[Servercert-wg] Ballot SC28v4: Logging and Log Retention

[Neil Dunbar]

In response to Dimitris's request to slow down on ballot throughput, I'm
putting this one on heartbeat, until I can discuss further with the
NetSec team.

So - there is no change to the text at all, but just to ensure the
ballot doesn't get lost.

Regards,

Neil

The amended discussion document is attached to this email.

Principal changes:

1) Moving text to make clearer =the scope of CA key/certificate event retention

Updated redline: https://github.com/cabforum/documents/compare/16a5a9b...neildunbar:498c5ad


Purpose of Ballot:


The proposed changes seek to clarify the relationship between audit
logging obligations under Network and Certification System Security
Requirements and Baseline Requirements and to reduce the retention
period for log data, when appropriate. The proposed change also provides
clarification by specifically cross-referencing the Baseline Requirements.

The current log retention requirements for subscriber certificates
require certificate validation and certificate activity to be retained
for seven years, while the lifetime of a certificate is only two years.
There does not seem to be a justification for retaining logs three times
as long as the lifetime of the certificate. As certificate lifetimes
move to one year this further supports a reduction in log retention;
this ballot proposes a sorting of the logged events into logical
categories, together with a requirement of CAs to retain the data for
two years after the event has passed (as opposed to the blanket seven
years which exists as a duty currently).

The benefit of this ballot is to reduce data retention requirements for
those log elements which most CAs consider as having limited long-term
value. As an example, firewall and router activity logs are of
significant size and thus impose significant storage requirements. These
logs serve a benefit when investigating a potential security event,
however, these logs lose value with the passage of time. Logs containing
firewall traffic that is several years old provide little value in the
investigation of a contemporary incident. Additionally, certificate
validation and issuance logs have little value after a certificate has
expired. The log size for many CAs is measured in terabytes, each year
and the overhead of storing these logs and monitoring for compliance is
significant. The benefit for reducing retention is considered high.

The dicussion document which forms the basis of the ballot is attached
as a PDF to this email - previous attempts to link to the Google Drive
document ran up against permission problems in the past.

Proposal

The following ballot is proposed by Neil Dunbar of TrustCor Systems and
endorsed by Trevoli Ponds-White of Amazon and Dustin Hollenback of
Microsoft.

*— MOTION BEGINS —*

Delete the following Section 5.4.1. from the “Baseline Requirements for
the Issuance and Management of Publicly-Trusted Certificates”, version
1.6.7, which currently reads as follows:

The CA and each Delegated Third Party SHALL record details of the
actions taken to process a certificate request and to issue a
Certificate, including all information generated and documentation
received in connection with the certificate request; the time and date;
and the personnel involved. The CA SHALL make these records available
to its Qualified Auditor as proof of the CA’s compliance with these
Requirements.

The CA SHALL record at least the following events:

 1. CA key lifecycle management events, including: 

a. Key generation, backup, storage, recovery, archival,
and destruction; and 

b. Cryptographic device lifecycle management events. 

2. CA and Subscriber Certificate lifecycle management events, including:

a.  Certificate requests, issuance, renewal, and re-key requests,
 and revocation;

b.  All verification activities stipulated in these Requirements
 and the CA’s Certification Practice Statement;

c.  Date, time, phone number used, persons spoken to, and end
 results of verification telephone calls;

d.  Acceptance and rejection of certificate requests; Frequency
 of Processing Log

e.  Issuance of Certificates; and

f.  Generation of Certificate Revocation Lists and OCSP entries.

3. Security events, including:

a.  Successful and unsuccessful PKI system access attempts;

b.  PKI and security system actions performed;

c.  Security profile changes;

d.  System crashes, hardware failures, and other anomalies;

e.  Firewall and router activities; and

f.  Entries to and exits from the CA facility.

Insert in Section 1.6.1 (Definitions)  of the “Baseline Requirements for the
Issuance and Management of Publicly-Trusted Certificates”, the following (after
the definition of “Certification Practice Statement”):

Certificate Profile: A set of documents or files that defines requirements for
Certificate content and Certificate extensions in accordance with Section 7 of
the Baseline Requirements. e.g. a Section in a CA’s CPS or a certificate
template file used by CA software.

