They way I see it there are basically 2 cases:
1) The root CA and the other CAs are not related.  Those other CAs are
   *not* Sub-CAs, they are CAs on their own and are independent of
   the root CA.
2) The root CA and *all* Sub-CAs are the same organization. 

What I see here being argued is that KISA should fall under 1).
And I have no problem seeing KISA as being independent here, since
I understand that they are so under the law.

But this would mean the following for me:
- The other CAs need to have an audit at least every year to check
  for compliance with *our* requirements, not the requirements from
  the Korean law.  That is, we might have more requirements than
  the Korean law, and they need to be checked too.
- There is no need for us to accept the KISA root CA, since they
  don't sign end user certificates and the LCAs need to have
  an audit anyway.  We can just accept the LCAs that request it
  based on KISA's audits, assuming that they meet all the
  requirements.

But I have yet to see that KISA has been audited to comply with
all our requirements.  Nothing in here says that KISA has been
audited for compliance with the CA/Browser forum Baseline
Requirements.

There has been no clear indication what the Korean law now asks
you to audit in the LCAs and whether that's equivalent to any of
those audits we now accept.  It's also not clear that all are
requirements are being audited in those LCAs.

I'm still of the opinion that we should not add KISA and that the
LCAs should instead apply themself.  I see no problem with KISA
doing the audits.  If they do not audit all our requirements some
or all of those might need to be audited by an other independent
party.


Kurt

On Tue, Mar 11, 2014 at 11:12:20AM +0900, ??? ????? wrote:
> there was no and is no on-going financial relationship between KISA and all
> the Sub-CAs.
> (and of course there will be no)
> 
> 
> 2014-03-11 11:04 GMT+09:00 Al Billings <abilli...@mozilla.com>:
> 
> > On 3/10/14, 6:58 PM, spark0...@gmail.com wrote:
> > > This might be a normal case for CA and Sub-CA in the business and that's
> > why I am mentioning Korea Electronic Signature Act.
> > > I do understand why BR is requesting for 'independency' of the auditor,
> > but because KISA is designated by law to audit the accredited CAs, our
> > relationship is clear(no corruption or mis-audit can happen). It is between
> > the auditor and auditee. We also do not have any conflict of interest
> > between KISA and Sub-CAs because we do not make any profit from the sub-CAs.
> >
> > The reasoning here is that there should be no ongoing financial
> > relationship causing a conflict of interest, I believe.
> >
> > Al
> >
> > --
> > Program Manager
> > Firefox Platform Security Team
> >
> >
> >
> 
> 
> -- 
> ???????? ?????
> ??? ?????(G-ISMS, K-ISMS, ISO-27001)
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