RE: CA handling of contact information when reporting problems

2019-08-22 Thread Jeremy Rowley via dev-security-policy
I'm not sure there should be a strict requirement that you can't provide that 
communication (sometimes there is good reason to get people talking together). 
However, we don't forward this information as policy because we like to get the 
reports. Anything that ends up stifling getting the information is worse for us 
and hinders getting third party input on improvements on our operation. A 
Mozilla policy or CAB forum policy against disclosure seems like a bad idea 
since there are cases of abuse that could happen give the broad range of 
potential reasons for revocation under the BRs, some of which may require 
corroboration between the reporter and site owner, like "accurate information" 
or "misuse". 

-Original Message-
From: dev-security-policy  On 
Behalf Of Matthew Hardeman via dev-security-policy
Sent: Thursday, August 22, 2019 9:49 AM
To: mozilla-dev-security-pol...@lists.mozilla.org
Subject: Re: CA handling of contact information when reporting problems

I'm merely a relying party and subscriber, but it seems quite unreasonable to 
believe that there is or should be any restriction upon a party to a business 
communication (which is what a report / complaint from a third party regarding 
key compromise, etc, is) from further dissemination of said communications.

It seems to me quite a stretch to suggest that the even the GDPR restrains such 
behavior.  Are people seriously suggesting that a third party, with whom you 
have no NDA or agreement in place, may as much as email you and expect you to 
take action based upon said email AND expect that you be enjoined from as 
little as forwarding a copy of that email?  That seems absurd.
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Re: CA handling of contact information when reporting problems

2019-08-22 Thread Matthew Hardeman via dev-security-policy
I'm merely a relying party and subscriber, but it seems quite unreasonable
to believe that there is or should be any restriction upon a party to a
business communication (which is what a report / complaint from a third
party regarding key compromise, etc, is) from further dissemination of said
communications.

It seems to me quite a stretch to suggest that the even the GDPR restrains
such behavior.  Are people seriously suggesting that a third party, with
whom you have no NDA or agreement in place, may as much as email you and
expect you to take action based upon said email AND expect that you be
enjoined from as little as forwarding a copy of that email?  That seems
absurd.
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RE: CA handling of contact information when reporting problems

2019-08-22 Thread Tim Hollebeek via dev-security-policy
DigiCert currently has a policy of not publishing the names of those who
report things to us without their permission.  It just seems like the right 
thing to do.

If we do find that people are abusing that protection to selectively harass 
people that they personally have issues with, we may need to revisit that, but 
we haven't seen any evidence that is currently happening.  Most of the people 
who report issues to us are quite professional about it, and we're always happy 
to engage with them.

I would be interested to hear what others think the appropriate behavior for a 
CA is here, since it isn't covered by any compliance requirements.  

