[Servercert-wg] VOTING BEGINS: SC28v6 - Logging and Log Retention

[Ponds-White, Trevoli]

Amazon Trust Services votes Yes for SC28v6

From: Servercert-wg <servercert-wg-bounces at cabforum.org> On Behalf Of Neil Dunbar via Servercert-wg
Sent: Thursday, September 3, 2020 5:23
To: servercert-wg at cabforum.org
Subject: [EXTERNAL] [Servercert-wg] VOTING BEGINS: SC28v6 - Logging and Log Retention


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This begins the voting period for ballot SC28: Logging and Log Retention.

The ballot has been in heartbeat for some time - hopefully CAs have had the time to look at the issues within during this extended discussion period.

[The discussion document is attached to this email]

Current 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:

a.  the destruction of the CA Private Key; or

b.  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;

c.

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: 2020-07-10 17:00:00 UTC



End Time: 2020-08-28 17:00:00 UTC



Vote for approval (7 days)



Start Time : 2020-09-03 17:00:00 UTC



End Time: 2020-09-10 17:00:00 UTC
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