Hello,

We are seeking clarification on CCADB Policy Section 5.2 "Audit Statement 
Content" ( https://www.ccadb.org/policy#52-audit-statement-content 
<https://jpn01.safelinks.protection.outlook.com/?url=https%3A%2F%2Furldefense.com%2Fv3%2F__https%3A%2Fwww.ccadb.org%2Fpolicy*52-audit-statement-content__%3BIw!!N8Xdb1VRTUMlZeI!haCbfBmwmVzz7l3WYH3J-ACee3qt2I2oTwiEL6y7Pfo2lNTfcAaL1LxnsMxODGipyArxdFTl9rZZqXpMOIexcDzTmF02%24&data=05%7C02%7Cfumia-ono%40secom.co.jp%7C8c8da93451f149f97ef208ded666bd2a%7C06363084c30d488cb1cc6bc879220953%7C0%7C0%7C639183933937349492%7CUnknown%7CTWFpbGZsb3d8eyJFbXB0eU1hcGkiOnRydWUsIlYiOiIwLjAuMDAwMCIsIlAiOiJXaW4zMiIsIkFOIjoiTWFpbCIsIldUIjoyfQ%3D%3D%7C0%7C%7C%7C&sdata=BMgYFBp8cvsKQHqebYchEr0l9yBzQqaaVOQu4TP7h0o%3D&reserved=0>
 ), specifically regarding how incident disclosures should be presented in 
audit statements when both audited subordinate CAs and externally-operated 
subordinate CAs exist within the same root CA hierarchy.

As a starting point, we intend to separate the presentation of 
Bugzilla-reported incidents into two distinct categories within the root CA 
owner’s audit statement:


   - Incidents related to subordinate CAs that are included in the scope of 
   the root CA owner’s audit statement
   - Incidents related to externally-operated subordinate CAs that maintain 
   independent audit statements and are not included in the root CA owner’s 
   audit scope

This separation is intended to clearly distinguish audit scope, available 
audit evidence, and verification responsibility, while ensuring that all 
incidents disclosed by SECOM in Bugzilla are fully accounted for.

Under this presentation model, we are considering the following approach:

For subordinate CAs included in the root CA owner’s audit scope, the 
auditor will verify not only the existence of incidents but also the status 
and appropriateness of the Root Cause analysis and corresponding Action 
Items.

For externally-operated subordinate CAs outside the scope of the root CA 
owner’s audit, the auditor will rely on the independent audit statement 
issued for the subordinate CA. In such cases, that audit is expected to 
cover the Root Cause analysis and Action Items relating to both the 
externally-operated subordinate CA’s responsibilities and any relevant 
responsibilities attributable to the root CA owner.

However, within the root CA owner’s audit statement, the extent of 
verification for externally operated subordinate CAs may differ depending 
on the availability of audit evidence.

In such cases, verification of the Root Cause analysis and corresponding 
Action Items is performed based on available evidence within the root CA 
owner’s audit, while detailed verification is expected to be performed as 
part of the audit of the externally operated subordinate CA, in accordance 
with its independent audit scope.

This approach does not change the underlying responsibility model, but 
reflects how audit procedures are applied based on scope and available 
evidence.

In this way, all Bugzilla incidents disclosed by SECOM are included, while 
audit evidence and verification responsibilities are separated according to 
audit scope.

Additionally, even in cases where incidents related to externally-operated 
subordinate CAs are already covered by the subordinate CA’s independent 
audit statement, we consider that including those incidents in the root CA 
owner’s audit statement (i.e., duplicating the disclosure) would not 
present compliance concerns and may enhance overall transparency.

We would appreciate the community’s feedback on the following specific 
points:
1. Whether separating incident disclosure based on audit scope (i.e., 
in-scope vs. out-of-scope subordinate CAs) is acceptable under CCADB Policy 
Section 5.2 
2. Whether including incidents related to externally operated subordinate 
CAs in the root CA owner’s audit statement, even when those incidents are 
already covered in the subordinate CA’s independent audit statement (i.e., 
duplication of disclosure), is considered acceptable or preferred from a 
compliance and transparency perspective.

Best regards,

ONO Fumiaki / 大野 文彰
(Japanese name order: family name first, in uppercase)
SECOM Trust Systems CO., LTD.

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