Re: Change of Root ownership structure

[Arnold Essing via dev-security-policy]

We would like to inform you that our transition from "T-Systems International 
GmbH" to "Deutsche Telekom Security GmbH" has been finalized on July 1, 2020.
This has been discussed in this mailing list in the time period of April 27th 
to May 26th,2020: 
https://groups.google.com/d/msg/mozilla.dev.security.policy/pOu_jWY0SVY/9HnbIjaiAwAJ
Our CP, CPS and other documents have all been updated and published 
accordingly. Our Audit Attestations will be updated soon.
Thanks to Kathleen Wilson for carrying out the necessary changes in the CCADB.
Since July 1st 2020, our Trust Center also received a new homepage 
(www.telesec.de). The English version of that homepage is still under 
construction for which we want apologize.
Due to "Deutsche Telekom Security GmbH" being quite a long term we plan to use 
our short name "Telekom Security" whenever possible.



-Ursprüngliche Nachricht-
Von: dev-security-policy  Im 
Auftrag von Arnold Essing via dev-security-policy
Gesendet: Montag, 27. April 2020 06:45
An: mozilla-dev-security-pol...@lists.mozilla.org
Betreff: Change of Root ownership structure

This message is addressed to the CA/Browser community in relation to the 
request for transfer of root ownership. The root ownership will change from 
"T-Systems International GmbH" to "Deutsche Telekom Security GmbH". Both units 
are 100% subsidiary of the "Deutsche Telekom AG". In accordance with the 
Mozilla Root Store 
Policy<https://www.mozilla.org/en-US/about/governance/policies/security-group/certs/policy/>
 (section 8.1), we would like to inform you and wish to start a public 
discussion.

The internal ownership structure of the two public roots "T-TeleSec GlobalRoot 
Class 2" and "T-TeleSec GlobalRoot Class 3" from T-Systems International GmbH 
is planned to change on July 1, 2020.  The ownership will remain within the 
company "Deutsche Telekom AG". The CA's operation team, Root decision makers 
and Top Level Management will not change. There will be no material or 
technical location changes. It is planned to transfer via spin-off agreement.

Some information concerning the new company for security, "Deutsche Telekom 
Security GmbH":
   Deutsche Telekom Security GmbH
   Bonner Talweg 100
   53113 Bonn
   The company is based at the Bonn District Court (Amtsgericht Bonn), under 
HRB 15241.
   The spin-off and transfer of the Security subordinate operation as an 
operational business (contracts, employees, property, etc.) from T-Systems 
International GmbH to Deutsche Telekom Security GmbH is planned for July 1, 
2020.
   This will become effective once the secession has been entered in the 
commercial register.

We plan to update and publish our CP/CPS documents for the time the changes 
become effective. At the moment there are no anticipated changes to the CP/CPS 
updates for July 1, 2020 other than the new organization name and address.

We will inform you once the transition has been finalized in accordance with 
the German Reorganization and Transformation Act (UmwG). The projected date is 
July 1, 2020.

Please contact us if you have any questions or if more information is needed.

Best regards,
T-Systems Root Team


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Re: Change of Root ownership structure

[Wayne Thayer via dev-security-policy]

Given that no other concerns have been raised, I consider this request to
have been "resolved with a positive conclusion" as required by Mozilla
policy section 8.1.

Arnold: please update the information in CCADB (or ask Kathleen if you are
unable) when this change takes effect.

- Wayne

On Wed, Apr 29, 2020 at 11:56 AM Wayne Thayer  wrote:

> Thank you for making this announcement Arnold. This change of legal
> ownership is covered by section 8.1 of the Mozilla Root Store Policy,
> including the following statement:
>
> If the receiving or acquiring company is new to the Mozilla root program,
>> it must demonstrate compliance with the entirety of this policy and there
>> MUST be a public discussion regarding their admittance to the root program,
>> which Mozilla must resolve with a positive conclusion in order for the
>> affected certificate(s) to remain in the root program.
>>
>
> Technically I believe the statement above applies to this situation, so I
> would like to formally begin the discussion period for this change in legal
> ownership of the T-Systems CA by requesting additional thoughtful and
> constructive feedback from the community. I will plan to keep the
> discussion period open for a minimum of 3 weeks.
>
> T-Systems has already indicated that no changes to their CP/CPS are
> planned aside from the company name.
>
> On Tue, Apr 28, 2020 at 7:18 AM Pedro Fuentes via dev-security-policy <
> dev-security-policy@lists.mozilla.org> wrote:
>
>> Thanks, Arnold.
>>
>> Our change was more complex, so we had to go to a more cumbersome
>> process, including audits of the ownership receiving party.
>>
>> What I guess it's required now is an explicit confirmation from Mozilla
>> to say if such a direct transfer to an entity not member of the program is
>> compliant with section 8.1 of the policy.
>>
>>
> I believe that the plan described by T-Systems is compliant with Mozilla
> policy.
>
> - Wayne
>
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Re: Change of Root ownership structure

[Wayne Thayer via dev-security-policy]

Thank you for making this announcement Arnold. This change of legal
ownership is covered by section 8.1 of the Mozilla Root Store Policy,
including the following statement:

If the receiving or acquiring company is new to the Mozilla root program,
> it must demonstrate compliance with the entirety of this policy and there
> MUST be a public discussion regarding their admittance to the root program,
> which Mozilla must resolve with a positive conclusion in order for the
> affected certificate(s) to remain in the root program.
>

Technically I believe the statement above applies to this situation, so I
would like to formally begin the discussion period for this change in legal
ownership of the T-Systems CA by requesting additional thoughtful and
constructive feedback from the community. I will plan to keep the
discussion period open for a minimum of 3 weeks.

