[cabfpub] Baseline requirements for codesigning - Feb 4 2015.doc

Mon Feb 16 09:50:51 UTC 2015

Jody,

The auditor can be certified, can have a CISA, ISO27001 lead auditor, CISSP, etc. but does not entitled him to perform an ETSI audit. Of course is good to have, but is the auditing body that is allowed to perform an ETSI audit. And in their internal reqs they request their auditors to have those certifications or others. That has to be defined by the National Accreditation Body on the requirements to fulfill by the auditing body, in this case AuditCo.

If AuditCo meets the requirements, then it can be incorporated in the list of its NAB and therefore perform ETSI audits if ETSI is one of the admitted ones (otherwise you can´t be on the list, of course). Once AuditCo is accredited in its NAB according to whatever national scheme able to performing ETSI audits, then you can hire them even if you´re not, as a CA, belonging to that country.

Again, if we take Izenpe as a CA that wants to have an ETSI accredited audit (of course I can have ETSI audit but not accredited) then I have to look for Auditing bodies accredited in their countries (in Spain we don´t have), then I found that in Germany, TUV IT is accredited in its NAB according to the ISO standards requested and able to perform ETSI audits.

And yes, it´s not easy, not for me as a CA and not for you as a RP. As said, we´re working on improving the language (the requisites are not so easy as it depends on every country). Hopefully I can provide some inputs for the F2F

Iñigo Barreira
Responsable del Área técnica
i-barreira at izenpe.net <mailto:i-barreira at izenpe.net> 

945067705

ERNE! Baliteke mezu honen zatiren bat edo mezu osoa legez babestuta egotea. Mezua badu bere hartzailea. Okerreko helbidera heldu bada (helbidea gaizki idatzi, transmisioak huts egin) eman abisu igorleari, korreo honi erantzuna. KONTUZ!
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De: Jody Cloutier [mailto:jodycl at microsoft.com] 
Enviado el: viernes, 13 de febrero de 2015 21:28
Para: Barreira Iglesias, Iñigo; public at cabforum.org
Asunto: RE: [cabfpub] Baseline requirements for codesigning - Feb 4 2015.doc

Thank you, Inigo, 

What seems to be happening is that organizations are applying the ETSI standard in cases in which either there is no National Standards Body, or where the national standards body does not certify the company. Building on the scenario below, Audit Co is not recognized by ISRAC, but Auditor Jones has a CISP certification, which I've already confirmed with ETSI is not sufficient. 

I think what would help here is to make the requirement much more specific:

A Qualified Auditor is limited to an auditor that is employed by a company that is certified by a National Authority listed in either the Members or Associate Members link. 

This, much simplified language, seems to be what you are saying below, but the current language is such that Audit Co can argue that it can issue an ETSI audit because it's company is certified by another national authority that's not listed on the ETSI webpages anywhere. 

Jody

From: i-barreira at izenpe.net [mailto:i-barreira at izenpe.net] 
Sent: Friday, February 13, 2015 12:16 AM
To: Jody Cloutier; public at cabforum.org
Subject: RE: [cabfpub] Baseline requirements for codesigning - Feb 4 2015.doc

Dear Jody,

I understand your concern because it´s not easy for you to manage all possible combinations regarding ETSI audits in different countries so will try to clarify your example.

First of all, no AuditCo has to be member of ETSI, AuditCo can perform ETSI accredited audits without being member of ETSI, they only need to be accredited in their country as stated in Annex E requirements.

So,

For example, 

·         Company A is a commercial CA that operates in Israel

·         Auditor Jones works for AuditCo, which is based in Israel

·         AuditCo is certified by some governmental agency as a qualified auditor

IBà AuditCo has to be accredited under its National Accreditation Body according to ISO 17021. In the case of Israel, to follow the example, in the associated members tab of the EA, you can find the Israeli accreditation body, called ISRAC. Then AuditCo should be listed there and meeting the requirements to perform ETSI audits according to the national scheme indicated by ISRAC

·         AuditCo is not an ETSI Member or Associate Member

IB à this is not necessary. No need to be an ETSI member to perform ETSI audits

·         Auditor Jones audits Company A using the ETSI 102042 standard, and Company A sends the auditor's attestation letter to Microsoft as evidence that Company A complied with the Program's requirements.  

IBà this is perfectly valid if AuditCo is listed in ISRAC and is allowed to perform ETSI audits. Of course Auditor Jones has to be also accredited to perform these kind of audits, has to be "qualified", so it´s not only the company but also the auditor, but that´s an internal task of the AuditCo.

Regarding of being member of not, this is voluntary, they can join ETSI or not and don´t think that solve the problem because joining ETSI does not mean that you´re "qualified" or "accredited" to perform an ETSI audit, it´s just indicate that you belong to a club for example.

And of course, if company A needs an auditing company accredited in Israel and there´s none, they can look for in other countries. For example, in Spain there´s no accredited auditing bodies to perform ETSI audits listed in our NAB, called ENAC, so, we, Izenpe, had to look for another option. So, we contacted for the first 6 years with KPMG in the Netherlands, and the last 3, with TUV IT in Germany. And Izenpe has an accredited ETSI audits according to the, right now, German national scheme and we´re listed in Germany.

