As I implied in my previous message about the KISA request for inclusion 
of its roots, government CAs can pose special problems in the context of 
our current Mozilla CA policy, and I wanted to take the opportunity to 
discuss the topic briefly, since we may want to consider future changes 
to our policy to address these.

Some government CAs undergo truly independent audits, e.g., by getting 
WebTrust for CAs audits using WebTrust-certified auditors. (I think the 
government of Taiwan did this, for example.) However in many countries 
the government CA is audited by a separate agency of government; this is 
the case in South Korea (where MIC is the auditor of KISA) and 
elsewhere. Furthermore, some of these audits (including KISA's) are 
based on laws and regulations specific to the country in question, as 
opposed to being based on globally-applicable criteria like WebTrust, 
ETSI 101 456, etc.

This causes more work for us (because we have to investigate each 
country's practices individually) and also raises questions about 
governments auditing themselves.

In its new policy for its root program

http://www.microsoft.com/technet/archive/security/news/rootcert.mspx?mfr=true

Microsoft has taken an interesting approach to this problem, one that I 
think is worth discussing:

"[F]or government CAs who issue certificates to secure government to 
government or citizen to government transactions, Microsoft will accept 
a statement from a government or private party auditor attesting to the 
CA’s audit status, giving the name of and reference to their audit 
guidelines, the date of the last audit, and equivalence of their audit 
criteria to the Operating Standards (e.g. WebTrust For CAs, ETSI TS 102 
042, ETSI 101 456, ISO 21188)."

Should we think about adopting similar language in a future policy 
revision? I'll give my own thoughts about this in a subsequent message, 
but I'll pause here to let others comment.

Frank

-- 
Frank Hecker
[EMAIL PROTECTED]
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