Re: Forbidden Practices: Subscriber key generation

2017-11-22 Thread Gervase Markham via dev-security-policy
On 14/11/17 21:53, Doug Beattie wrote
> The question is, if we issue Code Signing certificates via P12 files
> in compliance with the Code Signing standard, are we out of
> compliance with the Mozilla policy?  How do you recommend we respond
> to this checklist question?

Mozilla does not have policies relating to code signing. We would
therefore expect CAs to arrange things such that their code signing
activities fall outside the scope of the Mozilla policy. The scope
statement in the policy section 1.1, and it seems to me that the easiest
technical way to achieve this is to do code signing activities under an
intermediate which is technically constrained so it cannot issue email
or server certs.

> And the same for S/MIME and SSL certificates.  If CAs generate and
> then securely distribute the keys to the subscribers using similar
> methods, is that permitted provided we implement similar security, or
> does that practice need to immediately stop?  Your guidance in this
> area would be appreciated.

For SSL, I would say it needs to immediately stop. Although see:
https://github.com/mozilla/pkipolicy/issues/107

For S/MIME, as you can see, the Problematic Practices page permits it.

> Side question: Is there a deadline when you expect to receive
> self-assessments from all CAs?  We've found that complying with the
> checklist means a major update to our CPS (among other things...),
> and I suspect most other CAs will also need a major update.

I believe Kathleen did put a date in the CA Communication. If you need
more time, contact certificates@mozilla dot org with your good reasons :-)

Gerv
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Forbidden Practices: Subscriber key generation

2017-11-14 Thread Doug Beattie via dev-security-policy
Hi Gerv and Kathleen,

We're working on the Mozilla CA self-assessment checklist and referenced 
requirements you have placed on CAs.  On your page of Forbidden or Problematic 
Practices [1], you state that CAs must not generate private keys for signer 
certificates.
CAs must never generate the key pairs for signer or SSL certificates. CAs may 
only generate the key pairs for SMIME encryption certificates.

The Code signing standard [2], section 10.2.4 permits CAs to generate private 
keys for code signing certificates.  Specifically:
If the CA or any Delegated Third Party is generating the Private Key on behalf 
of the Subscriber where the Private Keys will be transported to the Subscriber 
outside of the Signing Service's secure infrastructure, then the entity 
generating the Private Key MUST either transport the Private Key in hardware 
with an activation method that is equivalent to 128 bits of encryption or 
encrypt the Private Key with at least 128 bits of encryption strength. Allowed 
methods include using a 128-bit AES key to wrap the private key or storing the 
key in a PKCS 12 file encrypted with a randomly generated password of more than 
16 characters containing uppercase letters, lowercase letters, numbers, and 
symbols for transport.


The question is, if we issue Code Signing certificates via P12 files in 
compliance with the Code Signing standard, are we out of compliance with the 
Mozilla policy?  How do you recommend we respond to this checklist question?

And the same for S/MIME and SSL certificates.  If CAs generate and then 
securely distribute the keys to the subscribers using similar methods, is that 
permitted provided we implement similar security, or does that practice need to 
immediately stop?  Your guidance in this area would be appreciated.

Side question: Is there a deadline when you expect to receive self-assessments 
from all CAs?  We've found that complying with the checklist means a major 
update to our CPS (among other things...), and I suspect most other CAs will 
also need a major update.

Doug

[1] https://wiki.mozilla.org/CA/Forbidden_or_Problematic_Practices
[2] 
https://casecurity.org/wp-content/uploads/2016/09/Minimum-requirements-for-the-Issuance-and-Management-of-code-signing.pdf


Doug Beattie
Product Mangement
GMO GlobalSign, Inc.
Portsmouth, NH USA

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