Here is an edit to address this -
https://github.com/BenWilson-Mozilla/pkipolicy/commit/10946b7133bf57818638fdee95d38c8696baca63

On Tue, Mar 29, 2022 at 9:28 AM Ben Wilson <[email protected]> wrote:

> Should I add language that says ", regardless of changes in ownership or
> control of the root CA,"?
>
> "CA operators SHALL maintain links to older versions of each CP and CPS
> (or CP/CPS)*, regardless of changes in ownership or control of the root
> CA, *until *the entire* root CA certificate hierarchy operated in
> accordance with such documents are no longer trusted in the Mozilla root
> program."
>
> It will be the responsibility of the current root CA operator to maintain
> those older versions of CPs and CPSes.  I think this may affect several CA
> operators in the Mozilla program that have acquired roots from their
> original owners. I hope they will be able to locate those older CPs and
> CPSes. Should there be a cut-off going back? Or would the inability to
> produce those CPs/CPSes be one of the reasons for root removal? (This would
> be a factor in retiring an older root.  See
> https://github.com/mozilla/pkipolicy/issues/232)
>
> Should this item 7 in MRSP section 3.3 also include requirements for
> retention and availability of the CPs and CPSes of externally operated
> third party CAs?  "This requirement also applies to the CPs and CPSes of
> externally operated third party CAs."
>
> Thanks,
>
> Ben
>
>
>
> On Mon, Mar 28, 2022 at 7:24 PM Ryan Sleevi <[email protected]> wrote:
>
>> Well, yes, but it's not that things can't change - just that there's a
>> history of those changes.
>>
>> In practice, I think it's more relevant to think of in the context of CA
>> Lifecycle that Wayne presented about during the Shanghai F2F [1]. A root
>> program understandably would want to know the entire lifecycle of the CA's
>> key material and operations - from birth to death. Having an audit report
>> over the continuous history is an important first step, for sure, but the
>> audit report is going to be contextual based on the policies and practices
>> in place during the audit period. So to have a full "birth to death"
>> situation, you need not only a continuous set of audits, but also an
>> unbroken sequence of policy documents for that same period.
>>
>> This policy change doesn't fully require the "birth certificate" approach
>> (although it's great to consider going forward), but it does seem to make
>> sense to set forward the policy documentation requirement, which presumably
>> the CA has and has maintained. If they haven't, perhaps it's another
>> incentive to rotate roots?
>>
>> Yes, I'm stuck on rotating roots. It's still good :)
>>
>> [1]
>> https://cabforum.org/2018/10/18/minutes-for-ca-browser-forum-f2f-meeting-45-shanghai-17-18-october-2018/#28-Audit-requirements-over-the-lifecycle-of-a-root
>>
>> On Mon, Mar 28, 2022 at 9:15 PM Jeremy Rowley <[email protected]>
>> wrote:
>>
>>> Even key protection changes over time as things move to new safes and
>>> hsms. Although I can see the value in knowing how the keys were stored
>>> during each phase of its life - ie a historic record of key protection from
>>> its creation to identify any areas that are later exposed as vulnerable.
>>> ------------------------------
>>> *From:* Ryan Sleevi <[email protected]>
>>> *Sent:* Monday, March 28, 2022 7:13 PM
>>> *To:* Jeremy Rowley <[email protected]>
>>> *Cc:* Pedro Fuentes <[email protected]>;
>>> [email protected] <[email protected]>;
>>> [email protected] <[email protected]>
>>> *Subject:* Re: Policy 2.8: MRSP Issue #185: Require publication of
>>> outdated CA policy documents
>>>
>>>
>>>
>>> On Mon, Mar 28, 2022 at 8:58 AM 'Jeremy Rowley' via
>>> [email protected] <[email protected]> wrote:
>>>
>>>> I don’t see the point of keeping the old CPS docs after the 7-year
>>>> requirement as everything after the 7-year archive period is purged. No one
>>>> should be operating under the old CPS docs at that time. Can you imagine if
>>>> we were protecting root keys the same way we did 30 years ago? Or doing the
>>>> validation the same way.
>>>>
>>>
>>> All the more reason to replace roots every few years, yes? ;-)
>>>
>>>
>>>> The only relevant section in old CPS docs that I’m aware of is key
>>>> generation. Key generation is a rather short section in CPS docs without a
>>>> lot of detail. The detail is in the key ceremony docs. If you want to
>>>> enforce records on key ceremonies, require retention of those rather than
>>>> the CPS docs.
>>>>
>>>
>>> Not just key generation though - but also key protection.
>>>
>>> Although yes, I agree with you, in practice most CP/CPSes are so
>>> anemically anodyne that the practical value, versus the intended value, is
>>> probably quite limited.
>>>
>>> There are other reasons that this could be useful, but they've primarily
>>> been tackled through other policy avenues (e.g. disclosure and auditing of
>>> intermediates).
>>>
>>

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