[cabfpub] Bylaws: Update Membership Criteria (section 2.1)

Ryan Sleevi sleevi at google.com
Tue Jan 29 14:56:24 UTC 2019

On Tue, Jan 29, 2019 at 2:18 AM Dimitris Zacharopoulos <jimmy at it.auth.gr>

> On 28/1/2019 8:48 μ.μ., Ryan Sleevi via Public wrote:
> On Thu, Jan 24, 2019 at 2:30 PM Dimitris Zacharopoulos (HARICA) via Public
> <public at cabforum.org> wrote:
>> On 24/1/2019 8:16 μ.μ., Wayne Thayer via Public wrote:
>> On today's call we discussed a number of changes to the bylaws aimed at
>> clarifying the rules for membership. The proposal for section 2.1(a)(1)
>> resulting from today's discussion is:
>> Certificate Issuer: The member organization operates a certification
>>> authority that has a publicly-available audit report or attestation
>>> statement that meets the following requirements:
>>> * Is based on the full, current version of the WebTrust for CAs, ETSI EN
>>> 319 411-1 , or ETSI EN 319 411-2 audit criteria
>> Using the example reports for discussion (
> http://www.webtrust.org/practitioner-qualifications/docs/item85808.pdf )
> If a CA does not escrow CA keys, does not provide subscriber key
> generation services, or suspension services, does that count as being based
> on the "full, current version"? (Page 11, paragraph 2)
> I think so, yes. Based on the exact CA operations, the exact audit scope
> is determined. The Forum has set the WebTrust for CAs and ETSI EN 319 411-1
> as an absolute minimum that includes attestation of the existence of
> reasonable organizational and technical controls. If you recall, I had
> proposed that for the SCWG we should also require WebTrust for CAs Baseline
> and NetSec because they are already included in ETSI EN 319 411-1 and are
> more suitable for SSL/TLS Certificates. If a CA obtains a WebTrust for CAs
> or ETSI EN 319 411-1 audit report, it means that the core CA services are
> there and are operational.

I don't believe this is a correct understanding. By highlighting that it's
acceptable to carve out the scope, you're seemingly acknowledging that it's
acceptable to take subsets of the audit criteria. For example, if I
provided an audit for the physical security controls of my data center
against the WebTrust for CAs criteria, is that sufficient for membership as
a CA?

This isn't theoretical; at least one CA member provides such audits, as
they use such a third-party datacenter. If the datacenter provided just
their report, would they qualify? If they don't, then what is the property
that we're trying to achieve, and why, so that we can do it?

> Root programs have audit requirements exceptions and this applies equally
> to Microsoft and Mozilla. I don't disagree to being more inclusive but I
> believe the Forum must have objective and specific requirements based on
> some international standards and not just government regulations.

Then by this goal, I don't believe our current membership criteria meet
this. For example, a qualified auditor is determined by... government
regulations in the case of ETSI. Does that mean we should exclude ETSI
audits from the scope? Or should we allow CABs that are not accredited by
the NABs?

I realize it may seem like I'm being difficult, but I think there's a core
piece missing, which is trying to understand why it's important for some
members to exclude some other CAs that have had long-standing operations.
This is particularly relevant for the discussion of the S/MIME charter, in
which there is significant and extant set of 'trusted' certificates, in a
variety of software, that does not meet the criteria for participation.
They would be excluded from participating in engaging or drafting the new
criteria, by virtue of the Forum membership criteria, and I think that's
something we should be thinking very carefully about and articulating what
properties we expect of CAs and why.

> * Covers a period of at least 60 days
>> I'm curious for feedback from the ETSI folks, but perhaps a more
> inclusive definition would be
> - "Reports on the operational effectiveness of controls for a historic
> period of at least 60 days"
> The context being that ETSI is a certification scheme, but as part of that
> certification, the CAB "may" ("should") examine the historic evidence for
> some period of time. 7.9 of 319 403 only requires "since the previous audit"
> I am not representing ETSI or ACAB'c but if there are concerns with this
> requirement we can solve this issue using the language proposed by Wayne
> "Covers a period of at least 60 days". I would use "Covers a period of
> operations of at least 60 days".

I'm not sure what this is a response to. I was pointing out the issues with
the language proposed by Wayne and why it's insufficient, so it's not clear
to me how you've resolved that.
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