Hi Moudrick,

yes, we are aware of that and have requested those members to provide updated 
information some weeks ago. I agree, we should send out another reminder and 
demand to provide the information asap.

The problem was caused by the German accreditor that decided to re-structure 
their website, causing all the existing links to fail.

Best regards
Matthias


Von: [email protected] <[email protected]> Im 
Auftrag von Moudrick Dadashov
Gesendet: Freitag, 4. Februar 2022 00:18
An: Ben Wilson <[email protected]>
Cc: Ryan Sleevi <[email protected]>; Tim Hollebeek <[email protected]>; 
[email protected] <[email protected]>
Betreff: Re: Policy 2.8: MRSP Issue #219: Require ETSI auditors to be ACAB-c 
members


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Maybe someone from ACAB-c could check the links in the table that give 404?

Thanks,
M.D.

On Fri, Feb 4, 2022, 00:31 Ben Wilson 
<[email protected]<mailto:[email protected]>> wrote:
Regarding "Relying on a non-official source for accreditation information has 
its own risks that should be taken seriously." - That isn't how it works - in 
the third column over on https://www.acab-c.com/members/, the link is to the 
official source, which is what we review.

On Thu, Feb 3, 2022 at 3:16 PM Ryan Sleevi 
<[email protected]<mailto:[email protected]>> wrote:


On Thu, Feb 3, 2022 at 4:03 PM Tim Hollebeek 
<[email protected]<mailto:[email protected]>> wrote:
Ben,

The policy requirements should be structured to match the policy goals.  You 
have mentioned two important ones, which I agree with.  The first can be solved 
by requiring the use of ACAB’c templates.  The second points to a legitimate 
issue that the NABs/CABs need to solve.  Relying on a non-official source for 
accreditation information has its own risks that should be taken seriously.

Tim,

I don't want to belabor this point, but you haven't highlighted if, how, or why 
you believe WebTrust is different. WebTrust is organizationally and 
functionally the same as ACAB'c in this regard, as far as professional 
association goes. Do you believe WebTrust is only valid if the US or Canadian 
governments recognize it - knowing full well they reject such audits as being 
insufficient?

This reply seems to demonstrate a fundamental misunderstanding about the role 
of CABs/NABs, or that there is some value that is not yet articulated. The 
burden of proof rests on you to demonstrate what this value is - and what these 
risks are, that you believe should be taken seriously. You have not yet done 
that.

There’s also no guarantee that ACAB’C membership will be free in the future.  
Organizations change.  ACAB’c could also adopt membership rules which some 
organizations are unable to comply with.

Again, how is this functionally different from WebTrust, which charges a 
licensing fee and which has restrictions on who can join? This is a point that 
goes back 20 years, in particular, during the discussion of Scott Perry as an 
auditor who was not WebTrust licensed at the time and not a CPA. I mention 
Scott as an example, because Scott S. Perry is who DigiCert has used as their 
auditor (and which was recently acquired by Shellman).

The argument here does not establish why Mozilla should be concerned about free 
or not. Similarly, the point that ACAB'c "could" do something is nothing more 
that unsubstantiated FUD, because it ignores the fact that if there was a 
negative development, Mozilla - or anyone else - could respond if necessary.

As was pointed out internally, ACAB’C is a very small association of mostly 
French and German auditors, with very few members.  As much as I appreciate 
their work on templates and other issues, I don’t think forcing people to join 
another organization is a good thing for organizations to do, no matter how 
well-intended it is.  It takes away their agency, which will certainly put a 
damper on their desire to participate.

This is the closest we've got to actually establishing the substance of your 
objection, but it is entirely unclear what bearing it should have on this 
discussion. By this logic, requiring WebTrust licensed auditors is an equally 
unacceptable imposition - do you agree or not?

Is there some point you believe is being overlooked? This message is full of 
conclusions, but lacks the logical footing necessary to reach those 
conclusions. If you think it's being misunderstood, please articulate.

The fact that NABs/CABs have not solved this issue, that there has been years 
of discussion with ETSI, and that fundamentally the organizational goals of 
NABs/CABs is specifically to support that of Supervisory Bodies, and is not 
aligned with browser needs, appears to be entirely discarded here. There's zero 
reason to believe that continuing on the present course is somehow going to 
lead somewhere differently, other than in the abstract ideal state.

I don't disagree that there are arguments being made here, but their arguments 
that are easily refuted, or which don't logically hold. I hope I'm overlooking 
something.
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