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

[Dimitris Zacharopoulos (HARICA)]

On 21/1/2022 9:57 μ.μ., Clint Wilson wrote:
>
>
>> On Jan 20, 2022, at 2:54 AM, Dimitris Zacharopoulos (HARICA) via 
>> Servercert-wg <servercert-wg at cabforum.org> wrote:
>>
>> 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 agree that the authors of RFC 3647 intended for more detail to be 
> included in a CPS around each of these sections than is currently in 
> the BRs or added via the proposed changes in this ballot, however I 
> don’t believe that RFC 3647 intends for 5.4 and 5.5 to represent two 
> entirely different sets of “evidence”. For example, in section 4.5.4 
> (“Audit Logging Procedures”) it indicates that coverage should include 
> “Frequency with which audit logs are processed or archived”. 
> Similarly, in 4.5.5 (“Records Archival”) the RFC indicates that 
> coverage should include “Types of records that are archived, for 
> example all audit data….”. These references to archive and audits lead 
> me to the interpretation that the authors of RFC 3647 intended for the 
> records archival process to be an overarching collection and retention 
> of audit data (i.e. everything logged in section 5.4) along with other 
> data which may not be processed by event logging or audit systems 
> (such as documentation supporting certificate applications). That is, 
> as a Venn diagram, this is one circle inside another. This ballot 
> attempts to clearly outline the end result of this relationship by 
> delineating (and repeating, where relevant) the categories of data 
> accounted for in both sections 5.4 and 5.5. Given Aaron’s feedback, I 
> definitely think there’s room for improving /how/ we outline that end 
> result, however.
>
> Of course, one could also imagine, in CA-specific scenarios and 
> modernized validation/issuance processes, that all data processed by 
> the CA goes through event logging systems, and therefore there would 
> be no additional data beyond audit data present in the records 
> archive. I don’t believe this ballot negatively impacts such a CA, but 
> I would love to hear if there are perceived unintended implications 
> from the proposed text which can be corrected.
>
>>
>> I understand that RFC3647 has a different meaning in the term 
>> "archival" (used in the phrase "records archival") compared to this 
>> ballot.
> Are there differences that would be helpful to share here? FWIW, my 
> understanding is that archival is, as noted in 4.5.5 of RFC 3647, 
> “records retention” — that is, the continued possession and control of 
> a collection of records, typically (but not necessarily) on a less 
> frequently used storage medium. Perhaps this would be worth including 
> as a newly defined term, if there’s general agreement that this 
> represents what an archive is meant to be in the context of 5.5?

The notion of retention is also included in 4.5.4 in the phrase "Period 
for which audit logs are kept" but I see your point.

I believe the interpretation that audit logs (described in section 5.4 
of the BRs) are a subset of records archival (described in section 5.5) 
is fair and reasonable, and unless there are any objections, we should 
adopt it as such in the BRs by providing the necessary additional 
language. This will clarify the intent and expectations from CAs and 
auditors evaluating these requirements.

Dimitris.
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