-Tim

> -Original Message-
> From: dev-security-policy  On
> Behalf Of Jakob Bohm via dev-security-policy
> Sent: Monday, August 19, 2019 8:22 PM
> To: mozilla-dev-security-pol...@lists.mozilla.org
> Subject: Re: CA handling of contact information when reporting problems
> 
> On 20/08/2019 03:15, Corey Bonnell wrote:
> > On Monday, August 19, 2019 at 10:26:06 AM UTC-4, Mathew Hodson wrote:
> >> Tom Wassenberg on Twitter reported an experience he had with Sectigo
> >> when reporting a compromised private key.
> >>
> >> https://twitter.com/tomwas54/status/1162114413148725248
> >> https://twitter.com/tomwas54/status/1162114465065840640
> >> https://twitter.com/tomwas54/status/1162114495017299976
> >>
> >> "So a few weeks ago, I came across a private key used for a TLS
> >> certificate, posted online. These should never be public (hence the
> >> "private"), and every trusted CA is obliged to revoke any certificate
> >> they issued when they become aware its private key is compromised.
> >>
> >> "So when I informed the issuing CA (@SectigoHQ) about this, they
> >> promptly revoked the cert. Two weeks later however, I receive an
> >> angry email from the company using the cert (cc'd to their lawyer),
> >> blaming me for a disruption in the services they provide.
> >>
> >> "The company explicitly mentioned @SectigoHQ "was so kind" to give
> >> them my contact info! It was a complete surprise for me that
> >> @SectigoHQ would do this without my consent. Especially seeing how
> >> the info was used to badger me."
> >>
> >> If these situations were common, it could create a chilling effect on
> >> problem reporting that would hurt the WebPKI ecosystem. Are specific
> >> procedures and handling of contact information in these situations
> >> covered by the BRs or Mozilla policy?
> >
> > Many CAs disclose the reporter's name and email address as part of their
> response to item 1 of the incident report template [1]. So this information is
> already publicly available if the Subscriber were so inclined to look for it.
> >
> > Section 9.6.3 of the BRs list the provisions that must be included in the
> Subscriber Agreement that every Applicant must agree to. Notably, one of
> them is protection of the private key. The Subscriber in this case materially
> violated the Subscriber Agreement by disclosing their private key, so I don't
> think they have much footing to go badgering others for problems that they
> brought on themselves.
> >
> > Thanks,
> > Corey
> >
> > [1]
> > https://wiki.mozilla.org/CA/Responding_To_An_Incident#Incident_Report
> >
> 
> The question was if this is appropriate behavior, when the incident is not at
> the CA, but at a subscriber.  This is typically different from the case of 
> security
> researchers filing systemic CA issues for which they typically want public
> recognition.
> 
> Specificially, the question is one of whistleblower protection for the 
> reporter
> (in the general sense of whistleblower protection, not that of any single
> national or other whistleblower protection legal regime).
> 
> On the other hand there is the question of subscribers having a right to face
> their accuser when there might be a question of trust of subjectivity 
> (example:
> Someone with trusted subscriber private key access maliciously sending it to
> the CA to cause revocation for failure to protect said key).
> 
> Situation would get much more complicated when the report is one of
> claiming a subscriber violates a subjective rule, such as malicious cert use 
> or
> name ownership conflicts.
> 
> 
> 
> Enjoy
> 
> Jakob
> --
> Jakob Bohm, CIO, Partner, WiseMo A/S.  https://www.wisemo.com
> Transformervej 29, 2860 Søborg, Denmark.  Direct +45 31 13 16 10 This public
> discussion message is non-binding and may contain errors.
> WiseMo - Remote Service Management for PCs, Phones and Embedded
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Re: CA handling of contact information when reporting problems

2019-08-21 Thread Adrian R via dev-security-policy
On Monday, 19 August 2019 17:26:06 UTC+3, Mathew Hodson  wrote:
[...]
> If these situations were common, it could create a chilling effect on
> problem reporting that would hurt the WebPKI ecosystem. Are specific
> procedures and handling of contact information in these situations
> covered by the BRs or Mozilla policy?

>From my experience if something is already covered by legislation there 
>doesn't need to be a separate procedure for "complying with the law".

Since that researcher is an EU citizen from Netherlands, the GDPR applies for 
his personal contact data and both Sectigo's and that "angry" company's actions 
are (possible) GDPR violations.

Was there explicit consent given to Sectigo to forward his contact details to 
that company? Is that "angry" company even aware of the GDPR?
(GDPR, article 6 and 7)
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Re: CA handling of contact information when reporting problems

2019-08-20 Thread Ryan Sleevi via dev-security-policy
On Mon, Aug 19, 2019 at 10:26 AM Mathew Hodson via dev-security-policy <
dev-security-policy@lists.mozilla.org> wrote:

> If these situations were common, it could create a chilling effect on
> problem reporting that would hurt the WebPKI ecosystem. Are specific
> procedures and handling of contact information in these situations
> covered by the BRs or Mozilla policy?
>

No, there are not.

This is not an uncommon practice within the broader realm of Security
Incident Reporting / Disclosure, and has been the subject of much
discussion and debate for 30+ years of computer security. You can find
plenty of information about lawsuits intended to chill vulnerability
disclosure. This is not a problem that can or will be solved within the BRs
or Mozilla Policy.

In general, anyone disclosing vulnerabilities should expect their
information may be released. That's par for the course here. Different
jurisdictions may have different protections, but reporters are encouraged
to disclose directly with the CA. Root Store Operators may be willing to
intermediate (e.g. disclosing to Mozilla's security reporting), but I'm
also not aware of any strong guarantees Mozilla makes with respect to
protecting the information of folks who report security issues, especially
in the potential incident of (misguided, frivolous) lawsuits.
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Re: CA handling of contact information when reporting problems

2019-08-20 Thread Daniel Marschall via dev-security-policy
Hello,

I am a bit shocked about this case.

The fact that this happened to someone would restrain myself from reporting key 
compromises.

Even though it is the company's fault to protect their private key, their 
lawers still might sue the incident-reporter. A judge might not understand the 
PKI system and therefore might tend to decide in favor of the company, because 
the company can proove that they lost XXX dollars revenue because of the 
service outtage. I think big companies have a lot of expensive lawers who might 
win such a case against a private person who might not even have the money for 
a good lawer at all.