T-Systems has already indicated that no changes to their CP/CPS are planned
aside from the company name.

On Tue, Apr 28, 2020 at 7:18 AM Pedro Fuentes via dev-security-policy <
dev-security-policy@lists.mozilla.org> wrote:

> Thanks, Arnold.
>
> Our change was more complex, so we had to go to a more cumbersome process,
> including audits of the ownership receiving party.
>
> What I guess it's required now is an explicit confirmation from Mozilla to
> say if such a direct transfer to an entity not member of the program is
> compliant with section 8.1 of the policy.
>
>
I believe that the plan described by T-Systems is compliant with Mozilla
policy.

- Wayne
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Re: Change of Root ownership structure

[Pedro Fuentes via dev-security-policy]

Thanks, Arnold.

Our change was more complex, so we had to go to a more cumbersome process, 
including audits of the ownership receiving party.

What I guess it's required now is an explicit confirmation from Mozilla to say 
if such a direct transfer to an entity not member of the program is compliant 
with section 8.1 of the policy.
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AW: Change of Root ownership structure

[Arnold Essing via dev-security-policy]

Hello Pedro,

In response to your questions:
Yes, the ownership of all Root and Subordinate CAs of "T-Systems International 
GmbH" will be changed to "Deutsche Telekom Security GmbH".
Since the change of ownership is between two 100%-subsidiaries of the "Deutsche 
Telekom AG" and does not involve any changes to physical locations, personnel, 
procedures or material, the actual change is mainly only on paper, replacing 
the name "T-Systems International GmbH" with "Deutsche Telekom Security GmbH" 
in the corresponding documents as well as updating contracts with suppliers etc.
Also, the auditors have been informed of the upcoming change. 

Kind regards,
Arnold



-Ursprüngliche Nachricht-
Von: dev-security-policy  Im 
Auftrag von Pedro Fuentes via dev-security-policy
Gesendet: Montag, 27. April 2020 09:44
An: mozilla-dev-security-pol...@lists.mozilla.org
Betreff: Re: Change of Root ownership structure

Hello Arnold,
as we did recently an ownership change, I'm interested on how yours is arranged.

I'd have some questions:
- Would this imply the change of ownership of all the subordinates too or some 
will remain owned by T-Systems?
- You mention that the ownership change already has a date (July, 1st). What is 
your compliance plan, to ensure that the new owner is aligned with the Root 
Program Policies (i.e. Webtrust audit or similar).

Thanks,
Pedro
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Re: Change of Root ownership structure

[Pedro Fuentes via dev-security-policy]

Hello Arnold,
as we did recently an ownership change, I'm interested on how yours is arranged.

I'd have some questions:
- Would this imply the change of ownership of all the subordinates too or some 
will remain owned by T-Systems?
- You mention that the ownership change already has a date (July, 1st). What is 
your compliance plan, to ensure that the new owner is aligned with the Root 
Program Policies (i.e. Webtrust audit or similar).

Thanks,
Pedro
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Change of Root ownership structure

[Arnold Essing via dev-security-policy]

This message is addressed to the CA/Browser community in relation to the 
request for transfer of root ownership. The root ownership will change from 
"T-Systems International GmbH" to "Deutsche Telekom Security GmbH". Both units 
are 100% subsidiary of the "Deutsche Telekom AG". In accordance with the 
Mozilla Root Store 
Policy
 (section 8.1), we would like to inform you and wish to start a public 
discussion.

The internal ownership structure of the two public roots "T-TeleSec GlobalRoot 
Class 2" and "T-TeleSec GlobalRoot Class 3" from T-Systems International GmbH 
is planned to change on July 1, 2020.  The ownership will remain within the 
company "Deutsche Telekom AG". The CA's operation team, Root decision makers 
and Top Level Management will not change. There will be no material or 
technical location changes. It is planned to transfer via spin-off agreement.

Some information concerning the new company for security, "Deutsche Telekom 
Security GmbH":
   Deutsche Telekom Security GmbH
   Bonner Talweg 100
   53113 Bonn
   The company is based at the Bonn District Court (Amtsgericht Bonn), under 
HRB 15241.
   The spin-off and transfer of the Security subordinate operation as an 
operational business (contracts, employees, property, etc.) from T-Systems 
International GmbH to Deutsche Telekom Security GmbH is planned for July 1, 
2020.
   This will become effective once the secession has been entered in the 
commercial register.

We plan to update and publish our CP/CPS documents for the time the changes 
become effective. At the moment there are no anticipated changes to the CP/CPS 
updates for July 1, 2020 other than the new organization name and address.

We will inform you once the transition has been finalized in accordance with 
the German Reorganization and Transformation Act (UmwG). The projected date is 
July 1, 2020.

Please contact us if you have any questions or if more information is needed.

Best regards,
T-Systems Root Team

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