Ben, I think Gerv addressed Doug's concern and indicated that situation
wouldn't fall under this policy. If that's not accurate, it'd be worth an
on-list clarification.

On Tue, Oct 24, 2017 at 9:01 AM, Ben Wilson via dev-security-policy <
dev-security-policy@lists.mozilla.org> wrote:

> I echo Doug's concerns.  I can see this process as being useful/helpful
> where the private key is off-premises, but for vanity CAs where the
> operator
> of the root CA maintains control of the private key the same as it does for
> all other issuing CAs, I think this would introduce unnecessary additional
> steps.
>
> -----Original Message-----
> From: dev-security-policy
> [mailto:dev-security-policy-bounces+ben=digicert....@lists.mozilla.org] On
> Behalf Of Doug Beattie via dev-security-policy
> Sent: Tuesday, October 24, 2017 9:44 AM
> To: Gervase Markham <g...@mozilla.org>;
> mozilla-dev-security-pol...@lists.mozilla.org
> Subject: RE: Proposed policy change: require private pre-notification of
> 3rd
> party subCAs
>
> Gerv,
>
> I assume this applies equally to cross signing, but not to "Vanity" CAs
> that
> are set up and run by the CA on behalf of a customer.  Is that accurate?
>
> Doug
>
> > -----Original Message-----
> > From: dev-security-policy [mailto:dev-security-policy-
> > bounces+doug.beattie=globalsign....@lists.mozilla.org] On Behalf Of
> > Gervase Markham via dev-security-policy
> > Sent: Tuesday, October 24, 2017 11:28 AM
> > To: mozilla-dev-security-pol...@lists.mozilla.org
> > Subject: Proposed policy change: require private pre-notification of
> > 3rd party subCAs
> >
> > One of the ways in which the number of organizations trusted to issue
> > for the WebPKI is extended is by an existing CA bestowing the power of
> > issuance upon a third party in the form of control of a
> > non-technically-constrained subCA. Examples of such are the Google and
> > Apple subCAs under GeoTrust, but there are others.
> >
> > Adding new organizations to the list of those trusted is a big deal,
> > and currently Mozilla has little pre-insight into and not much control
> > over this process. CAs may choose to do this for whoever they like,
> > the CA then bears primary responsibility for managing that customer,
> > and as long as they are able to file clean audits, things proceed as
> normal.
> >
> > Mozilla is considering a policy change whereby we require private pre-
> > notification of such delegations (or renewals of such delegations).
> > We would not undertake to necessarily do anything with such
> > notifications, but lack of action should not be considered permissive in
> an estoppel sense.
> > We would reserve the right to object either pre- or post-issuance of
> > the intermediate. (Once the intermediate is issued, of course, the CA
> > has seven days to put it in CCADB, and then the relationship would
> > probably become known unless the fields in the cert were misleading.)
> >
> > This may not be where we finally want to get to in terms of regulating
> > such delegations of trust, but it is a small step which brings a bit
> > more transparency while acknowledging the limited capacity of our team
> > for additional tasks.
> >
> > Comments are welcome.
> >
> > Gerv
> > _______________________________________________
> > dev-security-policy mailing list
> > dev-security-policy@lists.mozilla.org
> > https://lists.mozilla.org/listinfo/dev-security-policy
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>


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