[cabfpub] Ballot 221 v3: Two-Factor Authentication and Password Improvements

Patrick Tronnier Patrick.Tronnier at oati.net
Tue May 15 15:37:09 UTC 2018


“the counter-argument is "Well, we want to rotate passwords more frequently, so we can be more secure".

I want to make it clear that OATI agrees with the minimum 2 year password period as the more secure route. It is FedRAMP and other standards which don’t. ☺

Thanks

With kind regards,

Patrick Tronnier
Principal Security Architect &
Sr. Director of Quality Assurance & Customer Support
Phone: 763.201.2000
Direct Line: 763.201.2052
Open Access Technology International, Inc.
3660 Technology Drive NE, Minneapolis, MN

CONFIDENTIAL INFORMATION: This email and any attachment(s) contain confidential and/or proprietary information of Open Access Technology International, Inc. Do not copy or distribute without the prior written consent of OATI. If you are not a named recipient to the message, please notify the sender immediately and do not retain the message in any form, printed or electronic.

From: Ryan Sleevi [mailto:sleevi at google.com]
Sent: Tuesday, May 15, 2018 11:03 AM
To: Patrick Tronnier <Patrick.Tronnier at oati.net>
Cc: CA/Browser Forum Public Discussion List <public at cabforum.org>; `PKI Monitor <PKIMonitor at oati.net>
Subject: Re: [cabfpub] Ballot 221 v3: Two-Factor Authentication and Password Improvements


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So I agree that changes the wording to no longer favor incumbents - but I think it's problematic for a different reason, in that it introduces a new form of severability, similar to 9.16.3.

9.16.3 applies to law, regulation, or government order - and it's not intended as a blanket get out of jail free card. It's a temporary thing, and the reality is that Root Stores may (and almost certainly will) set sunsets on that severability. It provides temporary redemption for those CAs that are, by virtue of their physical existence, placed in an awkward bind.

Yet this situation you describe is not that. It's a voluntary action by the CA, to entangle two or more PKIs with conflicting requirements, and to argue that the more favorable one wins. While I realize that the counter-argument is "Well, we want to rotate passwords more frequently, so we can be more secure" - but part of the point is that this doesn't make the systems more secure, and can tangibly make them less secure.

Two years seems like a generous sunset to work on a transition plan to disentangle these separable requirements, thus there's no need for an express severability clause to be added.

On Tue, May 15, 2018 at 9:30 AM, Patrick Tronnier <Patrick.Tronnier at oati.net<mailto:Patrick.Tronnier at oati.net>> wrote:
Hi Ryan,

“Previous audits” was meant to prove the CA was audited against password criteria separate from, or in addition to, the BR’s… which is a burden to incumbents such as OATI, GlobalSign, etc.

Also, we have considered segmenting our PKI but because the server certificates protect web sites which fall under both Web PKI and Energy Industry standards (NERC, NAESB) I am not sure how this can be achieved.

Perhaps this is better wording?

“If passwords are required to be changed periodically, that period SHOULD be at least two years.  Effective April 1, 2020, if passwords are required to be changed periodically, that period SHALL be at least two years. Compliance to other standards which conflict with this password requirement must be disclosed as part of the audit process."

Thanks

With kind regards,

Patrick Tronnier
Principal Security Architect &
Sr. Director of Quality Assurance & Customer Support
Phone: 763.201.2000
Direct Line: 763.201.2052
Open Access Technology International, Inc.
3660 Technology Drive NE, Minneapolis, MN<https://maps.google.com/?q=3660+Technology+Drive+NE,+Minneapolis,+MN&entry=gmail&source=g>

CONFIDENTIAL INFORMATION: This email and any attachment(s) contain confidential and/or proprietary information of Open Access Technology International, Inc. Do not copy or distribute without the prior written consent of OATI. If you are not a named recipient to the message, please notify the sender immediately and do not retain the message in any form, printed or electronic.

From: Public [mailto:public-bounces at cabforum.org<mailto:public-bounces at cabforum.org>] On Behalf Of Ryan Sleevi via Public
Sent: Monday, May 14, 2018 11:43 PM
To: Patrick Tronnier <Patrick.Tronnier at oati.net<mailto:Patrick.Tronnier at oati.net>>; CA/Browser Forum Public Discussion List <public at cabforum.org<mailto:public at cabforum.org>>
Subject: Re: [cabfpub] Ballot 221 v3: Two-Factor Authentication and Password Improvements


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Doesn't that seem to favor incumbents such as OATI? How would a new CA demonstrate this via previous audits?

Isn't it far better for OATI to use that time to establish a solution that segments out those PKIs as appropriate, to separate those of the Web PKI from those aforementioned other standards?

On Mon, May 14, 2018 at 10:26 PM, Patrick Tronnier via Public <public at cabforum.org<mailto:public at cabforum.org>> wrote:
Hi Tim,

OATI operates in an industry where the changes proposed to Section 2g iv. (If passwords are required to be changed periodically, that period SHOULD be at least two years.  Effective April 1, 2020, if passwords are required to be changed periodically, that period SHALL be at least two years.) conflict with multiple industry standards (i.e. NERC CIP, NAESB WEQ-12, FedRAMP, etc.).

