[Cscwg-public] [EXTERNAL] Re: Signing Service Discussion of 10 March 2022

[Bruce Morton]

Hi Dimitris,

I see the value in creating greater improvements to signing, but as you stated, I would prefer to make smaller improvements. I believe that the first phase is to update the CSBRs based on the model changes which we have discussed. I don’t think there would be a lot of effort to get this done. I would be happy to draft proposed changes after we have changed the CSBR format.

I was reviewing TS 119 431-1, but also need to see EN 419 241-1. I can’t find this document in my ETSI search. I am hoping that we will find ETSI requirements which we might be able to use in the CSBRs, if we find a gap.


Thanks, Bruce.

From: Cscwg-public <cscwg-public-bounces at cabforum.org> On Behalf Of Dimitris Zacharopoulos (HARICA) via Cscwg-public
Sent: Friday, March 11, 2022 7:40 AM
To: Bruce Morton via Cscwg-public <cscwg-public at cabforum.org>
Subject: [EXTERNAL] Re: [Cscwg-public] Signing Service Discussion of 10 March 2022

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Following-up on the discussion about signing services, and the decisions of previous meetings that a signing service is basically an entity that manages private keys on behalf of Subscribers, please take a look at the latest relevant ETSI TS available at:

  *   https://www.etsi.org/deliver/etsi_ts/119400_119499/11943101/01.02.01_60/ts_11943101v010201p.pdf<https://urldefense.com/v3/__https:/www.etsi.org/deliver/etsi_ts/119400_119499/11943101/01.02.01_60/ts_11943101v010201p.pdf__;!!FJ-Y8qCqXTj2!Ijvhfy-9g01wuZ723tQAyBgBJgGeKkaTuxMc5JXiF3j2ydaMont9Piw0M6hmZP9Hk00$>

The responsibility to manage keys on behalf of subscribers is not to be taken lightly as the current CSBRs do. Agreed that we can take some small improvements to the current CSBRs but if we believe that the goal is to define a secure environment with secure policies/practices that will make the ecosystem safer for subscribers and ultimately Relying Parties, then we probably need to invest more time if we want to copy good practices from other schemes.

On the other hand, this ETSI standard is already auditable and a legal entity could be audited and certified against ETSI TS 119 431. If a CA or a Subscriber wants to use a signing service, that signing service could either comply with the CSBRs and be audited against the requirements of section 17.1, or be audited against ETSI TS 119 431.

Thoughts?

Dimitris.

On 10/3/2022 10:00 μ.μ., Bruce Morton via Cscwg-public wrote:
Here is the text we were discussing in the CSCWG meeting today.

Thanks, Bruce.

=================================

Proposed Signing Service items:

  1.  Signing Service is may be performed by the CA or a third party
  2.  Signing Service is not a CA requirement, so is NOT a function of a Delegated Third Party – this will limit scope
  3.  Signing Service references may be removed when not required - this will limit implied scope
  4.  Signing Service is not a Subscriber, so all Private Keys are only associated to certificate Subscriber
  5.  Signing Service is not an RA, so will not receive certificate requests from an Applicant – CA or Delegated Third Party RA will receive certificate requests
  6.  Signing Request requirements will not be defined in the CSBRs


Private key generation

  1.  Signing Service must provide evidence to the CA that the private key was created by the Signing Service.
  2.  Question - Ballot CSC-13 allows the Signing Service to use cloud-based key generation. Can the CA can operate the cloud-based service?

Audit

  1.  Specific compliance sections of CSBRs and NetSec should be stated in the CSBRs as the compliance/audit scope should not be determined by the CA, Signing Service and Auditor. Note, WebTrust for CA or ETSI EN 319 411-1 would not be in scope for Signing Service.
  2.  For cloud-based key generation, is there a compliance requirement for the cloud-based service?

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