On 3 November 2016 at 19:33, Jeremy Rowley <[email protected]> wrote:
> Depends on your interpretation of Article 12 of Directive 95/46/EC, the ECHR,
> and the potential impact of Article 17 of the new GDRP, although I suppose the
> data is still considered necessary in relation to purposes for which it was
> discussed and there are legitimate grounds for the processing. Given that
> names and email addresses will be discussed if subject information is included
> (especially if we'd like CT to eventually apply to s/MIME certs),

Redaction is not the correct solution for S/MIME certs. As I already
said, something CONIKS-like would be more appropriate (i.e. something
that hides the email in a verifiable way). I imagine there are other
possibilities.

> I'd like a
> way to redact the info as it's questionable whether "forever" on a CT long
> complies with the requirement to keep the data no longer than necessary.
>
> -----Original Message-----
> From: Stephen Farrell [mailto:[email protected]]
> Sent: Thursday, November 3, 2016 1:13 PM
> To: Jeremy Rowley <[email protected]>; Ben Laurie <[email protected]>;
> Peter Bowen <[email protected]>
> Cc: Melinda Shore <[email protected]>; [email protected]
> Subject: Re: [Trans] Topicality
>
>
>
> On 03/11/16 17:42, Jeremy Rowley wrote:
>> Unlike the certificate, which can be deleted, revoked, or in some other way
>> removed from the CA's database and the server, a certificate cannot be
>> removed from a CT log, meaning it's impossible to delete PII in compliance
>> with the EU directive.
>
> Again - there is no "EU directive" that calls for deletion of
> this PII, that's just speculation.
>
> S.
>
>>
>> -----Original Message-----
>> From: Trans [mailto:[email protected]] On Behalf Of Ben Laurie
>> Sent: Thursday, November 3, 2016 11:31 AM
>> To: Peter Bowen <[email protected]>
>> Cc: Melinda Shore <[email protected]>; [email protected]; Stephen Farrell
>> <[email protected]>
>> Subject: Re: [Trans] Topicality
>>
>> On 3 November 2016 at 16:36, Peter Bowen <[email protected]> wrote:
>>> On Thu, Nov 3, 2016 at 8:45 AM, Ben Laurie <[email protected]> wrote:
>>>> On 1 November 2016 at 01:04, Peter Bowen <[email protected]> wrote:
>>>>>
>>>>> There are certificates that have personal information (e.g. given
>>>>> name, surname, and physical location) in the subject distinguished
>>>>> name or the subject alternative names.  It is very possible that
>>>>> there may be a desire to redact this information (in fact it could
>>>>> even be required in some jurisdictions as CT could be considered a
>> database).
>>>>> We already see this with domains in many countries where the full
>>>>> registrant details are not publicly available.
>>>>>
>>>>> Additionally, while 6962-bis does focus on certificates used for TLS
>>>>> server authentication, there are other types of certificates that
>>>>> could be logged.  For example a certificate that is used with email
>>>>> and contains both the email address and given/surname.  It might be
>>>>> that the owner of the certificate only wishes to disclose this
>>>>> binding to people receiving email from them rather than publicly
>>>>> disclosing it.  We have also seen requests for certificates that
>>>>> cover phone numbers.  A similar situation would apply -- having an
>> "unlisted"
>>>>> number should be possible, where the subject details (other than
>>>>> phone
>>>>> number) are only known to a group of people who communicate with the
>>>>> number.
>>>>
>>>> For these use cases, something CONIKS-like is probably more appropriate.
>>>
>>> How does CONIKS doesn't solve the problem of server authentication
>>> certificates that identify an individual as the certificate
>>> subscriber?
>>
>> Sorry, I was referring to the latter cases - e.g. S/MIME (which is what you
>> seem to be describing).
>>
>>>  Even if we assume for the moment that 6962bis is only for
>>> "traditional" PKI  and only for server authentication, these certs are
>>> still problematic to log unredacted.
>>
>> Since the personal info in those cases is not relevant to browsers
>> validation of the cert, in principle I can't see why we would care if it
>> were redacted. OTOH, the certificate is public anyway, so not sure why
>> redacting it in the log is useful.
>>
>> The real problem is the certificate, not the log entry!
>>
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>

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