To avoid this auditing nightmare would you consider a slight change in the wording of Ballot 221?

Perhaps “If passwords are required to be changed periodically, that period SHOULD be at least two years.  Effective April 1, 2020, if passwords are required to be changed periodically, that period SHALL be at least two years unless previous audits prove conflict with other password standards."

Thanks

With kind regards,

Patrick Tronnier
Principal Security Architect &
Sr. Director of Quality Assurance & Customer Support
Phone: 763.201.2000
Direct Line: 763.201.2052
Open Access Technology International, Inc.
3660 Technology Drive NE, Minneapolis, MN<https://maps.google.com/?q=3660+Technology+Drive+NE,+Minneapolis,+MN&entry=gmail&source=g>

CONFIDENTIAL INFORMATION: This email and any attachment(s) contain confidential and/or proprietary information of Open Access Technology International, Inc. Do not copy or distribute without the prior written consent of OATI. If you are not a named recipient to the message, please notify the sender immediately and do not retain the message in any form, printed or electronic.

From: Public [mailto:public-bounces at cabforum.org<mailto:public-bounces at cabforum.org>] On Behalf Of Tim Hollebeek via Public
Sent: Monday, May 14, 2018 7:32 AM
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>>
Subject: Re: [cabfpub] Ballot 221 v3: Two-Factor Authentication and Password Improvements

Ok, the person I was waiting for had no comments.  I will probably start the voting period
tomorrow.

From: Public [mailto:public-bounces at cabforum.org] On Behalf Of Tim Hollebeek via Public
Sent: Friday, May 4, 2018 3:49 PM
To: CA/Browser Forum Public Discussion List <public at cabforum.org<mailto:public at cabforum.org>>
Subject: [cabfpub] Ballot 221 v3: Two-Factor Authentication and Password Improvements

Unchanged from v2.  Refreshing time period so it doesn’t expire while I’m on PTO.

Still waiting for comments from one person.  Any other comments also welcome.

-Tim

Ballot 221: Two-Factor Authentication and Password Improvements

Purpose of Ballot: The Network Security Working Group met a number of times to
improve the Network Security Guidelines requirements around authentication,
specifically by requiring two-factor authentication, and improving the password
requirements in line with more recent NIST guidelines.

While CAs are encouraged to improve their password requirements as soon as
possible, a two year grace period is being given to allow organizations to
develop and implement policies to implement the improved requirements, especially
since some organizations may have to simultaneously comply with other
compliance frameworks that have not been updated yet and are based on older NIST
guidance about passwords.

The following motion has been proposed by Tim Hollebeek of DigiCert and endorsed
by Dimitris Zacharopoulos of Harica and Neil Dunbar of TrustCor.

— MOTION BEGINS –

This ballot modifies the “Network and Certificate System Security Requirements”
as follows, based upon Version 1.1:

In the definitions, add a definition for Multi-Factor Authentication:

"Multi-Factor Authentication: An authentication mechanism consisting of two or
more of the following independent categories of credentials (i.e. factors) to
verify the user’s identity for a login or other transaction: something you know
(knowledge factor), something you have (possession factor), and something you
are (inherence factor).  Each factor must be independent.  Certificate-based
authentication can be used as part of Multifactor Authentication only if the
private key is stored in a Secure Key Storage Device."

Capitalize all instances of the defined term "Multi-Factor Authentication".

Add a definition for Secure Key Storage Device:

"Secure Key Storage Device: A device certified as meeting at least FIPS 140-2
level 2 overall, level 3 physical, or Common Criteria (EAL 4+)."

In section 1.j., capitalize Multi-Factor Authentication, and strike the
parenthetical reference to subsection 2.n.(ii).

In section 2.f., add "(for accountability purposes, group accounts or shared
role credentials SHALL NOT be used)" after "authenticate to Certificate Systems".

Change section 2.g. to read:

"g. If an authentication control used by a Trusted Role is a username and password,
    then, where technically feasible, implement the following controls:
  i.           For accounts that are accessible only within Secure Zones or High Security
               Zones, require that passwords have at least twelve (12) characters;
  ii.          For authentications which cross a zone boundary into a Secure Zone or High
               Security Zone, require Multi-Factor Authentication.  For accounts accessible
               from outside a Secure Zone or High Security Zone require passwords that have
               at least eight (8) characters and are not be one of the user's previous
               four (4) passwords; and implement account lockout for failed access attempts
               in accordance with subsection k;
  iii.        When developing password policies, CAs SHOULD take into account the password
               guidance in NIST 800-63B Appendix A.
  iv.         If passwords are required to be changed periodically, that period SHOULD be
               at least two years.  Effective April 1, 2020, if passwords are required to
               be changed periodically, that period SHALL be at least two years."

