Re: Allow Redaction of issues detailed in BR Audit statements?

2014-09-03 Thread Kurt Roeckx

On 2014-08-27 18:15, Kathleen Wilson wrote:

Based on the discussion so far, I think the answer is that the CAs need
to work with their auditors to create a public-facing audit statement
that does not have information in it that the CA considers sensitive,
but that sufficiently lists the BRs that the CA is still working to
conform with.


I agree with this too.  I think it's important to know that there are 
problems and that they are being worked on.


I've been checking certificates and filing bugs in Mozilla's bugzilla, 
so all those things are currently also public.  But I try to only put 
there what I think is needed, and if the CA wants more detailed 
information I'm happy to send it to them directly instead of via bugzilla.


The wiki you pointed to about the baseline requirements says that the 
first audit might have a list of things it's not in compliance with and 
that we expect the next one confirm they have been fixed.  Do such 
reports explicitly confirm that they have been fixed?


It seems to give the impression that next audit report is not supposed 
to give a (public) list of requirements it's not in compliance with. 
But since the requirements change over time, for instance 1024/2048 bit, 
SHA1/SHA256, procedures and used software might change over time, and so 
on, I expect that a next audit might find new issues that were 
previously not found.  So I expect every report to give such a list, or 
explicitly say that no problems where found.  And that would go for all 
the audit reports.



Kurt

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Re: Allow Redaction of issues detailed in BR Audit statements?

2014-08-28 Thread Man Ho (Certizen)

On 8/28/2014 9:42 AM, Man Ho (Certizen) wrote:
 I think some CAs don't
 even want to claim they are CAB/Forum BR compliant, but just want to be
 included in all root certificate programs.
What I mean is that some CAs don't want to claim they are CAB/Forum BR
compliant, but committed to conform to it in order to be included in all
root certificate programs. They just don't bother to publicly claim that
they have any connection with CAB/Forum.

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Re: Allow Redaction of issues detailed in BR Audit statements?

2014-08-28 Thread Matt Palmer
On Thu, Aug 28, 2014 at 02:40:08PM +0800, Man Ho (Certizen) wrote:
 On 8/28/2014 9:42 AM, Man Ho (Certizen) wrote:
  I think some CAs don't
  even want to claim they are CAB/Forum BR compliant, but just want to be
  included in all root certificate programs.

 What I mean is that some CAs don't want to claim they are CAB/Forum BR
 compliant, but committed to conform to it in order to be included in all
 root certificate programs. They just don't bother to publicly claim that
 they have any connection with CAB/Forum.

I don't believe a CA has to claim any connection with the CA/B Forum.  They
merely have to assert (and have that assertion supported by an audit
finding) that they're compliant with either the WebTrust criteria (which are
based off the CA/B Forum requirements), or one of a couple of ETSI standards
(which, I believe, aren't).

- Matt

-- 
I invented the term object-oriented, and I can tell you I did not have C++
in mind.   -- Alan Kay

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Re: Allow Redaction of issues detailed in BR Audit statements?

2014-08-28 Thread Moudrick Dadashov
Please see page 7 of ETSI 102 042:

ETSI - Electronic Signature and Infrastructure (ESI) includes in the present 
document provisions consistent with the requirements for issuing Extended 
Validation Certificates (EVC), as specified in the above mentioned CAB Forum 
EVC Guidelines (EVCG [16]) as well as Publicly trusted TLS/SSL certificates, as 
specified in the mentioned CAB Forum PTC guidelines (BRG [19]) As a 
consequence, EVC and PTC issued by CAs operating in compliance with the EVC and 
PTC related provisions as indicated in the present document can be assessed as 
meeting the requirements specified by the CAB Forum in their EVCG [16] and BRG 
[19] plus recognised good practice for CA's issuing certificates. 

Thanks,
M.D.

Matt Palmer mpal...@hezmatt.org wrote:

On Thu, Aug 28, 2014 at 02:40:08PM +0800, Man Ho (Certizen) wrote:
 On 8/28/2014 9:42 AM, Man Ho (Certizen) wrote:
  I think some CAs don't
  even want to claim they are CAB/Forum BR compliant, but just want to be
  included in all root certificate programs.

