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

Wed Mar 9 12:26:38 UTC 2022

I believe this language and double confirmation comes from years ago 
when tools like remote key attestation were not available.

If we are to allow an Applicant to generate keys remotely (i.e. without 
the presence of a CA representative and without hardware that supports 
remote key attestation), which seems to be the case with the CSCWG 
today, we need to rely on policy to accomplish that. It is reasonable to 
hold both sides, the Applicant and the CA, accountable to this policy. 
See below.

On 9/3/2022 11:43 π.μ., Adriano Santoni via Cscwg-public wrote:
>
> As far as I'm concerned, I find confusing and overly complex the 
> double requirement:
>
> 1) customer must make a "representation" that they will use a hardware 
> crypto module (or signing service), and ...
>

This is required because a customer could potentially "fake" the 
hardware device id and create a virtual driver that emulates the actual 
hardware device. The Applicant must be held accountable if they try to 
manipulate the process or make any changes to the process and tools 
provided by the CA.

> 2) the CA must ensure that the customer will really use a hardware 
> crypto module (or signing service).
>

The CA must establish a process and develop the proper tools to provide 
reasonable assurance that the Applicant remotely generates keys in a 
hardware crypto module which is usually within a limited set of devices 
approved by the CA. The CA is not allowed to say "please send me a CSR 
and pinky swear that it was generated in a crypto device". They must 
develop tools and middleware and establish a process to make sure the 
key is generated in approved crypto-devices only.

> If the CA will be obliged to meet req #2, then I do not see what use 
> is req #1.
>

Hope this explanation helps.
Dimitris.

