[Cscwg-public] [EXTERNAL] Re: Discussion: Proposed Ballot CSC-6: Update to Subscriber Private Key Protection Requirements

Corey Bonnell Corey.Bonnell at digicert.com
Thu Dec 9 13:42:17 UTC 2021

Hi Ian,

Thank for you for circulating the latest copy of the draft ballot. Comments


1.	As a general comment, it would be more consistent to use the Defined
Terms of "Private Key" and "Key Pair" throughout.


2.	"Acceptable methods of satisfying this requirement include the
following" is unclear whether the list is exhaustive or is merely a list of
illustrative examples. I believe the intent is that the list of methods is
exhaustive, so I suggest changing this to "One of the following methods MUST
be employed to satisfy this requirement:"


3.	"6.          The CA or a Qualified Auditor witnesses the key
creation in a suitable Hardware Crypto Module solution including a
cloud-based key generation and protection solution;" 


"Qualified Auditor" is a Defined Term that denotes an auditor with specific
experience and ability to carry out WebTrust/ETSI audits. Do we need this
level of specificity, especially when Section 11.7 prescribes "relying on a
report provided by the Applicant that is signed by an auditor who is
approved by the CA and who has IT and security training or is a CISA"? If we
do not, perhaps it would be best to align on the language in Section 16.3.2
(6) with the auditor qualification requirement in Section 11.7.






From: Cscwg-public <cscwg-public-bounces at cabforum.org> On Behalf Of Ian
McMillan via Cscwg-public
Sent: Tuesday, December 7, 2021 5:24 PM
To: Adriano Santoni <adriano.santoni at staff.aruba.it>;
cscwg-public at cabforum.org; Dimitris Zacharopoulos (HARICA)
<dzacharo at harica.gr>; Bruce Morton <bruce.morton at entrust.com>
Subject: Re: [Cscwg-public] [EXTERNAL] Re: Discussion: Proposed Ballot
CSC-6: Update to Subscriber Private Key Protection Requirements


Hi Folks,


Coming out of our last call, I've made all the updates we discussed
including producing a definition for the term "hardware crypto module" (see


Hardware Crypto Module: A tamper-resistant device with a dedicated
cryptography processor used for the specific purpose of protecting the
lifecycle of cryptographic keys (generating, managing, processing, and


Please see the attached redline now with all the latest updates and provide
feedback and willingness to endorse the ballot. 





From: Cscwg-public <cscwg-public-bounces at cabforum.org
<mailto:cscwg-public-bounces at cabforum.org> > On Behalf Of Adriano Santoni
via Cscwg-public
Sent: Tuesday, November 23, 2021 8:34 AM
To: cscwg-public at cabforum.org <mailto:cscwg-public at cabforum.org> 
Subject: Re: [Cscwg-public] [EXTERNAL] Re: Discussion: Proposed Ballot
CSC-6: Update to Subscriber Private Key Protection Requirements


Hi all,

I find the language in "Baseline Requirements for the Issuance and
Management of Code Signing.v2.6+CSC-6_redline_v2" rather confusing, about
private key protection.

It seems to me that section 16.3.1, in the added parts, only allows three
options for protecting the private key effective Sep 1, 2022: 

1) hosted hardware crypto module (in short "HCM")
2) cloud-based key generation and protection solution (backed by an HCM)  (I
am not clear what's the difference with #1)
3) signing service

But later on, section 16.3.2 seems to allow a wider range of options,
including a suitable HCM shipped to the subscriber by the CA.

Am I reading wrong? 

Also, I am not clear how option #3 in §16.3.2 works: 

"3.    The Subscriber uses a CA prescribed CSP and a suitable hardware
module combination for the key pair generation and storage;"

Anybody willing to explain?


Il 23/11/2021 11:07, Dimitris Zacharopoulos (HARICA) via Cscwg-public ha


On 18/11/2021 7:03 μ.μ., Dimitris Zacharopoulos (HARICA) via Cscwg-public

Ok, so you are thinking of a Subscriber that owns an HSM and gets an IT
audit that has an audit report that asserts that all Keys associated with
Code Signing Certificates are generated in an on-prem certified HSM. Is this
what this method is supposed to cover?

After our recent meeting, we agreed to tweak the language of 4. to cover
this use case described by Bruce. I recommend changing

"4.    The Subscriber provides a suitable IT audit indicating that its
operating environment achieves a level of security specified in section


"4.    The Subscriber provides an internal or external IT audit indicating
that it is only using a suitable hardware module as specified in section
16.3.1 to generate keys pairs to be associated with Code Signing

I also noticed that we don't have consistency among all listed options. Some
options just say " suitable hardware module", others point to 16.3.1 and
others say both. We could discuss at our next call or someone could take a
stab at it and try to use consistent language.


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