[cabfpub] [Servercert-wg] Ballot SC3: Improvements to Network Security Guidelines

[Mike Reilly (GRC)]

Hi Tim. Sorry for the delayed response.  The concern is not the finite number of years but the fact that it would be a requirement vs. a recommendation or best practice.  The concern is NOT with a 2 year transition timeline but the fixed minimum timeline for life of a password.  The concerns I initially brought up are still not directly addressed.  Specifically:


  *   What about when a CA employee leaves who knows the password which requires it to be change in less than two years?
  *   What about if the password is compromised and needs to be changed in less than two years?
  *   How would auditors verify and prove that a CA did not change a password more frequently than two years? This is trying to prove a negative.
  *   Also, what about the use of Just In Time (JIT) admin where all CA access is done with a session password that is deleted when the session ends. So we literally have passwords that last minutes. Once the session ends the password is useless.

In summary:

  *   2 years is probably fine for implementation of whatever password change recommendation is put in place but we don’t think it should be a requirement.  Any prescriptive language around password lifecycles should be avoided.
  *   Any wording that requires a password NOT change within a certain period of time is problematic as there are numerous exceptions and auditing will be a challenge.

Perhaps language such as this would work:  “Frequent password changes have been shown to cause users to select less secure passwords.  For passwords associated with CAs, key materials and related systems, it is recommended that the CA set password change targets of 2 years or more to reduce the risk of insecure passwords being used to control and operate CAs.”  However the use of JIT may make this problematic as well.

Thanks, Mike
From: Tim Hollebeek <tim.hollebeek at digicert.com>
Sent: Saturday, July 14, 2018 12:10 AM
To: Mike Reilly (GRC) <Mike.Reilly at microsoft.com>; CA/Browser Forum Public Discussion List <public at cabforum.org>; Wayne Thayer <wthayer at mozilla.com>
Cc: servercert-wg at cabforum.org
Subject: RE: [cabfpub] [Servercert-wg] Ballot SC3: Improvements to Network Security Guidelines

Mike,

Is there a finite number of years larger than two you could get behind?

-Tim

From: Mike Reilly (GRC) [mailto:Mike.Reilly at microsoft.com]
Sent: Friday, July 13, 2018 7:39 PM
To: Tim Hollebeek <tim.hollebeek at digicert.com<mailto:tim.hollebeek at digicert.com>>; CA/Browser Forum Public Discussion List <public at cabforum.org<mailto:public at cabforum.org>>; Wayne Thayer <wthayer at mozilla.com<mailto:wthayer at mozilla.com>>
Cc: servercert-wg at cabforum.org<mailto:servercert-wg at cabforum.org>
Subject: RE: [cabfpub] [Servercert-wg] Ballot SC3: Improvements to Network Security Guidelines

Tim and Wayne, I believe making this a requirement will be problematic as I commented on with the original ballot (at bottom of thread).  So language would need to be as shown below. Thanks, Mike

  iv.         Frequent password changes have been shown to cause users to select less
               secure passwords.  If the CA has any policy that specifies routine periodic password changes,
               that period SHOULD NOT be less than two years.  Effective April 1, 2020,
               if the CA has any policy that requires routine periodic password changes, that period SHALL NOT
               be less than two years."

From: Public <public-bounces at cabforum.org<mailto:public-bounces at cabforum.org>> On Behalf Of Tim Hollebeek via Public
Sent: Friday, July 13, 2018 3:49 PM
To: Wayne Thayer <wthayer at mozilla.com<mailto:wthayer at mozilla.com>>
Cc: servercert-wg at cabforum.org<mailto:servercert-wg at cabforum.org>; CA/Browser Forum Public Discussion List <public at cabforum.org<mailto:public at cabforum.org>>
Subject: Re: [cabfpub] [Servercert-wg] Ballot SC3: Improvements to Network Security Guidelines

Works for me.  I’ll update the ballot.

-Tim

From: Wayne Thayer [mailto:wthayer at mozilla.com]
Sent: Friday, July 13, 2018 12:24 PM
To: Tim Hollebeek <tim.hollebeek at digicert.com<mailto:tim.hollebeek at digicert.com>>
Cc: CA/Browser Forum Public Discussion List <public at cabforum.org<mailto:public at cabforum.org>>; servercert-wg at cabforum.org<mailto:servercert-wg at cabforum.org>
Subject: Re: [cabfpub] [Servercert-wg] Ballot SC3: Improvements to Network Security Guidelines

On Fri, Jul 13, 2018 at 4:50 AM Tim Hollebeek <tim.hollebeek at digicert.com<mailto:tim.hollebeek at digicert.com>> wrote:
Do you have proposed modifications that would address these questions?  I would be happy to incorporate them.


How about this:

  iv.         Frequent password changes have been shown to cause users to select less
               secure passwords.  If the CA has any policy that specifies routine periodic password changes,
               that period SHOULD NOT be less than two years.  Effective April 1, 2020,
               if the CA has any policy that requires routine periodic password changes, that period SHALL NOT
               be less than two years."

From: Wayne Thayer [mailto:wthayer at mozilla.com<mailto:wthayer at mozilla.com>]
Sent: Thursday, July 12, 2018 7:35 PM
To: Tim Hollebeek <tim.hollebeek at digicert.com<mailto:tim.hollebeek at digicert.com>>; CA/Browser Forum Public Discussion List <public at cabforum.org<mailto:public at cabforum.org>>
Cc: Adriano Santoni <adriano.santoni at staff.aruba.it<mailto:adriano.santoni at staff.aruba.it>>; servercert-wg at cabforum.org<mailto:servercert-wg at cabforum.org>
Subject: Re: [cabfpub] [Servercert-wg] Ballot SC3: Improvements to Network Security Guidelines

How are the concerns that were raised by Microsoft (copied below for reference) addressed in this version? If the intent is for the language in section 2.g(iv) to only apply to periodic, policy-driven password changes and not to prevent event-driven changes, I think that should be clarified.

* How would auditors verify and prove that a CA did not change a password more frequently than two years? This is trying to prove a negative.
* What about when a CA employee leaves who knows the password which requires it to be change in less than two years?
* What about if the password is compromised and needs to be changed in less than two years?

- Wayne

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