[cabf_validation] Disclosure of verification sources

[Pedro FUENTES]

Hello,
As discussed yesterday…

The current wording of 11.1.3, not only doesn't mandate to disclose QGIS, but applying strict reading, it would even disallow to use QGIS, but only “Incorporating Agency or Registration Agency”. Given that in many countries these agencies don’t have online search facilities, in many occasions CAs must rely on QGIS to do verifications (i.e. to validate a document presented by the applicant or to find out information the CA itself).

My proposal is to change section 11.1.3, so it opens the possibility to disclose and use QGIS, but without creating a potential issue with the JOI that must be specified in the certificate, which is still “where the applicant is incorporated or registered in a given agency”, so when it happens that incorporation/registration is at State or Locality level, but we are using a country-level QGIS, nobody is tempted to simplify and state a JOI at country-level.

Proposed text:
*******
11.1.3. Disclosure of Verification Sources
Prior to the use of Verification Source to fulfil these verification requirements, the CA MUST publicly disclose Agency Information about the Incorporating Agency or Registration Agency, or QGIS. This disclosure SHALL be through an appropriate and readily accessible online means.

This Agency Information SHALL include at least the following:
Sufficient information to unambiguously identify the Incorporating Agency or Registration Agency or QGIS (such as a name, jurisdiction, and website); and,
The accepted value or values for each of the subject:jurisdictionLocalityName (OID: 1.3.6.1.4.1.311.60.2.1.1), subject:jurisdictionStateOrProvinceName (OID: 1.3.6.1.4.1.311.60.2.1.2), and subject:jurisdictionCountryName (OID: 1.3.6.1.4.1.311.60.2.1.3) fields, when a certificate is issued using information from that Incorporating Agency or Registration Agency, indicating the jurisdiction(s) that the Agency is appropriate for; and,
The acceptable form or syntax of Registration Numbers used by the Incorporating Agency or Registration Agency, if the CA restricts such Numbers to an acceptable form or syntax; and,
A revision history that includes a unique version number and date of publication for any additions, modifications, and/or removals from this list.
The CA MUST document where to obtain this information within Section 3.2 of the CA’s Certificate Policy and/or Certification Practice Statement.

When using a QGIS, the CA will need to ensure that the following conditions are met:
The QGIS informs of:
The name of the Incorporating Agency or Registration Agency where the applicant is incorporated/registered, and
The registration number assigned by the Agency to the Applicant
The Jurisdiction of Incorporation or Registration to be included in the certificate MUST match the accepted values listed for the Agency, and will also MUST match the jurisdiction of incorporation or registration of the applicant 

The CA MUST document where to obtain this information within Section 3.2 of the CA’s Certificate Policy and/or Certification Practice Statement.

*******

As reference, original text:
*******
11.1.3. Disclosure of Verification Sources
Effective as of 1 October 2020, prior to the use of an Incorporating Agency or Registration Agency to fulfill these verification requirements, the CA MUST publicly disclose Agency Information about the Incorporating Agency or Registration Agency. This disclosure SHALL be through an appropriate and readily accessible online means.

This Agency Information SHALL include at least the following:
Sufficient information to unambiguously identify the Incorporating Agency or Registration Agency (such as a name, jurisdiction, and website); and,
The accepted value or values for each of the subject:jurisdictionLocalityName (OID: 1.3.6.1.4.1.311.60.2.1.1), subject:jurisdictionStateOrProvinceName (OID: 1.3.6.1.4.1.311.60.2.1.2), and subject:jurisdictionCountryName (OID: 1.3.6.1.4.1.311.60.2.1.3) fields, when a certificate is issued using information from that Incorporating Agency or Registration Agency, indicating the jurisdiction(s) that the Agency is appropriate for; and,
The acceptable form or syntax of Registration Numbers used by the Incorporating Agency or Registration Agency, if the CA restricts such Numbers to an acceptable form or syntax; and,
A revision history that includes a unique version number and date of publication for any additions, modifications, and/or removals from this list.
The CA MUST document where to obtain this information within Section 3.2 of the CA’s Certificate Policy and/or Certification Practice Statement.
*******



WISeKey SA
Pedro Fuentes
CSO - Trust Services Manager
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