 What I mean is that some CAs don't want to claim they are CAB/Forum BR
 compliant, but committed to conform to it in order to be included in all
 root certificate programs. They just don't bother to publicly claim that
 they have any connection with CAB/Forum.

I don't believe a CA has to claim any connection with the CA/B Forum.  They
merely have to assert (and have that assertion supported by an audit
finding) that they're compliant with either the WebTrust criteria (which are
based off the CA/B Forum requirements), or one of a couple of ETSI standards
(which, I believe, aren't).

- Matt

-- 
I invented the term object-oriented, and I can tell you I did not have C++
in mind.  -- Alan Kay

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Re: Allow Redaction of issues detailed in BR Audit statements?

2014-08-28 Thread Kathleen Wilson

On 8/27/14, 9:15 AM, Kathleen Wilson wrote:

Based on the discussion so far, I think the answer is that the CAs need
to work with their auditors to create a public-facing audit statement
that does not have information in it that the CA considers sensitive,
but that sufficiently lists the BRs that the CA is still working to
conform with.



I added text about this to
https://wiki.mozilla.org/CA:BaselineRequirements#BR_Audits

==
As with the other audits required of CAs in Mozilla's Program, the BR 
Audit statement must be a public-facing document. Section 6 of Mozilla's 
CA Certificate Inclusion Policy says: We require that all CAs whose 
certificates are distributed with our software products: ... publicly 
disclose information about their policies and business practices (e.g., 
in a Certificate Policy and Certification Practice Statement); ... 
provide *public attestation* of their conformance to the stated 
verification requirements and other operational criteria by a competent 
independent party or parties with access to details of the CA’s internal 
operations.


As previously stated, it is acceptable for an audit statement to list 
the BRs that the CA is not yet fully in compliance with. However, this 
may result in an auditor providing information in the BR audit statement 
that the CA considers sensitive (e.g. subordinate CA specifics, RA 
information, customer information, or security sensitive information). 
Each CA must work with their auditor to create a public-facing BR audit 
statement that does not have information in it that the CA considers 
sensitive, but that sufficiently lists the BRs that the CA is still 
working to conform with.


Here are some examples of the level of information that should be 
included in the BR audit statement in regards to BRs that the CA is not 
yet fully conforming to.


BR 9.5 – 1024-bit certs with validity beyond 2013 (in order to 
support legacy customer apps)

BR 13.2.6 - OCSP giving status “good” for unknown serial numbers.
BR 16.5 - multi-factor authentication for all accounts capable of 
directly causing certificate issuance
BR 17.5 - The audit period for the Delegated Third Party SHALL NOT 
exceed one year
BR 17.8 – audits on at least a quarterly basis against a randomly 
selected sample of the greater of one certificate or at least three 
percent of the Certificates issued by it during the period commencing 
immediately after the previous self-audit sample was taken

BR 11.2 – re-verifying identity for cert renewal requests
==


I'll appreciate feedback on this.

Thanks,
Kathleen





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Re: Allow Redaction of issues detailed in BR Audit statements?

2014-08-27 Thread Jean-Marc Desperrier

David E. Ross a écrit :

With a redacted audit report, the presumption
should be that hidden negative information exists that would disqualify
the certification authority from having its root certificate in the NSS
database if such information were disclosed.

any redaction would imply the existence of hidden negative
information that would necessitate removal of the affected root
certificate from the NSS database if such information were disclosed.


I think there's miscomprehension here.

I understand that the CAs are OK with people knowing that some unknown 
serial numbers would give status “good”, but not with them knowing the 
exact values of the concerned serial numbers, which could be used to 
attack the system. Likewise with the 1024-bit certs with validity beyond 
2013, it's useful to know they existed but a different matter to get the 
name of the client (in that case, Mozilla could published the number of 
certificates concerned).
Or letting people know which accounts exactly didn't have  multi-factor 
authentication for certificate issuance.


I understand the redaction not to be about which kind of problem there 
was, but about letting specific nominative information be published 
about each problem.

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Re: Allow Redaction of issues detailed in BR Audit statements?

