[Cscwg-public] Update to Subscriber Private Key Protection Requirements (CSC-6 to CSC-13)

Tue Mar 8 21:05:58 UTC 2022

Thanks Bruce for clarifying the 16.2 change for Doug.

Doug, the 11.7 section needs a larger overhaul that we have in our parking lot list and we had decided that any further updates to 11.7 would be included in the larger overhaul. That said, I see you point on there are multiple 16.3.1(1) and 16.3.1(2), etc., so I've updated the section numbering to continue, and we now have section 16.3.1(1-9). Please see the attached updated redline document.

Thanks,
Ian

From: Bruce Morton <Bruce.Morton at entrust.com>
Sent: Thursday, March 3, 2022 9:08 AM
To: Doug Beattie <doug.beattie at globalsign.com>; Ian McMillan <ianmcm at microsoft.com>; Tim Hollebeek <tim.hollebeek at digicert.com>; cscwg-public at cabforum.org
Subject: [EXTERNAL] RE: Update to Subscriber Private Key Protection Requirements (CSC-6 to CSC-13)

Doug,

Regarding the 16.2 section, this statement was also struck-out, "After 2021-06-01, the same protection requirements SHALL apply to Non EV Code Signing Certificates." So I believe that the requirement already applied to normal code signing certificates. The edits are just a cleanup.

Bruce.

From: Doug Beattie <doug.beattie at globalsign.com<mailto:doug.beattie at globalsign.com>>
Sent: Thursday, March 3, 2022 6:56 AM
To: Ian McMillan <ianmcm at microsoft.com<mailto:ianmcm at microsoft.com>>; Tim Hollebeek <tim.hollebeek at digicert.com<mailto:tim.hollebeek at digicert.com>>; cscwg-public at cabforum.org<mailto:cscwg-public at cabforum.org>; Bruce Morton <Bruce.Morton at entrust.com<mailto:Bruce.Morton at entrust.com>>
Subject: [EXTERNAL] RE: Update to Subscriber Private Key Protection Requirements (CSC-6 to CSC-13)

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Hi Ian,

Good work on section 16.3, that is much more clear now.  I have 2 more comments for your consideration.

Comment #1:

In Section 11.7 we say:
If the CA is aware that the Applicant was the victim of a Takeover Attack, the CA MUST verify that the Applicant is protecting its Code Signing Private Keys under Section 16.3.1(1) or Section 16.3.1(2). The CA MUST verify the Applicant's compliance with Section 16.3.1(1) or Section 16.3.1(2) (i) through technical means that confirm the Private Keys are protected using the method described in 16.3.1(1) or 16.3.1(2) or (ii) by 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.

But now there are actually 2 lists in sections 16.3.1(1) or Section 16.3.1(2) with those list numbers.  Do we need to be more specific, or renumber the second list a-c?

After 15 November, what is the right remediation for Take Over attack, do we need to reference one or more of the items in the new list (the list we might renumber a-c), or is there no remediation now?

There are multiple references to 16.3.1(1) so we'd want to apply the same logic to all instances.

Comment #2:
Section 16.2 removed the reference to EV in the scope so this applies to normal Code signing certificates.  Since this does not have a date associated with it, do we assume that this requirement change for normal code signing certs is effective immediately?

From: Ian McMillan <ianmcm at microsoft.com<mailto:ianmcm at microsoft.com>>
Sent: Wednesday, March 2, 2022 5:56 PM
To: Tim Hollebeek <tim.hollebeek at digicert.com<mailto:tim.hollebeek at digicert.com>>; cscwg-public at cabforum.org<mailto:cscwg-public at cabforum.org>; Doug Beattie <doug.beattie at globalsign.com<mailto:doug.beattie at globalsign.com>>; Bruce Morton <bruce.morton at entrust.com<mailto:bruce.morton at entrust.com>>
Subject: RE: Update to Subscriber Private Key Protection Requirements (CSC-6 to CSC-13)

Thank you, Tim, I really like the structure suggestions here. I've made those updates per your suggestion in the attached copy of the redline document.

I'll note your endorsement.

Cheers,
Ian

From: Tim Hollebeek <tim.hollebeek at digicert.com<mailto:tim.hollebeek at digicert.com>>
Sent: Wednesday, March 2, 2022 4:57 PM
To: Ian McMillan <ianmcm at microsoft.com<mailto:ianmcm at microsoft.com>>; cscwg-public at cabforum.org<mailto:cscwg-public at cabforum.org>; Doug Beattie <doug.beattie at globalsign.com<mailto:doug.beattie at globalsign.com>>; Bruce Morton <bruce.morton at entrust.com<mailto:bruce.morton at entrust.com>>
Subject: [EXTERNAL] RE: Update to Subscriber Private Key Protection Requirements (CSC-6 to CSC-13)

I would recommend against using parentheticals to express the deprecation dates, as it makes the sentences more complicated than they need to be.  I'd just modify the first sentence of each part so the structure is as follows:

   For Non-EV Code Signing Certificates issued prior to November 15, 2022, ...

   For EV Code Signing Certificates issued prior to November 15, 2022, ...

   Effective November 15, 2022, ...

But otherwise, the updates look good and we are willing to endorse CSC-13.

-Tim

From: Ian McMillan <ianmcm at microsoft.com<mailto:ianmcm at microsoft.com>>
Sent: Wednesday, March 2, 2022 11:31 AM
To: cscwg-public at cabforum.org<mailto:cscwg-public at cabforum.org>; Doug Beattie <doug.beattie at globalsign.com<mailto:doug.beattie at globalsign.com>>; Bruce Morton <bruce.morton at entrust.com<mailto:bruce.morton at entrust.com>>; Tim Hollebeek <tim.hollebeek at digicert.com<mailto:tim.hollebeek at digicert.com>>
Subject: Update to Subscriber Private Key Protection Requirements (CSC-6 to CSC-13)

Hi Folks,

Attached you will find an updated redline doc of v2.7 of the CSBRs with the updates to the subscriber private key protection requirements as outlined previously in CSC-6. This updated version also includes edits to address issues Doug Beattie raised during the voting period of CSC-6, so I am looking for confirmation from Doug on these edits addressing the concerns he raised.

Additionally, I'm looking to get endorsements on this ballot under 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%7Cd4f1031bc20548d5353008d9fc978390%7C72f988bf86f141af91ab2d7cd011db47%7C0%7C0%7C637818549960291581%7CUnknown%7CTWFpbGZsb3d8eyJWIjoiMC4wLjAwMDAiLCJQIjoiV2luMzIiLCJBTiI6Ik1haWwiLCJXVCI6Mn0%3D%7C3000&sdata=K2KcmHbxwQ0sUNuNRmUs709PD16hYnqvPbLB%2BGzExng%3D&reserved=0>, and hope that Bruce and Tim, as previous endorsers can review the edits and endorse the new ballot. Once we have endorsers I'll proceed with the formal ballot process.

Cheers,
Ian
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