<div dir="ltr"><div dir="ltr"><br></div><br><div class="gmail_quote"><div dir="ltr" class="gmail_attr">On Wed, Jan 30, 2019 at 2:21 AM Dimitris Zacharopoulos (HARICA) <<a href="mailto:dzacharo@harica.gr">dzacharo@harica.gr</a>> wrote:</div><blockquote class="gmail_quote" style="margin:0px 0px 0px 0.8ex;border-left:1px solid rgb(204,204,204);padding-left:1ex"><div bgcolor="#FFFFFF">I disagree that for S/MIME there is no set of existing rules. ETSI
EN 319 411-1 (scope LCP, NCP) and AFAIK WebTrust for CAs have been
used as attestations of adequate level of organizational/technical
controls for S/MIME, clientAuthentication and Code Signing
Certificates.<br></div></blockquote><div><br></div><div>They are not tailored towards S/MIME, while there exist a number of schemes that are, which you seem to wish to exclude from consideration or participation. I disagree that it's been seen as an "adequate" level - otherwise, we wouldn't have been talking about the need for guidelines for both S/MIME and codeSigning for a number of years.</div><div> </div><blockquote class="gmail_quote" style="margin:0px 0px 0px 0.8ex;border-left:1px solid rgb(204,204,204);padding-left:1ex"><div bgcolor="#FFFFFF">
The main reason I prefer using an international scheme is because it
is more carefully drafted, usually by experts in that area, and have
a good and internationally acceptable quality assurance. The
auditors themselves are assessed by peer reviews (WebTrust) or by
NABs (ETSI). Local laws and National regulations may not have
similar quality level but lower. </div></blockquote><div><br></div><div>Or, as it happens, they may be higher.</div><div> </div><blockquote class="gmail_quote" style="margin:0px 0px 0px 0.8ex;border-left:1px solid rgb(204,204,204);padding-left:1ex"><div bgcolor="#FFFFFF">Auditors are usually a government
agency. </div></blockquote><div><br></div><div>A regulated entity, as opposed to self-regulation with demonstrable lack of oversight. I would point to the sizable number of issues with ETSI audits, both in reporting and performance, that might suggest otherwise.</div><div> </div><blockquote class="gmail_quote" style="margin:0px 0px 0px 0.8ex;border-left:1px solid rgb(204,204,204);padding-left:1ex"><div bgcolor="#FFFFFF">I consider the level of audit schemes in the Baseline
Requirements to be a good set of standards to start with because it
sets the bar pretty high from the very beginning.</div></blockquote><div><br></div><div>You're ignoring, however, that these schemes are recognized as such for SSL/TLS. I see no reason to support the conclusion that they're good schemes for these other cases, and ample evidence (both from the SSL/TLS discussions and the need to form these WGs) that they are substantially lacking.</div><div><br></div><div>However, in all of this response, you haven't really articulated why a CA that lacks a WebTrust or ETSI audit should be able to participate and/or vote in the Forum. You've articulated that you think these schemes are great starting grounds, and while there's ample evidence to disagree with that, it doesn't actually help describe why it should be a Forum-level requirement as opposed to a servercert-wg requirement.</div><div><br></div><div>I'm fundamentally uncomfortable with CAs "on the inside" attempting to keep other CAs out, and it seems like a definition that recognizes that CA trust is fundamentally imparted by the Certificate Consumers seems... useful. If a WG goes off the rails because, say, a certificate consumer decided to let everyone under the sun in - or if it gets stacked with certificate consumers with interests not aligned with major platforms - then the natural consequence is that that WG and its work product will be ignored and not required by Certificate Consumers.</div><div><br></div><div>The goal of a WG - S/MIME or Code Signing - is not to produce something that CAs like or even agree with. It's to produce a set of criteria that reflect the participating Certificate Consumers needs, so that they can then require it for participation in their Root Programs. If the requirements do not meet their needs, such Consumers can choose not to require them. Similarly, such Consumers can impose their own requirements above and beyond. In both situations, it seems extremely valuable to support as diverse and varied as possible a set of participants, to provide feedback for Certificate Consumers in developing and imposing requirements for their programs. I don't see how the possession of a WebTrust for CAs audit, over, say, participation in the US Federal PKI, fundamentally improves the quality of discourse or feedback. This is especially true if the consequence of developing and imposing such standards may result in presently-accepted Certificate Consumers from being excluded from participation in the future - that's all the more reason to want to ensure their views and voices are consistently and equally represented.</div></div></div>