In re privacy: Telling someone the name and/or email address of a person 
without their consent is a clear violation of the GDPR (European General Data 
Protection Regulation), in case European law applies. Publishing the name 
and/or email address online (e.g. in the incident template) is even worse.

Take care,
Daniel

Am Montag, 19. August 2019 16:26:06 UTC+2 schrieb Mathew Hodson:
> Tom Wassenberg on Twitter reported an experience he had with Sectigo
> when reporting a compromised private key.
> 
> https://twitter.com/tomwas54/status/1162114413148725248
> https://twitter.com/tomwas54/status/1162114465065840640
> https://twitter.com/tomwas54/status/1162114495017299976
> 
> "So a few weeks ago, I came across a private key used for a TLS
> certificate, posted online. These should never be public (hence the
> "private"), and every trusted CA is obliged to revoke any certificate
> they issued when they become aware its private key is compromised.
> 
> "So when I informed the issuing CA (@SectigoHQ) about this, they
> promptly revoked the cert. Two weeks later however, I receive an angry
> email from the company using the cert (cc'd to their lawyer), blaming
> me for a disruption in the services they provide.
> 
> "The company explicitly mentioned @SectigoHQ "was so kind" to give
> them my contact info! It was a complete surprise for me that
> @SectigoHQ would do this without my consent. Especially seeing how the
> info was used to badger me."
> 
> If these situations were common, it could create a chilling effect on
> problem reporting that would hurt the WebPKI ecosystem. Are specific
> procedures and handling of contact information in these situations
> covered by the BRs or Mozilla policy?

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Re: CA handling of contact information when reporting problems

2019-08-19 Thread Jakob Bohm via dev-security-policy

On 20/08/2019 03:15, Corey Bonnell wrote:

On Monday, August 19, 2019 at 10:26:06 AM UTC-4, Mathew Hodson wrote:

Tom Wassenberg on Twitter reported an experience he had with Sectigo
when reporting a compromised private key.

https://twitter.com/tomwas54/status/1162114413148725248
https://twitter.com/tomwas54/status/1162114465065840640
https://twitter.com/tomwas54/status/1162114495017299976

"So a few weeks ago, I came across a private key used for a TLS
certificate, posted online. These should never be public (hence the
"private"), and every trusted CA is obliged to revoke any certificate
they issued when they become aware its private key is compromised.

"So when I informed the issuing CA (@SectigoHQ) about this, they
promptly revoked the cert. Two weeks later however, I receive an angry
email from the company using the cert (cc'd to their lawyer), blaming
me for a disruption in the services they provide.

"The company explicitly mentioned @SectigoHQ "was so kind" to give
them my contact info! It was a complete surprise for me that
@SectigoHQ would do this without my consent. Especially seeing how the
info was used to badger me."

If these situations were common, it could create a chilling effect on
problem reporting that would hurt the WebPKI ecosystem. Are specific
procedures and handling of contact information in these situations
covered by the BRs or Mozilla policy?


Many CAs disclose the reporter's name and email address as part of their 
response to item 1 of the incident report template [1]. So this information is 
already publicly available if the Subscriber were so inclined to look for it.

Section 9.6.3 of the BRs list the provisions that must be included in the 
Subscriber Agreement that every Applicant must agree to. Notably, one of them 
is protection of the private key. The Subscriber in this case materially 
violated the Subscriber Agreement by disclosing their private key, so I don't 
think they have much footing to go badgering others for problems that they 
brought on themselves.

Thanks,
Corey

[1] https://wiki.mozilla.org/CA/Responding_To_An_Incident#Incident_Report



The question was if this is appropriate behavior, when the incident is
not at the CA, but at a subscriber.  This is typically different from
the case of security researchers filing systemic CA issues for which
they typically want public recognition.

Specificially, the question is one of whistleblower protection for the
reporter (in the general sense of whistleblower protection, not that of
any single national or other whistleblower protection legal regime).

On the other hand there is the question of subscribers having a right
to face their accuser when there might be a question of trust of
subjectivity (example: Someone with trusted subscriber private key
access maliciously sending it to the CA to cause revocation for failure
to protect said key).

Situation would get much more complicated when the report is one of
claiming a subscriber violates a subjective rule, such as malicious cert
use or name ownership conflicts.



Enjoy

Jakob
--
Jakob Bohm, CIO, Partner, WiseMo A/S.  https://www.wisemo.com
Transformervej 29, 2860 Søborg, Denmark.  Direct +45 31 13 16 10
This public discussion message is non-binding and may contain errors.
WiseMo - Remote Service Management for PCs, Phones and Embedded
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