> Adriano
>
> -- Actalis
>
>
> Il 09/03/2022 10:21, Inigo Barreira via Cscwg-public ha scritto:
>>
>> Yes, please.
>>
>> It looks like this representation means something like “click here if 
>> you are over 18” or “click here if you agree” because these are also 
>> facts not opinions.
>>
>> IMO the message here is that CAs will rely in whatever the subscriber 
>> says, e.g.,  “yes, I´m a good guy and promise that I will keep my 
>> keys in a hardware device …” rather on making the corresponding tasks 
>> to ensure. Is this the right approach? This is what I understand from 
>> Dean´s response because CAs are not attesting anything just relying 
>> in a form signed by the subscriber in where it may say whatever.
>>
>> Regards
>>
>> *De:* Tim Hollebeek <tim.hollebeek at digicert.com>
>> *Enviado el:* martes, 8 de marzo de 2022 20:35
>> *Para:* Dean Coclin <dean.coclin at digicert.com>; Inigo Barreira 
>> <Inigo.Barreira at sectigo.com>; cscwg-public at cabforum.org; Bruce Morton 
>> <bruce.morton at entrust.com>; Doug Beattie 
>> <doug.beattie at globalsign.com>; Ian McMillan <ianmcm at microsoft.com>
>> *Asunto:* RE: Update to Subscriber Private Key Protection 
>> Requirements (CSC-6 to CSC-13)
>>
>> “representation” is being used here in the legal sense: “a 
>> statement of fact. A representation should be distinguished from a 
>> statement of opinion for many legal purposes, especially in 
>> relation to contractual obligations.”
>>
>> We should perhaps be using plain English instead of legalese.
>>
>> -Tim
>>
>> *From:*Dean Coclin <dean.coclin at digicert.com>
>> *Sent:* Tuesday, March 8, 2022 1:00 PM
>> *To:* Inigo Barreira <Inigo.Barreira at sectigo.com>; 
>> cscwg-public at cabforum.org; Bruce Morton <bruce.morton at entrust.com>; 
>> Doug Beattie <doug.beattie at globalsign.com>; Ian McMillan 
>> <ianmcm at microsoft.com>; Tim Hollebeek <tim.hollebeek at digicert.com>
>> *Subject:* RE: Update to Subscriber Private Key Protection 
>> Requirements (CSC-6 to CSC-13)
>>
>> This means exactly what it says, some representation that the 
>> subscriber makes to honor the condition. This traditionally has been 
>> something in writing that the subscriber signs and submits to the CA. 
>> CAs can provide a form to the subscriber which they attest to.
>>
>> *From:*Cscwg-public <cscwg-public-bounces at cabforum.org> *On Behalf Of 
>> *Inigo Barreira via Cscwg-public
>> *Sent:* Tuesday, March 8, 2022 11:03 AM
>> *To:* Bruce Morton <bruce.morton at entrust.com>; 
>> cscwg-public at cabforum.org; Doug Beattie 
>> <doug.beattie at globalsign.com>; Ian McMillan <ianmcm at microsoft.com>; 
>> Tim Hollebeek <tim.hollebeek at digicert.com>
>> *Subject:* Re: [Cscwg-public] Update to Subscriber Private Key 
>> Protection Requirements (CSC-6 to CSC-13)
>>
>> Hi all,
>>
>> Reviewing the section 16.3.1 I have a “wording” question. What does 
>> it mean that “The CA MUST obtain a representation from the Subscriber 
>> that the Subscriber will use one of the following options …”. So, 
>> what is a “representation from the subscriber”?
>>
>> Regards
>>
>> *De:* Cscwg-public <cscwg-public-bounces at cabforum.org> *En nombre de 
>> *Bruce Morton via Cscwg-public
>> *Enviado el:* jueves, 3 de marzo de 2022 15:08
>> *Para:* 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
>> *Asunto:* Re: [Cscwg-public] Update to Subscriber Private Key 
>> Protection Requirements (CSC-6 to CSC-13)
>>
>> CAUTION: This email originated from outside of the organization. Do 
>> not click links or open attachments unless you recognize the sender 
>> and know the content is safe.
>>
>> 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>
>> *Sent:* Thursday, March 3, 2022 6:56 AM
>> *To:* Ian McMillan <ianmcm at microsoft.com>; Tim Hollebeek 
>> <tim.hollebeek at digicert.com>; cscwg-public at cabforum.org; Bruce Morton 
>> <Bruce.Morton at entrust.com>
>> *Subject:* [EXTERNAL] RE: Update to Subscriber Private Key Protection 
>> Requirements (CSC-6 to CSC-13)
>>
>> WARNING: This email originated outside of Entrust.
>> DO NOT CLICK links or attachments unless you trust the sender and 
>> know the content is safe.
>>
>> ------------------------------------------------------------------------
>>
>> 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>
>> *Sent:* Wednesday, March 2, 2022 5:56 PM
>> *To:* Tim Hollebeek <tim.hollebeek at digicert.com>; 
>> cscwg-public at cabforum.org; Doug Beattie 
>> <doug.beattie at globalsign.com>; Bruce Morton <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>
>> *Sent:* Wednesday, March 2, 2022 4:57 PM
>> *To:* Ian McMillan <ianmcm at microsoft.com>; cscwg-public at cabforum.org; 
>> Doug Beattie <doug.beattie at globalsign.com>; Bruce Morton 
>> <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>
>> *Sent:* Wednesday, March 2, 2022 11:31 AM
>> *To:* cscwg-public at cabforum.org; Doug Beattie 
>> <doug.beattie at globalsign.com>; Bruce Morton 
>> <bruce.morton at entrust.com>; Tim Hollebeek <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://nam04.safelinks.protection.outlook.com/?url=https%3A%2F%2Fwiki.cabforum.org%2Fcscwg%2Fcsc_13_-_update_to_subscriber_private_key_protection_requirements&data=04%7C01%7Cinigo.barreira%40sectigo.com%7C8c395e17677b473299fe08d9fd1f31e3%7C0e9c48946caa465d96604b6968b49fb7%7C0%7C0%7C637819132704229104%7CUnknown%7CTWFpbGZsb3d8eyJWIjoiMC4wLjAwMDAiLCJQIjoiV2luMzIiLCJBTiI6Ik1haWwiLCJXVCI6Mn0%3D%7C3000&sdata=vVY6kf6AeMZd%2FrkLBqxgdyGhAQRLqyqUXVG2B5vGejM%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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