Steve,

Have you had a chance to review these questions? Considering that these are
all about existing practices, and as a CA should be readily available and
easy to answer, I'm hoping you can reply by end of day.

Please consider this a formal request from Google as part of investigating
this incident.

On Mon, Jan 23, 2017 at 5:58 PM, Ryan Sleevi <r...@sleevi.com> wrote:

> Steve,
>
> While I understand that your investigation is ongoing, this does seem
> extremely similar, if not identical, to Symantec's previous misissuance.
>
> In that previous incident, Symantec took a number of steps - beginning
> with reportedly immediately terminating the employees responsible and then
> continuing to a comprehensive system overhaul, as detailed at
> https://www.symantec.com/page.jsp?id=test-certs-update#
>
> What is particularly concerning here is that your current explanations
> suggest that either they are incomplete, or that Symantec's previous
> answers were either misleading or incorrect. This is extremely concerning,
> and I'm hoping you can clarify with answers to the following questions,
> independent of your ongoing investigation and as soon as possible:
>
> 1) In response to the previous incident, Symantec indicated they hold a
> "no compromise" bar for such breaches in the post titled "A tough day as
> leaders". [1]
>   a) Do you believe that the steps to "reduce privileges" represent a
> consistent application of that standard?
>   b) If not, what additional steps are you taking, consistent with your
> "no compromise" standard?
>
> 2) In response to the previous incident, Symantec indicated that the use
> of any privileged test tool would require senior leader justification from
> both QA and Production Operations teams and approvals from the heads of
> Engineering and Policy Compliance. [2]
>   a) Did Symantec mean that this was limited to validations performed by
> Symantec, and not that of Registration Authorities fulfilling the duties
> pursuant to Section 1.3.2 of the Baseline Requirements?
>   b) At the time Symantec made this statement, did Symantec have any
> Registration Authorities fulfilling the duties pursuant to Section 1.3.2 of
> the Baseline Requirements?
>   c) If such a statement was meant to be limited to Symantec, and not that
> of Registration Authorities, why did Symantec not feel it was appropriate
> to highlight that it did not extend to activities performed by Registration
> Authorities?
>   d) If such a statement was not meant to be limited to Symantec, was such
> a justification provided, and approvals granted, for the tool that allowed
> such Registration Authorities to issue these certificates?
>
> 3) In response to the previous incident, Symantec indicated a
> comprehensive review of issuance privileges was conducted to ensure only
> authorized personnel have the ability to issue certificates, and that a
> quarterly access review would be conducted to ensure this. [2]
>   a) Did such comprehensive review include that of Registration
> Authorities?
>   b) If not, why did Symantec not disclose that Registration Authorities
> were excluded?
>   c) Is Symantec currently performing access reviews of Registration
> Authorities?
>   d) If so, when does Symantec expect this to be completed?
>
> 4) In response to the previous incident, Symantec indicated it updated its
> internal policies and procedures for test certificates as used for
> commercial certificates. Further, it indicated that QA engineers and
> authentication personnel were trained on updated practices for test
> certificates. [2]
>   a) Did Symantec include Registration Authorities in the scope of that
> training?
>   b) If not, why did Symantec not disclose that Registration Authorities
> were excluded?
>   c) If so, why did Symantec's corrective actions for the previous
> misissuance fail to prevent this continued misissuance?
>
> 5) You have indicated that you have at least one WebTrust audited partner
> capable of causing issuance using Symantec-operated CAs.
>   a) Please provide a link to the audit results for each of these WebTrust
> audited partners.
>   b) Have you suspended the capabilities of these partners until Symantec
> completes its investigation?
>   c) If not, why not, and when do you expect to do so?
>
> 6) Does Symantec allow is Registration Authorities to deviate from the
> policies and standards set forth by its CP, CPS, and internal policies and
> controls?
>   a) If not, why did Symantec fail to detect that its Registration
> Authorities were deviating from its policies for this long?
>   b) If so, where does Symantec disclose this deviation within its CP
> and/or CPS?
>
> 7) When do you expect to provide the next update as to the ongoing
> investigation? If it is not within the next three days, why?
>
>
> Thank you for your time in answering each and every one of these questions
> and providing further details, so as to help inform the broader community
> as to the steps Symantec has taken and is taking to prevent continued
> misissuance contrary to the Baseline Requirements and the Mozilla CA
> Certificate Policy.
>
> [1] http://archive.is/Ro70U
> [2] https://www.symantec.com/page.jsp?id=test-certs-update
>
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