All, This email is part of the discussion for the next version of the Mozilla Root Store Policy (MSRP), version 2.7.1, to be published during of Q1-2021.
For audit delays, we currently require that audit statements disclose the locations that were and were not audited, but that requirement has not been incorporated yet into the MRSP. See https://wiki.mozilla.org/CA/Audit_Statements#Minimum_Expectations. That provision reads as follows: Disclose each location (at the state/province level) that was included in the scope of the audit or should have been included in the scope of the audit, whether the inspection was physically carried out in person at each location, and which audit criteria were checked (or not checked) at each location. - If the CA has more than one location in the same state/province, then use terminology to clarify the number of facilities in that state/province and whether or not all of them were audited. For example: "Facility 1 in Province", "Facility 2 in Province, Facility 3 in Province" *or* "Primary Facility in Province", "Secondary Facility in Province", "Tertiary Facility in Province". - The public audit statement does not need to identify the type of Facility. - "Facility" includes: data center locations, registration authority locations, where IT and business process controls of CA operations are performed, facility hosting an active HSM with CA private keys, facility or bank deposit box storing a deactivated and encrypted copy of a private key. It is proposed by Issue #207 <https://github.com/mozilla/pkipolicy/issues/207> that this language requiring the disclosure of site locations--audited and unaudited--be made clearly part of the MSRP by reference to the language above. A similar method of incorporating by reference has been taken in section 2.4 of the MSRP <https://www.mozilla.org/en-US/about/governance/policies/security-group/certs/policy/#24-incidents> with respect to incident reporting and in section 7.1 <https://www.mozilla.org/en-US/about/governance/policies/security-group/certs/policy/#71-inclusions> with requirements for the CA inclusion process. It is proposed that we add a new subsection 10 to MRSP section 3.1.4 <https://www.mozilla.org/en-US/about/governance/policies/security-group/certs/policy/#314-public-audit-information> that would require that audit documentation disclose the facility site locations that were, or were not, examined. One concern that has been raised previously is that the Baseline Requirements do not define "facility site location". However, we believe that the language above at https://wiki.mozilla.org/CA/Audit_Statements#Minimum_Expectations accomplishes that. We're open to suggestions for re-wording parts of it to make it even better. Currently, the audit letter template for WebTrust for CAs references the site location audited (at the level of specificity that is proposed above). Over this past year, due to COVID, some ETSI attestation letters have also explained which sites were and were not checked. This approach seems to work, and the additional information will be beneficial in the future as we evaluate the security and trust of PKI service providers. So, for the page cited above, we intend to move "Minimum Expectations" out from under "Audit Delay" so that it stands separately as a requirement for disclosing the facility site location. Then we will also revise MRSP section 3.1.4 by inserting a new subsection 10 to require "facility site locations that were, or were not, examined" with a hyperlink to the Minimum Expectations language cited above. We look forward to your comments and suggestions. Sincerely yours, Ben _______________________________________________ dev-security-policy mailing list dev-security-policy@lists.mozilla.org https://lists.mozilla.org/listinfo/dev-security-policy
