On Mon, Apr 2, 2018 at 4:36 PM, Jakob Bohm via dev-security-policy <
dev-security-policy@lists.mozilla.org> wrote:

>
> While Entrust happens to do this, as a relying party, I dislike frequent
> updates to CP/CPS documents just for such formal changes.
>
> This creates a huge loophole. The CP/CPS is the master set of policies the
TSP agrees to be bound by and audited against. If a TSP doesn't include a
new subCA certificate in the scope of their CP/CPS, then from an audit
perspective  there is effectively no policy that applies to the subCA.
Similarly, if the TSP claims to implement a new policy but doesn't include
it in their CP/CPS, then the audit will not cover it (unless it's a BR
requirement that has made it into the BR audit criteria).

This is because the CP/CPS is a lengthy legal document which relying
> parties are "supposed to" read and understand.  Thus each such needless
> change generates a huge wave of millions of relying parties being
> supposed to obtain and read through that document, a complete waste of
> our time as relying parties.
>
> I think you're confusing the Relying Party Agreement with the CP/CPS. Even
so, you've pointed out that it is absurd to use this as an argument against
regular CP/CPS updates.

TSPs are now required to maintain change logs in their CP/CPS.  Would not a
quick glance at that meet your needs?

It is much more reasonable, from a relying party perspective, for such
> informational details to be in a parallel document and/or be postponed
> until a scheduled annual or rarer document update (Yes I am aware of the
> BR that such needless updates be done annually for no reason at all).
>
> How would you distinguish between details and material changes? I would
argue that a new subCA certificate is more than an informational detail.

The point of the BR requirement is to create some documentation indicating
that a TSP is regularly reviewing and updating their CP/CPS.
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