In section 2.h., change "Require" to "Have a policy that requires"

In section 2.i., change "Configure" to "Have a procedure to configure"

Change section 2.k. to read:

"k. Lockout account access to Certificate Systems after no more than five (5) failed
    access attempts, provided that this security measure:
  i.           is supported by the Certificate System,
  ii.          Cannot be leveraged for a denial of service attack, and
  iii.        does not weaken the security of this authentication control;"

Change section 2.n. to read:

"Enforce Multi-Factor Authentication for all Trusted Role accounts on Certificate
Systems (including those approving the issuance of a Certificate, which equally
applies to Delegated Third Parties) that are accessible from outside a Secure Zone
or High Security Zone; and"

— MOTION ENDS –

The procedure for approval of this ballot is as follows:

Discussion (7+ days)

Start Time: 2018-03-28  15:00:00 EDT

End Time: after 2018-05-11 15:00:00 EDT

Vote for approval (7 days)

Start Time: TBD

End Time: TBD

From: Public [mailto:public-bounces at cabforum.org] On Behalf Of Tim Hollebeek via Public
Sent: Wednesday, March 28, 2018 12:26 PM
To: CA/Browser Forum Public Discussion List <public at cabforum.org<mailto:public at cabforum.org>>
Subject: [cabfpub] Ballot 221: Two-Factor Authentication and Password Improvements


Ballot 221: Two-Factor Authentication and Password Improvements

Purpose of Ballot: The Network Security Working Group met a number of times to
improve the Network Security Guidelines requirements around authentication,
specifically by requiring two-factor authentication, and improving the password
requirements in line with more recent NIST guidelines.

While CAs are encouraged to improve their password requirements as soon as
possible, a two year grace period is being given to allow organizations to
develop and implement policies to implement the improved requirements, especially
since some organizations may have to simultaneously comply with other
compliance frameworks that have not been updated yet and are based on older NIST
guidance about passwords.

The following motion has been proposed by Tim Hollebeek of DigiCert and endorsed
by Dimitris Zacharopoulos of Harica and Neil Dunbar of TrustCor.

— MOTION BEGINS –

This ballot modifies the “Network and Certificate System Security Requirements”
as follows, based upon Version 1.1:

In the definitions, add a definition for Multifactor Authentication:

"Multi-Factor Authentication: An authentication mechanism consisting of two or
more of the following independent categories of credentials (i.e. factors) to
verify the user’s identity for a login or other transaction: something you know
(knowledge factor), something you have (possession factor), and something you
are (inherence factor).  Each factor must be independent.  Certificate-based
authentication can be used as part of Multifactor Authentication only if the
private key is stored in a Secure Key Storage Device."

Add a definition for Secure Key Storage Device:

"Secure Key Storage Device: A device certified as meeting at least FIPS 140-2
level 2 overall, level 3 physical, or Common Criteria (EAL 4+)."

In section 1.j., capitalize Multi-Factor Authentication, and strike the
parenthetical reference to subsection 2.n.(ii).

In section 2.f., add "(for accountability purposes, group accounts or shared
role credentials SHALL NOT be used)" after "authenticate to Certificate Systems".

Change section 2.g. to read:

"g. If an authentication control used by a Trusted Role is a username and password,
    then, where technically feasible, implement the following controls:
  i.           For accounts that are accessible only within Secure Zones or High Security
               Zones, require that passwords have at least twelve (12) characters;
  ii.          For accounts that are accessible from outside a Secure Zone or High Security
               Zone, require Multi-Factor Authentication, with passwords that have at least
               eight (8) characters and are not be one of the user's previous four (4)
               passwords; and implement account lockout for failed access attempts in
               accordance with subsection k;
  iii.        When developing password policies, CAs SHOULD take into account the password
               guidance in NIST 800-63B Appendix A.
  iv.         If passwords are required to be changed periodically, that period SHOULD be
               at least two years.  Effective April 1, 2020, if passwords are required to
               be changed periodically, that period SHALL be at least two years."

In section 2.h., change "Require" to "Have a policy that requires"

In section 2.i., change "Configure" to "Have a procedure to configure"

Change section 2.k. to read:

"k. Lockout account access to Certificate Systems after no more than five (5) failed access attempts, provided that this security measure:
  i.           is supported by the Certificate System,
  ii.          Cannot be leveraged for a denial of service attack, and
  iii.        does not weaken the security of this authentication control;"

Change section 2.n. to read:

"Enforce Multi-Factor Authentication for all Trusted Role accounts on Certificate
Systems (including those approving the issuance of a Certificate, which equally
applies to Delegated Third Parties) that are accessible from outside a Secure Zone
or High Security Zone; and”

— MOTION ENDS –

The procedure for approval of this ballot is as follows:

Discussion (7+ days)

Start Time: 2018-03-28  15:30:00 EDT

End Time: after 2018-04-04 15:30:00 EDT

Vote for approval (7 days)

Start Time: TBD

End Time: TBD


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