Thank you for the incident report. I have posted it to the bug:
https://bugzilla.mozilla.org/show_bug.cgi?id=1495497

On Mon, Oct 8, 2018 at 8:25 AM piotr.grabowski--- via dev-security-policy <
dev-security-policy@lists.mozilla.org> wrote:

> Here's the incident report:
>
> 1.    How your CA first became aware of the problem (e.g. via a problem
> report submitted to your Problem Reporting Mechanism, via a
>
> discussion in mozilla.dev.security.policy, or via a Bugzilla bug), and the
> date.
>
> Email from Wayne Thayer Oct 1, 2018
>
> 2.    A timeline of the actions your CA took in response.
>
> A. Oct 2, 2018 - Investigation began.
> B. Oct 4, 2018 - Found impacted certificate policy templates.
> C  Oct 4, 2018 - All the certificates owners were contacted and agreed on
> issuance new BR compliant certificates in time convenient for them,
>           preferably not later than by the end of this year and revocation
> current ones.
> D. Oct 8, 2018 - Fixed impacted certificate policy templates.
> E. Oct 8, 2018 - This disclosure.
>
> Ongoing:
> F. Replacement of impacted certificates
> G. Training of periodic certificate policy templates validation.
>
> 3.    Confirmation that your CA has stopped issuing TLS/SSL certificates
> with the problem.
>
> Confirmed.
>
> 4.    A summary of the problematic certificates. For each problem: number
> of certs, and the date the first and last certs with that problem
>
> were issued.
>
> There are 46 certificates.  The certificates were issued between Feb 20,
> 2017 and Sep 25, 2018.
>
> 5.    The complete certificate data for the problematic certificates. The
> recommended way to provide this is to ensure each certificate is
>
> logged to CT and then list the fingerprints or crt.sh IDs, either in the
> report or as an attached spreadsheet, with one list per distinct
> problem.
>
> Added as attachment
>
> https://crt.sh/?caid=15985&opt=cablint,zlint,x509lint&minNotBefore=2017-01-01
>
> 6.    Explanation about how and why the mistakes were made or bugs
> introduced, and how they avoided detection until now.
>
> The the incident concerns 46 certificates in the vast majority issued on
> KIR S.A. internal system purposes.
> The root cause of this issue was human error in certificate policy
> templates.
>
> "Human error" is not a sufficient response to this questions. Please
describe the process in place for modifying policy templates and how it
failed to catch this problem.

>
> Remediation items:
>
> 1. Reviewed all certificate policy templates for ensuring that all of them
> are BR comliant.
> 2. All the certificates owners were contacted and agreed on issuance new
> BR compliant certificates in time convenient for them, preferably not later
> than by the end of this year and revocation current ones.
> 3. Added procedural step for periodic certificate policy templates
> validation.
>
> None of these remediation items will prevent future problems of this
nature. How will you improve your processes to prevent future misissuance?

I assume that KIR S.A. has not implemented pre-issuance linting. Why not?
Is there a plan to implement pre-issuance linting? When?

>
> We have by the way question about error: ERROR: The 'Organization Name'
> field of the subject MUST be less than 64 characters.
> According to https://www.ietf.org/rfc/rfc5280.txt and the note from this
> RFC 'ub-organization-name INTEGER ::= 64. For UTF8String or UniversalString
> at least four times the upper bound should be allowed. So what is the max
> length of this field  for UTF8String?
>
> Page 113 of RFC 5280 limits the length of the field to 64 characters
regardless of the data type:

-- Naming attributes of type X520OrganizationName:
--   X520OrganizationName ::=
--          DirectoryName (SIZE (1..ub-organization-name))
--
-- Expanded to avoid parameterized type:
X520OrganizationName ::= CHOICE {
      teletexString     TeletexString
                          (SIZE (1..ub-organization-name)),
      printableString   PrintableString
                          (SIZE (1..ub-organization-name)),
      universalString   UniversalString
                          (SIZE (1..ub-organization-name)),
      utf8String        UTF8String
                          (SIZE (1..ub-organization-name)),
      bmpString         BMPString
                          (SIZE (1..ub-organization-name))  }
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