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

Dimitris Zacharopoulos (HARICA) dzacharo at harica.gr
Tue Jan 29 17:11:57 UTC 2019

On 29/1/2019 4:56 μ.μ., Ryan Sleevi wrote:
> On Tue, Jan 29, 2019 at 2:18 AM Dimitris Zacharopoulos 
> <jimmy at it.auth.gr <mailto:jimmy at it.auth.gr>> wrote:
>     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 <mailto: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?

Would this WebTrust for CAs audit report be sufficient for acceptance in 
a Root Program? I don't think so.  All these years, CA/B Forum Members 
have been accepted by providing WebTrust for CAs and ETSI reports that 
include core PKI procedures. What you describe is probably an exception 
and we can decide how to handle this exception if in fact we ever 
receive an application for participation in a WG with a WebTrust for CAs 
audit report scoping just the physical security of a Datacenter. I'm 
hope that CA had other WebTrust for CAs reports for their other operations.

>     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?

This doesn't make a lot of sense. NABs are not Supervisory Bodies. It's 
different. I was referring to government audit schemes for CAs where a 
certain government unit audits a CA under national criteria.

> 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.

IMHO we need audit requirements that have undergone enough scrutiny and 
quality assurance. International standards like ISO, WebTrust and ETSI 
have such a process which provides better assurance for the audit 
outcome. That's my personal view. We can always listen to other schemes 
and we would welcome input from governments (as Interested Parties) if 
they choose to participate. If these schemes became so useful and 
comparable with existing international schemes, then the S/MIME Working 
Group could decide to add those schemes in the criteria for Membership 
and possibly in the produced Guidelines.

>>>             * 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.

This was in response to an audit that covers at least 60 days of 
operations. You argued that the ETSI scheme doesn't specifically mandate 
a minimum audit period before issuing an audit report. In practice, CABs 
use 60-90 days but it's not written in ETSI EN 319 403. Wayne's proposal 
attempts to add this in the requirements so it's clear that we are 
always talking about a period-of-time audit report for WebTrust and ETSI.

I hope it's clearer now.
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