[cabf_validation] [EXTERNAL] Draft Ballot SCXX: Improve OU validation requirements

Mon Nov 23 05:22:44 MST 2020

Thanks for your feedback Doug,

Let me list the changes in relation to the comments from Ryan:
If that were not troubling enough, however, I think it also bears mentioning that this approach continues with one which has been firmly discredited, and which we've been actively moving away from in the Forum since the Forum's very creation, which is the introduction of significant interpretation differences and leeway. "and an equivalent of the word ... " and "in the equivalent of the language" should best be read as "any other method", and much like how "but" serves to negate that which precedes it in a sentence, the "an equivalent" serves to negate any presumption of any rigor described.
Moving to a fixed set of pre/suffix values does addresses Ryans point on the usage of equivalent, this is also the reason I added 'certified translation', and I would like to extent this further to 'unambiguous certified translation of the equivalent in a language other than English'.

And, in the spirit of completely missing the problem space, it does nothing to address the fact that the following language is, practically speaking, unimplementable: "It SHALL NOT include a name, DBA, tradename, trademark, address, location, or other text that refers to a specific natural person or Legal Entity unless the CA has verified this information in relation to the Application accordance with Section 3.2."
Instead of SHALL NOT, the proposal now requires the CA to verify if the value is listed in the WIPO Global Brand Database or the local business registry and if registered that the usage rights must be verified.

I do not agree that an extension is the right place for the OU field. The organizational unit is for many large organizations a fundamental element to identify the accountable unit (equally for relying parties). A new extension might be great for other purposes such as unique tracking information which is currently often placed in the OU field and I'm happy to collaborate on that with you, after we have address the OU field.

________________________________
From: Doug Beattie
Sent: Monday, November 23, 2020 12:58
To: Paul van Brouwershaven; CA/Browser Forum Validation SC List; Ryan Sleevi
Subject: RE: [cabf_validation] [EXTERNAL] Draft Ballot SCXX: Improve OU validation requirements

Paul,

This does not address Ryan’s concerns he’s previously stated, so I doubt it’s really advancing the cause.

Ryan: I’m thinking the use of a private extension for this type of data (including LEIs and other industry desired data) that cannot be validated in accordance with the BRs (section 3.2) might be a good approach, similar to the QCStatement extension.  Would you have any serious objections to the long term use of a private extension which the browsers can ignore for conveying this type of data?

From: Validation <validation-bounces at cabforum.org> On Behalf Of Paul van Brouwershaven via Validation
Sent: Monday, November 23, 2020 4:00 AM
To: Ryan Sleevi <sleevi at google.com>; CA/Browser Forum Validation SC List <validation at cabforum.org>
Subject: Re: [cabf_validation] [EXTERNAL] Draft Ballot SCXX: Improve OU validation requirements

I created a version to address the highlighted concerns on the usage of the word 'equivalent' and the validation of trademarks and trade/business names.

This version:

  *   is using a fixed set of pre/suffix values
  *   includes a requirement for a certified translation for the equivalent in a language other than English
  *   requires the CA to check the value in the WIPO Global Brand Database and the local business registry

Proposed OU validation requirements:

If the Subject Identity Information is to include an organizational unit, then it MUST be preceded or followed by a whitespace and one of the words “unit”, “department”, “division”, “group”, “service", "system", "center", "office", “school”, “faculty”, "administration", "operations” in singular or plural form; or a certified translation of the equivalent in a language other than English.

The CA MUST verify the existence and affiliation of the organizational unit with the Applicant using an Organizational Chart provided by an authoritative source within the Applicant's organization, such as the Applicant's main business offices, corporate offices, human resource offices, information technology offices, or other department that the CA deems appropriate.

If a value holds an active registration in the ‘WIPO Global Brand Database’ or a local business register the CA MAY only include these registered values when the CA has verified the right of usage in relation to the Application in accordance with Section 3.2.

The value SHALL not be abbreviated unless this would exceed the maximum length of the `subject:organizationalUnitName` field, in which case it SHALL only use locally accepted abbreviation.

Please share your thoughts about this version.

Thanks,

Paul

________________________________

From: Ryan Sleevi <sleevi at google.com>
Sent: Monday, November 16, 2020 16:23
To: Paul van Brouwershaven <Paul.vanBrouwershaven at entrust.com>; CA/Browser Forum Validation SC List <validation at cabforum.org>
Subject: Re: [cabf_validation] [EXTERNAL] Draft Ballot SCXX: Improve OU validation requirements

On Mon, Nov 16, 2020 at 10:12 AM Paul van Brouwershaven via Validation <validation at cabforum.org<mailto:validation at cabforum.org>> wrote:

I have been thinking about a more simplistic and strict approach that doesn't follow all the current allowed methods listed in section 3.2 of the BR like we have proposed currently.

As with every other proposal Entrust has offered to date, this doesn't actually address the problem inherent to any use of this field, which is that it's unverified, unvetted data, as there is *no* way to validate and vet it.

The most recent proposal reflects a thoroughly-debunked theater exercise to security, which is to rely on statements like "The user should understand that ...". It attempts to absolve the CA of the responsibility for not placing unverified data in certificates in the first place, by trying to make it the user's responsibility on distinguishing that data from other fields and making an informed decision. Thankfully, this has been shown to be a theater exercise that harms users, so I feel like it's reasonable to simply reject it outright.

If that were not troubling enough, however, I think it also bears mentioning that this approach continues with one which has been firmly discredited, and which we've been actively moving away from in the Forum since the Forum's very creation, which is the introduction of significant interpretation differences and leeway. "and an equivalent of the word ... " and "in the equivalent of the language" should best be read as "any other method", and much like how "but" serves to negate that which precedes it in a sentence, the "an equivalent" serves to negate any presumption of any rigor described.

This isn't progress on any measured dimension of providing rigor or addressing the fundamental issues, and is an attempt to preserve the status quo without actually addressing the issues. I'm glad Entrust is now interested in this space, but this approach was discussed as far back as London in 2018, during the WG day, and highlights the problematic approach.

And, in the spirit of completely missing the problem space, it does nothing to address the fact that the following language is, practically speaking, unimplementable: "It SHALL NOT include a name, DBA, tradename, trademark, address, location, or other text that refers to a specific natural person or Legal Entity unless the CA has verified this information in relation to the Application accordance with Section 3.2."
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