Having received no comments on this proposal, I went ahead and added it to
the wiki [1].

- Wayne

[1] https://wiki.mozilla.org/CA/Responding_To_An_Incident#Incident_Report

On Wed, Dec 11, 2019 at 4:45 PM Wayne Thayer <wtha...@mozilla.com> wrote:

> While thinking about different ways to solve the problem of disclosing
> missed revocation deadlines, we devised a solution for searching and
> reporting on delayed revocations separately from other incidents. We've
> begun to add a new Bugzilla "whiteboard" label to delayed revocation
> incident bugs. We can then display those incidents separately on our
> Incident Dashboard, as follows:
> https://wiki.mozilla.org/CA/Incident_Dashboard#Revocation_Delays
>
> I've come to the conclusion that Mozilla should begin to require that CAs
> submit a separate bug when a revocation deadline is missed. I dislike the
> extra overhead of creating and managing more bugs, but doing so allows us
> to provide clearer guidance to CAs, and it helps to ensure that we are
> seeking out the root causes of revocation delays when they occur, rather
> than potentially missing those learnings amongst the issue(s) that
> triggered the revocation(s). To be clear, this proposal is not intended to
> create more work or somehow punish CAs for missing revocation deadlines.
>
> This results in the following new guidance:
>
> CAs should submit a separate incident report when:
> * Mozilla policy requires that the CA revoke one or more certificates by a
> certain deadline, such as those in BR section 4.9, but that deadline is not
> met by the CA
> * In the process of researching one incident, another incident with a
> distinct root cause and/or remediation is discovered
> * After an incident bug is marked resolved, the incident reoccurs
>
> I will appreciate everyone's feedback on these proposed improvements to
> the Incident Report section [1] of our Responding to an Incident wiki page.
> If no responses are received over the next few days, I'll go ahead and make
> these changes.
>
> - Wayne
>
> [1] https://wiki.mozilla.org/CA/Responding_To_An_Incident#Incident_Report
>
> On Thu, Nov 21, 2019 at 10:48 AM Ryan Sleevi <ryan.sle...@gmail.com>
> wrote:
>
>>
>>
>> On Thu, Nov 21, 2019 at 10:54 AM Wayne Thayer via dev-security-policy <
>> dev-security-policy@lists.mozilla.org> wrote:
>>
>>> During the recent CA/Browser Forum meeting, I was asked to provide better
>>> guidance on Mozilla's expectations for incident reporting. We're adding a
>>> requirement for incident reporting to the new version of our policy [1],
>>> but in this message I'm focused on the guidance provided on our wiki [2].
>>> The question was when to add information to an existing bug versus
>>> creating
>>> a new one. I'd like to propose adding the following guidance to the wiki
>>> to
>>> address this question:
>>>
>>> CAs should create a separate bug and file a new incident report when:
>>> * In the process of researching one incident another incident with a
>>> distinct root cause and/or remediation is discovered
>>> * After an incident bug is marked resolved, the incident reoccurs
>>>
>>> A third possible addition would be:
>>> * When a CA accidentally or intentionally misses a revocation deadline, a
>>> separate bug should/must be filed examining the root cause and
>>> remediation
>>> for missing the deadline
>>>
>>> I believe the argument for this is that tracking revocation issues
>>> separately will help us to focus on improving the agility of the web PKI.
>>> On the other hand, Mozilla has not generally required separate reports in
>>> the past, and doing so certainly creates more work for everyone involved.
>>> It's not clear to me that the benefit of this outweighs the cost.
>>
>>
>> Yeah, I've been thinking about this in light of the feedback Kathleen
>> offered on
>> https://groups.google.com/d/msg/mozilla.dev.security.policy/M7NGwCh14DI/jZft5ZH_AgAJ
>>
>> My primary objectives in treating it as two distinct issues are:
>> 1) Ensuring the timely remediation of the root causes of whatever
>> 'caused' the incident. In general, this should be 'sooner' than 'later'
>> 2) Ensuring transparency about when CAs are having repeat "delayed
>> revocation" issues; buried within issues themselves makes it difficult to
>> track when there are repeat offenders, but also limits visibility into
>> systemic issues that all CAs can/should be aware of when contemplating the
>> design and maintenance of their PKI
>> 3) Ensuring progress is made towards revocation, by not having bugs
>> prematurely closed when the 'root' incident is resolved but the CA has
>> taken no meaningful steps to bring their PKI back into compliance (yet)
>>
>
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