Not that a QIIS is slow to provide information but the QIIS may be slow to  
update. For example, one QIIS may say the address is A. A second may state the 
address as B. Resolving the different information takes time. Is there much 
interest from the CAB forum perspective on this issues?

Requiring reporting on this issues has the added disadvantage that it 
encourages a quick resolution (a determination that the address remained 
unchanged) rather than a thorough investigation about the changed info.

On Sep 13, 2017, at 10:44 AM, Ryan Sleevi 
<sle...@google.com<mailto:sle...@google.com>> wrote:



On Wed, Sep 13, 2017 at 1:24 PM, Jeremy Rowley via Public 
<public@cabforum.org<mailto:public@cabforum.org>> wrote:
A 24 hour report to the CAB Forum doesn’t make sense if the length of the 
investigation is not tied to the understanding/interpretation of the CAB Forum 
requirement.  For example, if someone alleges a company changed addresses, 
revocation may be required under “information appearing in the Certificate is 
inaccurate or misleading”.  Information in the QIIS might not be updated, the 
contact person may be on vacation, etc.  This isn’t a CAB Forum issue so 
there’s no reason to report that it’s taking longer than 24 hours to complete 
the certificate problem report.

What should be required, imo, is a report to the entity submitting the 
certificate problem report about why it’s taken longer than the required 24 
hours.  For investigation, what if we did:

  *   24 hours required for the initial report
  *   24 hours for the final report if the problem alleges X, Y, or Z
  *   7 days for the final report for all other reasons.

Anything taking longer than 24 hours because of an issue with the CAB Forum 
requirements, must be reported to the CAB Forum.

Then revocation stays at:

  *   24 hours required for X, Y, and Z
  *   24 hours SHOULD for all other reasons
  *   7 days required for all other reasons

Will this work?


I'm not sure I agree with that. That is, if someone is having trouble looking 
up information in a QIIS, then I think there is an expectation that CAs should 
be able to have process and controls to be able to confirm that information in 
a timely fashion. If, for example, the QIIS is particularly slow, then having a 
public discussion allows for opportunities to share information, such as 
whether CAs are using another QIIS to address this gap, or whether automated 
solutions exist, or whether an opportunity exists to feed that back to a QIIS.

I'm suggesting that, as an industry, we benefit most from information sharing, 
particularly around the challenges faced to ensure users are kept secure.

The ontology of whether or not it's a CA/B Forum issue is problematic, because 
one CA may argue it's a CABForum problem can easily vary between two CAs with 
the same problem. One may view it as a Forum problem that our definition of 
QIIS precludes certain automated sources (which might allow for a more rapid 
response), while another may view it as an external problem.

Similarly, if CAs are routinely getting 'bad' problem reports, having 
transparency about that allows the CA/Browser Forum to respond, as an industry, 
on potential solutions for that.
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