Company AB" because auditors kept it as better because Telia CA 
functions are carried by both affiliates: "Telia Finland Oyj" and "Cygate AB". 
We can ask auditors to add all three company names in the future audit reports 
if it makes audit results clearer.-"Telia Public Response to Audit 2021, In 
this single page document no reference to Telia Company AB or Telia Finland 
Oyj."Incorrect, footer has identification of entity that created this response 
which is: Telia Finland Oyj-"Mozilla policy requires clear indication of which 
audit criteria were checked (or not checked) at each location" - as you don’t 
have a CP and the relevant parts are not identified in the CP/CPS, its unclear 
what criteria you are talking about."I don't understand. We have CP (combined 
CP/CPS) that identifies the legal entities. I think the used audit criteria and 
locations (Finland and Sweden) are clearly stated in the audit reports. Both 
locations were using the same criteria. For WTCA criteria it is clearly written 
there "...in accordance with the WebTrust Principles and Criteria for 
Certificate Authorities v2.2.1." and for WTBR is using "...in accordance with 
the WebTrust Principles and Criteria for Certificate Authorities - SSL Baseline 
with Network Security v2.4.1."    maanantai 3. tammikuuta 2022 klo 18.38.08 
UTC+2 [email protected] kirjoitti:1. RE "recent eIDAS & GDPR misimplementation chaos 
started"1.1 misimplementation means an instance of applying something 
incorrectly1.1.1 instance means a data object that Telia's affiliates - SK ID 
Solutions (formerly AS Sertifitseerimeskeskus)  together with its RA - Omnitel 
(legal name - AB Telia Lietuva) have been issuing to the public as "qualified 
certificate" (QS).1.1.2 something means "Qualified certificate" - a complex 
data structure that was initially defined in directive 1999/93/EC. For clarity, 
the QS in 1.1.1 (which is incompatible with the directive) is called surrogate 
QS.1.1.3 Worth mentioning also evaluation of legality of surrogate QS by:a) the 
Data Protection Authority (legal name Valstybinė duomenų apsaugos inspekcija - 
VDAI) ordered Omnitel to stop issuing surrogate QSs. This order is still 
ignored (how and why can be discussed separately);b) the Supreme administrative 
court which ruled that surrogate QS violates the Data protection law (an 
implementation of directive 95/46/EC, now regulation 2016/679 - GDPR). This is 
also ignored (how and why can be discussed separately).See case translation 
here: https://journals.sas.ac.uk/deeslr/article/download/2142/2072/1.1.4 based 
on the above, misimplementation of directive 1999/93/EC means incorrect 
application of Article 2 (10) (and Article 8 and Annex I). For technical 
details see the surrogate QC profiles here: 
https://www.skidsolutions.eu/en/repository/CPS/1.1.5 the regulation 910/2014 
(eIDAS) enhances and expands the acquis of  Directive 1999/93/EB - its 
transitional measure (Article 51 (2)) provision the conditions for the 
recognition of QSs (issued according to directive 1999/93/EC) as qualified 
electronic signature certificates (QESC) under eIDAS.1.1.6 the fact that SK ID 
Solutions together with its unaudited RA - AB Telia Lietuva:a) within 
transitional period issued surrogate QSs only, means incorrect application of 
eIDAS Article 51;b) after transitional period have been issuing surrogate QSs 
only, means incorrect application of eIDAS Article 28 (1) - (3).1.1.7 based on 
the above, misimplementation of eIDAS means incorrect application of Article 5, 
28 (1) - (2) and 51 (2).1.2 chaos means complete confusion and disorder1.2.1 
when surrogate QCs are accepted as QESCs, it is confusion.1.2.2 eIDAS has at 
least three directly applicable mechanisms to prevent issuing surrogate QCs, 
but none of them worked as expected (disorder):a) TSP audit by CAB - surrogate 
QCs were accepted;b) TSP "qualified service" assessment by the Supervisory body 
- surrogate QCs were accepted;c) Trust list management by the Scheme operator 
under the Commission implementing decision 2015/1505 - surrogate QCs were 
accepted.2. RE "This sounds like you're specifically referring to actions taken 
by Telia Company AB"Correct. Telia Company AB is the driving force of an 
”organized group”, wherea) The Swedish government creates "favorable 
conditions" in the countries of Telia Company AB's business operation (at least 
easy access to local governments is guaranteed);b) The Telia Company AB 
management partners with local governments so that the doors of relevant 
institutions (agencies) are open to its local affiliate  (remember "What's good 
for General Motors is good for the 
country"?)https://m.facebook.com/story.php?story_fbid=10156465065383408&id=96251623407&m_entstream_source=video_home&player_suborigin=entry_point&player_format=permalinkc)
 The Telia Company AB affiliate develops "special relationship" with the  
institutions so that at least supervision of its business is completely 
"switched off", this includes lobbying any desired legislation (surrogate QC is 
"locally legitimazed" despite of competing with other national laws and EU 
directives and regulations.I must apologize for this schematic/simplified 
response covering 20+ years of Telia Company AB's business practices in 
Baltics.If you google "Telia + corruption", almost all information will be 
about Telia Company AB's (formerly TeliaSonera AB) "achievements" in teleco 
markets, this is partly because of:- its huge propaganda machine on mass media 
and social networks;- private embassy in Brussels, e. g. see 
https://www.linkedin.com/posts/skaitmeninio-sertifikavimo-centras_why-we-have-the-eidas-gdpr-misimplementation-activity-6747690541766504448-iYsc-
 naturally invisible/hard to understand trust services.Please let me know if 
you need more info or have any questions - the information above is backed by 
publicly acessible evidence material from official sources.Thanks,M.D.Sent from 
my Galaxy-------- Original message --------From: Moudrick Dadashov 
<[email protected]> Date: 12/30/21  17:34  (GMT+02:00) To: [email protected] 
Cc: "[email protected]" <[email protected]>, 
"[email protected]" <[email protected]>, "[email protected]" 
<[email protected]> Subject: Re: FW: RE: Public Discussion: Inclusion of Telia Root 
CA v2 Sure, Ryan, allow me 2-3 days as I’m fully booked by my grandchildren 
:)Thanks,M.D.On Thu, Dec 30, 2021, 06:00 Ryan Sleevi <[email protected]> 
wrote:On Wed, Dec 29, 2021 at 9:33 AM Moudrick M. Dadashov 
<[email protected]> wrote:If approved, this request will create a precedent 
of ”do like Telia” - a practice that is widely used by Telia Company AB and its 
affiliates in the trust services markets under eIDAS. That’s how the recent 
eIDAS & GDPR misimplementation chaos started.I suggest this request be approved 
after the conversion of corporate relationships into clearly identified, 
disclosed and audited specific PKI participant roles.Moudrick,For those 
following, could you share more precise details (e.g. references to news 
articles or other discussions) about the "recent eIDAS & GDPR misimplementation 
chaos started"? This sounds like you're specifically referring to actions taken 
by Telia Company AB, and perhaps some more context/references would help 
understand your concern. 




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