[Cscwg-public] Potential problem (procedural) with Ballot CSC-13: Update to Subscriber Private Key Protection Requirements

Dimitris Zacharopoulos (HARICA) dzacharo at harica.gr
Mon Apr 4 19:04:42 UTC 2022


It was noted to me that the procedure of this ballot may have some issues.

In the "Motion" section of the ballot, there is no reference to the 
*actual language changes* of the Guideline as noted in the attached 
redline when the voting started. Instead, the motion section contains 
"descriptions" of the changes.

I'm afraid this is inconsistent with section 2.4 of the Bylaws 
<https://github.com/cabforum/forum/blob/main/Bylaws.md#24-requirements-for-draft-guideline-ballots>. 
More specifically, the ballot should contain either the "Ballot Version" 
type of changes or a redline within the motion section. If they both 
appear, the "Ballot Version" takes precedence. This ballot was submitted 
with the redline outside the motion.

I understand that it's disappointing that this is identified so late in 
the process. Perhaps I'm wrong with this interpretation but I'd like 
other Members to also review and share their opinion.


Best regards,
Dimitris.

PS: We should also avoid including links of websites that are not 
publicly accessible when posting on the public list.


On 30/3/2022 8:01 μ.μ., Ian McMillan via Cscwg-public wrote:
>
> Ballot CSC-13: Update to Subscriber Private Key Protection 
> Requirements 
> <https://nam06.safelinks.protection.outlook.com/?url=https%3A%2F%2Fwiki.cabforum.org%2Fcscwg%2Fcsc_13_-_update_to_subscriber_private_key_protection_requirements&data=04%7C01%7Cianmcm%40microsoft.com%7C31d96159f5ed42ea367808da0ceebaa5%7C72f988bf86f141af91ab2d7cd011db47%7C0%7C0%7C637836517169400423%7CUnknown%7CTWFpbGZsb3d8eyJWIjoiMC4wLjAwMDAiLCJQIjoiV2luMzIiLCJBTiI6Ik1haWwiLCJXVCI6Mn0%3D%7C1000&sdata=W9JW6jbaoIP9q5eo5kI9KtC%2FbyLkrPw4%2BknyEac9Fa8%3D&reserved=0>
>
> Purpose of this ballot: Update the subscriber private key protection 
> requirements in the Baseline Requirement for the Issuance and 
> Management of Publicly-Trusted Code Signing Certificates v2.7. The 
> following motion has been proposed by Ian McMillan of Microsoft and 
> endorsed by Tim Hollebeek of DigiCert and Bruce Morton of Entrust.
>
> — MOTION BEGINS —
>
> This ballot updates the “Baseline Requirements for the Issuance and 
> Management of Publicly‐Trusted Code Signing Certificates“ version 2.7 
> according to the attached redline which includes:
>
>   * Update section 16.3 “Subscriber Private Key Protection” to
>     “Subscriber Private Key Protection and Verification”
>   * Update section 16.3 “Subscriber Private Key Protection” to include
>     sub-sections “16.3.1 Subscriber Private Key Protection” and
>     “16.3.2 Subscriber Private Key Verification”
>   * Update section 16.3 under new sub-section 16.3.1 to remove
>     allowance of TPM key generation and software protected private key
>     protection, and remove private key protection requirement
>     differences between EV and non-EV Code Signing Certificates
>   * Update section 16.3 under new sub-section 16.3.1 to include the
>     allowance of key generation and protection using a cloud-based key
>     protection solution providing key generation and protection in a
>     hardware crypto module that conforms to at least FIPS 140-2 Level
>     2 or Common Criteria EAL 4+
>   * Update section 16.3 under new sub-section 16.3.2 to include
>     verification for Code Signing Certificates' private key generation
>     and storage in a crypto module that meets or exceeds the
>     requirements of FIPS 140-2 level 2 or Common Criteria EAL 4+ by
>     the CAs. Include additional acceptable methods for verification
>     including cloud-based key generation and protection solutions and
>     a stipulation for CAs to satisfy this verification requirement
>     with additional means specified in their CPS. Any additional means
>     specified by a CA in their CPS, must be proposed to the CA/Browser
>     Forum for inclusion into the acceptable methods for section 16.3.2
>     by November 15, 2022.
>
> — MOTION ENDS —
>
> The procedure for approval of this ballot is as follows:
>
> Discussion (7 days)
>
> Start Time: 2022-03-23, 13:00 Eastern Time (US)
>
> End Time: 2022-03-30, 13:00 Eastern Time (US)
>
> Vote for approval (7 days)
>
> Start Time: 2022-03-30, 13:00 Eastern Time (US)
>
> End Time: 2022-04-06, 13:00 Eastern Time (US)
>
>
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> Cscwg-public at cabforum.org
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