Our company's CA system is independent of telecommunications system. There 
is no impact on Chunghwa Telecom's CA System related to that data breach 
news. Chunghwa Telecom will continue to strengthen the system & network 
security control of the CA system to ensure data security. Thank you.

   Li-Chun Chen
   Chunghwa Telecom
   

Amir Omidi (aaomidi) 在 2024年5月24日 星期五凌晨1:59:33 [UTC+8] 的信中寫道:

Thanks. I guess this question then is aimed at Chunghwa Telecom to let us 
know if what's been reported has had any impact on their CA systems.

On Thursday, May 23, 2024 at 1:07:39 PM UTC-4 Ben Wilson wrote:

Amir,
To answer the last question first, Chunghwa Telecom did not disclose this 
recent attack, but I don't think we have sufficient information from the 
article to determine the effects of the breach on the CA operations. So 
without more information, it might be premature to answer the question, "Is 
a security incident like the one I posted above considered an instance of a 
CA "failing to comply"?" 
The process envisioned by the policy and guidance does contemplate that 
these disclosures would be in a secure bug (to which Mozilla would grant 
other root programs access). It also contemplates that another, public bug 
would need to be created, using the incident-reporting template (including 
a description of the CA's incident response). Finally, because this is a 
new process, we do not yet have any experiences to share or to use in 
evaluating the success or shortcomings of the requirement.
Ben 

On Thu, May 23, 2024 at 9:54 AM 'Amir Omidi (aaomidi)' via 
[email protected] <[email protected]> wrote:

Hey folks,

I am bringing this up because of: 
https://www.darkreading.com/cyberattacks-data-breaches/taiwan-telco-breached-data-sold-on-dark-web

(I've marked my questions in bold)

I'm mainly basing this discussion around: 
https://wiki.mozilla.org/CA/Vulnerability_Disclosure. I want to understand 
what the intent of some of the wording in this is, and how it applies to 
CAs.

In that wiki, we see:

> Vulnerabilities/incidents that may “significantly impact the 
confidentiality, integrity, or availability” of a CA's internal systems, 
regardless of direct impact on certificate issuance, must be reported if 
they pose ongoing risk to the overall integrity and security of CA 
operations. This includes significant impact not just to issuing systems, 
but also to network and server security, internal software, and the 
availability and reliability of certificate status services, such as CRLs 
and OCSP.

What is Mozilla's intent by the phrase "must be reported if they pose 
ongoing risk to the overall integrity and security of CA operations."

More specifically:

   1. *"Disclosed" to whom? Public? Just Mozilla?*
   2. *What does "if they pose an ongoing risk" mean? If its a one-off 
   attack, does that mean it does not need to be disclosed?*

I'm also unsure about trusting CAs to determine the significance of such an 
attack. We've seen recently that a few CAs have really jumped to making 
claims such as "this incident has no security impact" before doing any 
proper RCA or even understanding the extent of the incident. *Has Mozilla 
found any issues with leaving the determination up to CAs in the past?*

More broadly, how does this wiki work when read in conjunction with the Mozilla 
Root Store Policy 
<https://www.mozilla.org/en-US/about/governance/policies/security-group/certs/policy/>

Specifically, section 2.4:

> When a CA operator fails to comply with any requirement of this policy - 
whether it be a misissuance, a procedural or operational issue, or any 
other variety of non-compliance - the event is classified as an incident 
and MUST be reported to Mozilla as soon as the CA operator is made aware.

*Is a security incident like the one I posted above considered an instance 
of a CA "failing to comply"?*

In 2.4.1 we see:

> Additionally, and not in lieu of the requirement to publicly report 
incidents as outlined above, a CA Operator MUST disclose a serious 
vulnerability or security incident in Bugzilla 
<https://bugzilla.mozilla.org> as a secure bug 
<https://bugzilla.mozilla.org/enter_bug.cgi?bug_type=task&component=CA%20Security%20Vulnerability&groups=ca-program-security&product=CA%20Program>
 
in accordance with guidance found on the Vulnerability Disclosure wiki page 
<https://wiki.mozilla.org/CA/Vulnerability_Disclosure>.

>From my reading here, this means that all security vulnerabilities are 
being disclosed privately to Mozilla. I guess this *kind of* makes sense 
here.

*Would Mozilla be open to having a limited cooling-off period where these 
secure bugs stay private, but after that period the information becomes 
public*?

My justification for asking this is:

   - Other CAs can and should learn from how a CA responded to a security 
   incident.
   - There may be commonalities in attack patterns that these incidents 
   being public can help surface.
   - It reassures the community that these incidents are being taken 
   seriously by allowing third parties to also verify and validate the 
   incident response and mitigation items.


Beyond this, *I'd also be interested in hearing if Chunghwa Telecom has 
disclosed the impact of this recent attack on their systems (if any) to 
Mozilla and the other root programs.*


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