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

Dimitris Zacharopoulos (HARICA) dzacharo at harica.gr
Thu Jan 20 10:53:52 UTC 2022


Similarly with Aaron, I support the intent of this ballot but have 
similar concerns about the terms used in the ballot.

Back in May 2021, I sent this message 
<https://lists.cabforum.org/pipermail/netsec/2021-May/000449.html> to 
the NetSec Subcommittee referring to RFC 3647 for guidance on the use of 
the terms "audit log" and "records archival". In my understanding the 
authors of RFC 3647 were trying to capture two different sets of 
"evidence". Each set would need to define the "types of events 
recorded/types of records archived", the "retention period", the 
"protection" controls, and the "backup" controls.

I understand that RFC3647 has a different meaning in the term "archival" 
(used in the phrase "records archival") compared to this ballot.

Based on 3647, sections 5.4 and 5.5 are complementary and symmetrical. 
With that said, it appears that 5.5.2 repeats what is already required 
in 5.4.3 (1.), (2.) and (3.). I'm fine with repeating important text but 
I'm concerned that this might cause some confusion. We should probably 
clarify these terms a little better.

I would also like to propose that a NOTE is added at the end of sections 
5.4.3 and 5.5.2:

In 5.4.3:

"*Note:* While these Requirements set the minimum retention period, the 
CA MAY choose a greater value as more appropriate in order to be able to 
investigate possible security or other types of incidents that will 
require retrospection and examination of past audit log events."

In 5.5.2:

"*Note:* While these Requirements set the minimum retention period, the 
CA MAY choose a greater value as more appropriate in order to be able to 
investigate possible security or other types of incidents that will 
require retrospection and examination of past records archived."

I would even recommend changing the MAY into a SHOULD if others agree.

Dimitris.

On 19/1/2022 10:50 μ.μ., Aaron Gable via Servercert-wg wrote:
> 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.
>
> Aaron
>
> 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
>
>     PURPOSE OF BALLOT
>
>     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.
>
>     MOTION
>
>     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
>
>
> _______________________________________________
> Servercert-wg mailing list
> Servercert-wg at cabforum.org
> https://lists.cabforum.org/mailman/listinfo/servercert-wg
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