We´ll debate this within ETSI ESI trying to find an easier solution.

Regards

Iñigo Barreira
Responsable del Área técnica
i-barreira at izenpe.net <mailto:i-barreira at izenpe.net> 

945067705

ERNE! Baliteke mezu honen zatiren bat edo mezu osoa legez babestuta egotea. Mezua badu bere hartzailea. Okerreko helbidera heldu bada (helbidea gaizki idatzi, transmisioak huts egin) eman abisu igorleari, korreo honi erantzuna. KONTUZ!
ATENCION! Este mensaje contiene informacion privilegiada o confidencial a la que solo tiene derecho a acceder el destinatario. Si usted lo recibe por error le agradeceriamos que no hiciera uso de la informacion y que se pusiese en contacto con el remitente.

De: Jody Cloutier [mailto:jodycl at microsoft.com] 
Enviado el: miércoles, 11 de febrero de 2015 0:32
Para: Barreira Iglesias, Iñigo; public at cabforum.org
Asunto: RE: [cabfpub] Baseline requirements for codesigning - Feb 4 2015.doc

Thank you, Inigo. 

I think the problem is that, under ETSI, it's difficult to discern what an "equivalent national scheme" is. This sets up the scenario in which an auditor is employed by an organization that is recognized somehow by the government, but is not affiliated with an ETSI member organization (http://www.european-accreditation.org/home ). Microsoft does not know whether or not this auditor is qualified or not. 

For example, 

·         Company A is a commercial CA that operates in Israel

·         Auditor Jones works for AuditCo, which is based in Israel

·         AuditCo is certified by some governmental agency as a qualified auditor

·         AuditCo is not an ETSI Member or Associate Member

·         Auditor Jones audits Company A using the ETSI 102042 standard, and Company A sends the auditor's attestation letter to Microsoft as evidence that Company A complied with the Program's requirements.  

In this scenario, how does Microsoft know that Auditor Jones conducted a proper audit without expending significant resources to determine whether and according to what standard AuditCo and Auditor Jones was certified? 

Microsoft believes that it would be simpler if the requirements were that the Auditor must work for a company that is affiliated with an ETSI-approved member organization. If Company A needs an auditor and there is no qualified auditor in Israel, the company can use an auditor from a member organization via the cross-border conformity rules. 

Unless I am fundamentally misunderstanding the rules, the above is something that Microsoft is presently struggling with, and we'd like to try to make the rules easier to understand for potential partners and ourselves. 

Jody Cloutier

Senior Security Program Manager

Microsoft Trusted Root Certificate Program <http://aka.ms/rootcert> 

jody.cloutier at microsoft.com <mailto:jody.cloutier at microsoft.com> 

425.443.8922

Operating Systems Group  Global Risk and Compliance

  <http://microsoft.com/> 

From: i-barreira at izenpe.net [mailto:i-barreira at izenpe.net] 
Sent: Tuesday, February 10, 2015 3:09 AM
To: Jody Cloutier; public at cabforum.org
Subject: RE: [cabfpub] Baseline requirements for codesigning - Feb 4 2015.doc

Hi Jody,

Regarding your comment on ETSI audits, I have to say that the ETSI audits shall be performed by accredited auditors as mentioned in Annex E of the current ETSI TS 102 042. ETSI audits performed by not accredited auditors shall be considered invalid. 

Microsoft is accepting ETSI audits since the very beginning in its root program requirements indicating this requirement. ETSI is providing a list of accredited auditors as mere information because has to be maintained by every NAB (National Accreditation Body).

It´s true that this has to be improved regarding the new regulation 910/2014 and the new ENs and will take some time, but at the moment, it´s clearly stated that the audits shall be performed by accredited auditors.

Don´t hesitate in contacting me for any additional information or help. Sometimes I´ve received some emails from Tom or Kelvin asking for the qualification of some audits, so, as say, you can contact me regarding this issue.

Regards

Iñigo Barreira
Responsable del Área técnica
i-barreira at izenpe.net <mailto:i-barreira at izenpe.net> 

945067705

ERNE! Baliteke mezu honen zatiren bat edo mezu osoa legez babestuta egotea. Mezua badu bere hartzailea. Okerreko helbidera heldu bada (helbidea gaizki idatzi, transmisioak huts egin) eman abisu igorleari, korreo honi erantzuna. KONTUZ!
ATENCION! Este mensaje contiene informacion privilegiada o confidencial a la que solo tiene derecho a acceder el destinatario. Si usted lo recibe por error le agradeceriamos que no hiciera uso de la informacion y que se pusiese en contacto con el remitente.

De: public-bounces at cabforum.org [mailto:public-bounces at cabforum.org] En nombre de Jody Cloutier
Enviado el: lunes, 09 de febrero de 2015 18:55
Para: CABFPub (public at cabforum.org)
Asunto: [cabfpub] Baseline requirements for codesigning - Feb 4 2015.doc

Microsoft comments on Section 17. 

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