2014-08-27 Thread David E. Ross
On 8/27/2014 7:11 AM, Jean-Marc Desperrier wrote:
 David E. Ross a écrit :
 With a redacted audit report, the presumption
 should be that hidden negative information exists that would disqualify
 the certification authority from having its root certificate in the NSS
 database if such information were disclosed.

 any redaction would imply the existence of hidden negative
 information that would necessitate removal of the affected root
 certificate from the NSS database if such information were disclosed.
 
 I think there's miscomprehension here.
 
 I understand that the CAs are OK with people knowing that some unknown 
 serial numbers would give status “good”, but not with them knowing the 
 exact values of the concerned serial numbers, which could be used to 
 attack the system. Likewise with the 1024-bit certs with validity beyond 
 2013, it's useful to know they existed but a different matter to get the 
 name of the client (in that case, Mozilla could published the number of 
 certificates concerned).
 Or letting people know which accounts exactly didn't have  multi-factor 
 authentication for certificate issuance.
 
 I understand the redaction not to be about which kind of problem there 
 was, but about letting specific nominative information be published 
 about each problem.
 

If a certification authority (CA) were concerned that its audit report
would be made public without any redaction whatsoever, that CA should
operate in a way that ensures nothing in the report would be
embarrassing to itself or harmful to its customers.

-- 
David E. Ross

The Crimea is Putin's Sudetenland.
The Ukraine will be Putin's Czechoslovakia.
See http://www.rossde.com/editorials/edtl_PutinUkraine.html.
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Re: Allow Redaction of issues detailed in BR Audit statements?

2014-08-27 Thread Kathleen Wilson

On 8/27/14, 7:11 AM, Jean-Marc Desperrier wrote:

David E. Ross a écrit :

With a redacted audit report, the presumption
should be that hidden negative information exists that would disqualify
the certification authority from having its root certificate in the NSS
database if such information were disclosed.

any redaction would imply the existence of hidden negative
information that would necessitate removal of the affected root
certificate from the NSS database if such information were disclosed.


I think there's miscomprehension here.

I understand that the CAs are OK with people knowing that some unknown
serial numbers would give status “good”, but not with them knowing the
exact values of the concerned serial numbers, which could be used to
attack the system. Likewise with the 1024-bit certs with validity beyond
2013, it's useful to know they existed but a different matter to get the
name of the client (in that case, Mozilla could published the number of
certificates concerned).
Or letting people know which accounts exactly didn't have  multi-factor
authentication for certificate issuance.

I understand the redaction not to be about which kind of problem there
was, but about letting specific nominative information be published
about each problem.



Yes. That is a good explanation of the issue.

So, I thought I would float the idea and see what happens, or see if 
others had ideas about this.


Based on the discussion so far, I think the answer is that the CAs need 
to work with their auditors to create a public-facing audit statement 
that does not have information in it that the CA considers sensitive, 
but that sufficiently lists the BRs that the CA is still working to 
conform with.


Thanks,
Kathleen

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Re: Allow Redaction of issues detailed in BR Audit statements?

2014-08-27 Thread Matt Palmer
On Thu, Aug 28, 2014 at 09:42:13AM +0800, Man Ho (Certizen) wrote:
 Concerning about a list of BRs that the CA is still working to conform
 with, I don't think CAs will agree to publish in public for security
 reason and also because of business sensitivity. I think some CAs don't
 even want to claim they are CAB/Forum BR compliant, but just want to be
 included in all root certificate programs.

And I want a pony.  But wishing don't make it so.

- Matt

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Re: Allow Redaction of issues detailed in BR Audit statements?

2014-08-26 Thread Peter Bowen
On Tue, Aug 26, 2014 at 11:35 AM, Kathleen Wilson kwil...@mozilla.com wrote:
 I am running into a problem with BR audit statements that list details about
 issues that have been found.

 https://wiki.mozilla.org/CA:CertificatePolicyV2.1#Baseline_Requirements
 ...The first BR audit for each CA and subCA may include a reasonable list
 of BRs that the CA (or subCA) is not yet in compliance with. ...

 The problem is that some BR audit statements provide information about the
 CA's BR non-conformance that the CA considers to be sensitive (and
 non-publishable) information.

Without any concrete data on the scope of the items that are not yet
in compliance it is hard to make judgements.