Insert, as Section 5.4.1. (Types of events recorded) of the “Baseline Requirements
for the Issuance and Management of Publicly-Trusted Certificates”, the following:

Section 5.4.1

The CA and each Delegated Third Party SHALL record details of the actions taken
to process a certificate request and to issue a Certificate, including all information
generated and documentation received in connection with the certificate request;
the time and date; and the personnel involved. The CA SHALL make these records
available to its Qualified Auditor as proof of the CA’s compliance with these
Requirements.

The CA SHALL record at least the following events:

 1.

    CA certificate and key lifecycle events, including:

     1.

        Key generation, backup, storage, recovery, archival, and destruction; 

     2.

        Certificate requests, renewal, and re-key requests, and revocation;

     3.

        Approval and rejection of certificate requests; 

     4.

        Cryptographic device lifecycle management events;

     5.

        Generation of Certificate Revocation Lists and OCSP entries;

     6.

        Introduction of new Certificate Profiles and retirement of existing Certificate Profiles.

 2.

    Subscriber Certificate lifecycle management events, including:

     1.

        Certificate requests, renewal, and re-key requests, and revocation;

     2.

        All verification activities stipulated in these Requirements and the CA's Certification Practice Statement;

     3.

        Approval and rejection of certificate requests; 

     4.

        Issuance of Certificates; and

     5.

        Generation of Certificate Revocation Lists and OCSP entries.

 3.

    Security events, including:

     1.

        Successful and unsuccessful PKI system access attempts;

     2.

        PKI and security system actions performed;

     3.

        Security profile changes;

     4.

        Installation, update and removal of software on a Certificate System; 

     5.

        System crashes, hardware failures, and other anomalies;

     6.

        Firewall and router activities; and

     7.

        Entries to and exits from the CA facility.

Delete the following Section 5.4.3. from the “Baseline Requirements for the Issuance
and Management of Publicly-Trusted Certificates”, version 1.6.7, which currently
reads as follows:

The CA SHALL retain any audit logs generated for at least seven years. The CA
SHALL make these audit logs available to its Qualified Auditor upon request.

Insert, as Section 5.4.3. Retention Period for Audit Logs of the “Baseline Requirements
for the Issuance and Management of Publicly-Trusted Certificates”, the following:

The CA SHALL retain, for at least two years:

 1.

    CA certificate and key lifecycle management event records (as set forth in Section 5.4.1 (1)) after the later occurrence of:

     1.

        the destruction of the CA Private Key; or

     2.

        the revocation or expiration of the final CA Certificate in that set of Certificates that have an X.509v3 basicConstraints extension with the cA field set to true and which share a common Public Key corresponding to the CA Private Key; 

 2.

    Subscriber Certificate lifecycle management event records (as set forth in Section 5.4.1 (2)) after the revocation or expiration of the Subscriber Certificate.

 3.

    Any security event records (as set forth in Section 5.4.1 (3)) after the event occurred. 

Delete from “Network and Certificate Systems Security Requirements”, Version 1.3,
Section 3.b

b.  Identify those Certificate Systems under the control of CA or Delegated
    Third Party Trusted Roles capable of monitoring and logging system activity
    and enable those systems to continuously monitor and log system activity;

Insert new “Network and Certificate Systems Security Requirements”, Version 1.3,
Section 3.b with the following text:

b.  Identify those Certificate Systems under the control of CA or Delegated
    Third Party Trusted Roles capable of monitoring and logging system activity,
    and enable those systems to log and continuously monitor the events specified
    in Section 5.4.1 (3) of the Baseline Requirements for the Issuance and
    Management of Publicly-Trusted Certificates;

*

*— MOTION ENDS —*

*

Discussion (7+ days)

Start Time: 2020-07-20 17:00:00 UTC

End Time: 2020-07-31 17:00:00 UTC

Vote for approval (7 days)

Start Time : TBD

End Time: TBD

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