[Servercert-wg] Discussion Period Begins on Ballot SC51: Reduce and Clarify Audit Log and Records Archival Retention Requirements

Aaron Gable aaron at letsencrypt.org
Wed Jan 19 20:49:57 UTC 2022

I fully support the intent of this ballot, but upon close reading I have
some slight concern.

Although this ballot brings the definitions from the NCSSRs directly into
the BRs, those definitions do not include a definition of the words
"retain" or "archive". This causes me some confusion.

My reading of the structure of this ballot is essentially:
1) A CA must record events X, Y, Z to an audit log
2) A CA must retain those audit logs for 2 years after A, B, C
3) A CA must archive records X, Y, Z, W, V
4) A CA must retain archives for 2 years after A, B, C

With no functional definition of the word "archive", it is unclear what the
purpose of having both of these sections at all is. With the exception of
the additional numbered items 5.2.2.(4) and 5.2.2.(5), the two sections
appear to be essentially identical. A CA which stores all required records
on a single hard drive appears to be equally in compliance with both
sections. So why have both sections at all?

Additionally, I find the phrasing of Section 5.5.1 to be unfortunate: it
contains two sentences, both of which start "The CA and each Delegated
Third Party SHALL archive records related to...". These should be combined
into a single bulleted list, much as Section 5.5.2 does.


On Thu, Jan 13, 2022 at 11:02 AM Clint Wilson via Servercert-wg <
servercert-wg at cabforum.org> wrote:

> This email begins the discussion period for Ballot SC51: Reduce and
> Clarify Audit Log and Records Archival Retention Requirements
> BALLOT SC51: Reduce and Clarify Audit Log and Records Archival Retention
> Requirements
> The purpose of this ballot is to consolidate and clarify aspects of audit
> log and records archival retention expectations and time-periods within
> 5.5.2.
> Foremost, this ballot reduces retention periods for records archival to 2
> years.
> Further, currently audit log events as outlined in section 5.4.1, and
> then referenced in 5.4.3 lead to confusion around the log retention that
> is defined and exclusive to each section, and how that retention feeds
> into records archival requirements. To further clarify the objectives
> of that interaction, an explicit requirement has been introduced in
> 5.5.1 stating that CAs must archive lifecycle event records.
> As minor adjustments to related requirements, this ballot also
> clarifies what is expected by the term “OCSP Entries” as a logged lifecycle
> event; as OCSP Entry is an undefined term, this was replaced with OCSP
> Response such that it should be clear that a CA will be logging the event
> of signing an OCSP Response (including the elements stipulated in
> 5.4.1). Similarly, some certificate lifecycle events expected to be
> retained are currently separated into 5.5.2; these have been incorporated
> into 5.4.1 instead. This ballot also explicitly calls out the need for
> delegated third parties to abide by the established retention periods for
> audit logging and records archival procedures.
> This ballot also formalizes incorporation of terms defined in the NCSSRs
> as also applying to the BRs.
> The following motion has been proposed by Clint Wilson of Apple and
> endorsed by Trevoli Ponds-White of Amazon and Dustin Hollenback of
> Microsoft.
> -----Motion Begins-----
> This ballot modifies the “Baseline Requirements for the Issuance and
> Management of Publicly-Trusted Certificates” as defined in the following
> redline, based on Version 1.8.0:
> https://github.com/cabforum/servercert/compare/cda0f92ee70121fd5d692685b97ebb6669c74fb7...63dc6210e728349bb4602e4ede051efed593a91c
> -----Motion Ends-----
> This ballot proposes a Final Maintenance Guideline. The procedure for
> approval of this ballot is as follows:
> Discussion (7+ days)
> Start Time: January 13 2022 19:00 UTC
> End Time: January 20 2022 19:00 UTC
> Vote for approval (7 days)
> Start Time: TBD
> End Time: TBD
> _______________________________________________
> Servercert-wg mailing list
> Servercert-wg at cabforum.org
> https://lists.cabforum.org/mailman/listinfo/servercert-wg
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