 In the spreadsheet of included roots, I could add a column to list BR
 section numbers that were in the redacted information.

Could you publish a list of BR section numbers which one or more CA is
saying they do not yet comply with, not including any CA names?  That
would help determine the scope of the request and provide some
guidance on the possible impact of the non-compliance without calling
out any specific CA(s).

Thanks,
Peter
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Re: Allow Redaction of issues detailed in BR Audit statements?

2014-08-26 Thread Kathleen Wilson

On 8/26/14, 12:10 PM, Peter Bowen wrote:

Could you publish a list of BR section numbers which one or more CA is
saying they do not yet comply with, not including any CA names?  That
would help determine the scope of the request and provide some
guidance on the possible impact of the non-compliance without calling
out any specific CA(s).




Collected from BR audit statements from multiple CAs...

BR 9.5 – 1024-bit certs with validity beyond 2013 (in order to support 
legacy customer apps)


BR 13.2.6 - OCSP giving status “good” for unknown serial numbers.

BR 16.5 - multi-factor authentication for *all* accounts capable of 
directly causing certificate issuance


BR 17.5 - The audit period for the Delegated Third Party SHALL NOT 
exceed one year


BR 17.8 –  audits on at least a quarterly basis against a randomly 
selected sample of the greater of one certificate or *at least three 
percent* of the Certificates issued by it during the period commencing 
immediately after the previous self-audit sample was taken


BR 11.2 – re-verifying identity for cert renewal requests




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Re: Allow Redaction of issues detailed in BR Audit statements?

2014-08-26 Thread Kathleen Wilson

On 8/26/14, 1:14 PM, Chris Palmer wrote:

On Tue, Aug 26, 2014 at 1:09 PM, Kathleen Wilson kwil...@mozilla.com wrote:


BR 9.5 – 1024-bit certs with validity beyond 2013 (in order to support
legacy customer apps)

BR 13.2.6 - OCSP giving status “good” for unknown serial numbers.

BR 16.5 - multi-factor authentication for *all* accounts capable of directly
causing certificate issuance

BR 17.5 - The audit period for the Delegated Third Party SHALL NOT exceed
one year

BR 17.8 –  audits on at least a quarterly basis against a randomly selected
sample of the greater of one certificate or *at least three percent* of the
Certificates issued by it during the period commencing immediately after the
previous self-audit sample was taken

BR 11.2 – re-verifying identity for cert renewal requests


It is a bad idea to censor these highly relevant facts.

These are the baseline requirements for a company to be trusted by the
entire planet.




This is the level of information I could list for each CA who had a 
redacted section in their BR audit.


The problem is that the BR audit statements have further details that 
the CAs do not want published.


I'm just exploring how to get past the current situation of CAs not 
being able to provide public-facing BR audit statements for their first 
full-year BR audit.




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Re: Allow Redaction of issues detailed in BR Audit statements?

2014-08-26 Thread Kathleen Wilson

On 8/26/14, 1:42 PM, Chris Palmer wrote:


If CAs can't meet the baseline requirements that they themselves
helped set, and prove so to the public, perhaps the current situation
is the end of the road.



Sigh. It'll get better. I can see in those audit statements that the 
issues either were resolved or are soon to be resolved.



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Re: Allow Redaction of issues detailed in BR Audit statements?

2014-08-26 Thread Peter Bowen
On Tue, Aug 26, 2014 at 1:24 PM, Kathleen Wilson kwil...@mozilla.com wrote:
 On Tue, Aug 26, 2014 at 1:09 PM, Kathleen Wilson kwil...@mozilla.com wrote:

 BR 9.5 – 1024-bit certs with validity beyond 2013 (in order to support
 legacy customer apps)

 BR 13.2.6 - OCSP giving status “good” for unknown serial numbers.

 BR 16.5 - multi-factor authentication for *all* accounts capable of
 directly causing certificate issuance

 BR 17.5 - The audit period for the Delegated Third Party SHALL NOT exceed
 one year

 BR 17.8 –  audits on at least a quarterly basis against a randomly
 selected sample of the greater of one certificate or *at least three 
 percent* of
 the Certificates issued by it during the period commencing immediately after
 the previous self-audit sample was taken

 BR 11.2 – re-verifying identity for cert renewal requests

 This is the level of information I could list for each CA who had a redacted
 section in their BR audit.

