It is not clear to me whether a decision has been made on this matter. Would Mozilla please clarify? If this new requirement were introduced in the MRSP with immediate effect, it would cause non trivial organizational problems for the CAs that are nearing their next audit cycle.

Adriano

ACTALIS S.p.A.


Il 03/02/2022 23:31, Ben Wilson ha scritto:
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]> wrote:



    On Thu, Feb 3, 2022 at 4:03 PM Tim Hollebeek
    <[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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