On Tue, November 3, 2015 4:24 pm, Kathleen Wilson wrote:
>  Topic to discuss [1]:
>  “(D3) Make the timeline clear about when the audit statements and
>  disclosure has to happen for new audited/disclosed subCAs.

>  What further clarification needs to be added to Mozilla’s CA Certificate
>  Policy to make it more clear when the audit statements and disclosure
>  has to happen for new subCAs?

Thanks for continuing to drive the discussion, Kathleen.

I think with respect to the Mozilla policy, the Baseline Requirements
themselves are quite explicit as to what the requirements are, and they're
a reasonable set of requirements. Where the disconnect appears to be is
how these are translated into auditable criteria under WebTrust or ETSI,
which unfortunately seems to be what a number of CAs (particularly ETSI
CAs, based on the issues) are relying on, rather than the standard they're
held to.

There are a number of ways to draw attention to this, but I think we
should be careful about how much attention we draw to it, relative to the
BRs as a whole.

I'm not necessarily advocating these options, but hopefully they can spark
a more thoughtful and thorough discussion:

Example 1: "The CA with a certificate included in Mozilla’s CA Certificate
Program
MUST disclose this information prior to the signing of the subordinate CA
certificate."

Example 2: "The CA with a certificate included in Mozilla's CA Certificate
Program MUST disclose this information following the completion of a point
in time readiness assessment, as described in Section 8.[whatever] of the
Baseline Requirements, and prior to the issuance of the first Publicly
Trusted Certificate."

Example 3: Keep the present language, but similar to documents such as
https://wiki.mozilla.org/CA:Schedule or
https://wiki.mozilla.org/CA:How_to_apply as an informal explanation of the
technical language.

I can think of pros and cons for each of these examples, but I present
them as ways to get people to think of the issues, as well as to see if
there are alternative solutions to the issue raised.

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