 The problem is that the BR audit statements have further details that the
 CAs do not want published.

 I'm just exploring how to get past the current situation of CAs not being
 able to provide public-facing BR audit statements for their first full-year
 BR audit.

The Mozilla CA Communcation in Jan 2013 asked each CA whether they
comply with the BR.
(https://wiki.mozilla.org/CA:Communications#January_10.2C_2013
question 2).  According to the results spreadsheet, a number of CAs
disclosed non-compliance with remediation dates (Option C under Action
2).

I would propose than any findings that match those called out in that
spreadsheet be redacted.  For example, unfairly picking on a CA,
Unizeto said they would have the OCSP requirement met by Oct 2013.  If
their audit shows that they did not meet BR 13.2.6 until September
2013, then this would match the spreadsheet and the finding would be
redacted.  However if, again unfairly picking a CA, A-Trust, who chose
option A, had findings, these would not be redacted.

This would allow the finer/more sensitive details of previously
disclosed items (for example the names of Unizeto's sub-CAs who didn't
have OCSP) to not be further disclosed.

Thanks,
Peter
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Re: Allow Redaction of issues detailed in BR Audit statements?

2014-08-26 Thread Matt Palmer
Hi Kathleen,

My take on this is that any information that is relevant to a CA's
conformance (or lack thereof) with the BRs (or any other part of Mozilla's
inclusion criteria) needs to be disclosed to those who are passing judgment
on the suitability of the CA for inclusion in the Mozilla trust store.  If
the public (or at least that subset which is subscribed to and
participates on this list) are deemed to be passing judgment, then yes,
that information needs to be publically disclosed.

At this point, though, there shouldn't be any CAs with an adverse finding in
their audit report.  The audit done by Feb 2013 could list adverse findings,
but the next audit statement (which was due in Feb 2014 -- six months ago)
should have been clean and without qualification.  Any CA who isn't willing
to hold up their audit report to the world and say See!  We're clean! is
eligible for removal, either because their audit is out of date (by at least
six months) or else is documented to not be in conformance with the BRs.

On an unrelated point, I'd like to thank you, Kathleen, for the work you do
in this area.  Going over the minutiae of audit reports can't be a
particularly fun job, but it *is* a very necessary one, so thanks for being
the one who does it.

- Matt

On Tue, Aug 26, 2014 at 11:35:27AM -0700, Kathleen Wilson wrote:
 I am running into a problem with BR audit statements that list
 details about issues that have been found.
 
 https://wiki.mozilla.org/CA:CertificatePolicyV2.1#Baseline_Requirements
 ...The first BR audit for each CA and subCA may include a
 reasonable list of BRs that the CA (or subCA) is not yet in
 compliance with. ...
 
 The problem is that some BR audit statements provide information
 about the CA's BR non-conformance that the CA considers to be
 sensitive (and non-publishable) information.
 
 As you know, Mozilla's policy requires public-facing audit statements.
 https://www.mozilla.org/en-US/about/governance/policies/security-group/certs/policy/inclusion/
 6. ... provide public attestation of their conformance to the
 stated verification requirements ...
 
 So, I need a way forward that enables the CA to provide the required
 BR audit statement without publicly disclosing sensitive
 information.
 
 Just brainstorming...
 
 Would it be OK to accept public-facing BR audit statements that have
 the information about the issues redacted?
 
 In the spreadsheet of included roots, I could add a column to list
 BR section numbers that were in the redacted information.
 
 I will appreciate thoughtful and constructive input on this topic.
 
 Kathleen
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 https://lists.mozilla.org/listinfo/dev-security-policy
 

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Re: Allow Redaction of issues detailed in BR Audit statements?

2014-08-26 Thread Chris Palmer
On Tue, Aug 26, 2014 at 5:18 PM, Matt Palmer mpal...@hezmatt.org wrote:

 On an unrelated point, I'd like to thank you, Kathleen, for the work you do
 in this area.  Going over the minutiae of audit reports can't be a
 particularly fun job, but it *is* a very necessary one, so thanks for being
 the one who does it.

And a hearty +1 to that!
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