[cabf_netsec] Draft Ballot SC 21
tcrawford at bdo.com
Mon Aug 19 08:48:15 MST 2019
"In proposed new 3.g., would "resulting alerts" be overly broad? Also, will this new requirement burden CAs with additional recordkeeping to demonstrate that they "addressed" alerts within the 7-day requirement? Which "objectives" of the NCSSRs are monitoring and alerting targeting? Should we narrow the scope of the proposal?
Currently drafted language: g. If continuous automated monitoring and alerting is utilized to satisfy any of the objectives of the Network and Certificate System Security Requirements, resulting alerts must be addressed within at most seven (7) days and follow up action instigated in accordance with the CA's incident response procedures."
Thank you for your comments, Ben. The intention of the new 3g was to be applied to significant alerts, such as those additional use cases being added for the updated version of 3e and 1h. Based on your question, I think it is fair point that the scope of alerts might be considered too broad. Please see my adjustment below.
This does add some burden on the CA to address alerts timely, but the goal was to have a net reduction in efforts by removing manual monitoring. I would not expect this to have significant additional burden from a record keeping standpoint, because I would assume these actions are all tracked through a ticketing system as part of an IRP process.
g. If continuous automated monitoring and alerting is utilized to satisfy any of the objectives of the Network and Certificate System Security Requirements, indicate the specific alerts and the objectives they have been implemented to satisfy. Those alerts shall be classified as high risk. Alerts classified as high risk must be addressed within at most seven (7) days and follow up action instigated in accordance with the CA's incident response procedures.
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