Re: Certigna Root Inclusion Request Round 2

2009-03-17 Thread Kathleen Wilson
Many thanks to those of you who have participated in the discussions
for this root inclusion request, and reviewed the information that has
been provided.

Certigna met the request from the first round of public discussion to
post and translate the relevant portions of their CPS. During the
discussions two items have been requested:
1) The public portion of the Certigna CPS should be made public and
posted on their website.
2) The internal document for code signing should be made part of the
CPS.
While Certigna is encouraged to do these two action items, these will
not block the inclusion request.

This concludes the public discussions about Certigna’s request to add
one new root CA certificate to the Mozilla root store, as documented
in the following bug:

https://bugzilla.mozilla.org/show_bug.cgi?id=393166

I will post a summary of the request and my recommendation for
approval in the bug.
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Re: Certigna Root Inclusion Request Round 2

2009-03-13 Thread Kathleen Wilson
Certigna met our request to post and translate the relevant portions
of their CPS. There has been very little resulting discussion.

Are there still questions that need to be addressed in this public
discussion phase? Or shall I move forward with making the
recommendation to approve this request?
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Re: Certigna Root Inclusion Request Round 2

2009-03-13 Thread Eddy Nigg

On 03/13/2009 07:34 PM, Kathleen Wilson:

Certigna met our request to post and translate the relevant portions
of their CPS. There has been very little resulting discussion.

Are there still questions that need to be addressed in this public
discussion phase? Or shall I move forward with making the
recommendation to approve this request?


The internal document for code signing should have been made part of the 
CP/CPS. Apart from that I've not seen anything of concern.


Unfortunately my knowledge in the French language is not sufficient 
enough in order to understand the CPS. Preferable we should be able to 
review (and understand) the CPS in its entirety, however I don't feel 
this to be a reason at this stage to question their inclusion after they 
complied to our requests from the first round.


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Re: Certigna Root Inclusion Request Round 2

2009-03-10 Thread Eddy Nigg

On 03/03/2009 11:35 PM, kathleen95...@yahoo.com:

The relevant, public portion of their CPS has been attached to the
bug:
https://bugzilla.mozilla.org/attachment.cgi?id=364343

Translations of portions of this document have also been attached to
the bug:
https://bugzilla.mozilla.org/attachment.cgi?id=364146


As a by-note I'd like to state that that ETSI 101 456 and ETSI TS 102 
042 speak very clearly about The CA shall make available to subscribers 
and relying parties its certification practice statement, and other 
relevant documentation, as necessary to assess conformance to the 
qualified certificate policy.


As such Certigna is not complying to the audit criteria it chose!


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Re: Certigna Root Inclusion Request Round 2

2009-03-10 Thread Ian G

On 10/3/09 09:22, Eddy Nigg wrote:

On 03/03/2009 11:35 PM, kathleen95...@yahoo.com:


Kathleen,

are we planning to move the discussions of accepting CAs into the root 
list over to the other list?  I think that dev-security-policy is going now?


iang
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Re: Certigna Root Inclusion Request Round 2

2009-03-10 Thread Kathleen Wilson
 are we planning to move the discussions of accepting CAs into the root
 list over to the other list?  I think that dev-security-policy is going now?

OK.  If no one objects, I will post all future root inclusion request
discussions on mozilla.dev.security.policy instead of
dev.tech.crypto.

Kathleen

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Re: Certigna Root Inclusion Request Round 2

2009-03-10 Thread Kyle Hamilton
I second this motion, no objections.

-Kyle H

On Tue, Mar 10, 2009 at 10:48 AM, Kathleen Wilson
kathleen95...@yahoo.com wrote:
 are we planning to move the discussions of accepting CAs into the root
 list over to the other list?  I think that dev-security-policy is going now?

 OK.  If no one objects, I will post all future root inclusion request
 discussions on mozilla.dev.security.policy instead of
 dev.tech.crypto.

 Kathleen

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Re: Certigna Root Inclusion Request Round 2

2009-03-10 Thread Nelson B Bolyard
Kyle Hamilton wrote, On 2009-03-10 14:14:
 I second this motion, no objections.
 
 -Kyle H
 
 On Tue, Mar 10, 2009 at 10:48 AM, Kathleen Wilson
 kathleen95...@yahoo.com wrote:
 are we planning to move the discussions of accepting CAs into the root
 list over to the other list?  I think that dev-security-policy is going now?
 OK.  If no one objects, I will post all future root inclusion request
 discussions on mozilla.dev.security.policy instead of
 dev.tech.crypto.

 Kathleen

Me too.  I'll bet there are some web pages that need to be updated to
point to the new list instead of the crypto list.
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Re: Certigna Root Inclusion Request Round 2

2009-03-03 Thread Kyle Hamilton
On Tue, Mar 3, 2009 at 1:35 PM,  kathleen95...@yahoo.com wrote:
 Email:  CPS section 5.2.6 specifies the controls for applications for
 the Certigna ID certificates. It says that in addition to verifying
 the identity of the applicant, they check the email address as follows
 as per the supplied translation:
 “On left part of the email address, we have to found, in a non
 equivoque form, the name and the first name of the future bearer. In
 the opposite case, and in case of a doubt on the intention of
 usurpation, it is important to report that at the security responsible
 who will defined the actions to make (exhaustive check of the order,
 reject or acceptation).
 On the right part of the email address is located the name of the web
 site of the entity or the name of a FAI (and name of another entity).”

I'll be so bold as to try to translate this into better English (this
is obviously NOT to be considered authoritative):

The left-hand side of the email address must contain both the first
and last name of the person in order to pass the automatic issuance
procedure [[NB: this is due to the word 'and' in the translation; I
would assume that it should actually be an 'or', and the email address
has to at least be the last name of the subscriber]].  If the
left-hand side of the email address does not contain the first and[or]
last name of the person, then it gets passed up the line for manual
review.  [[NB: the mechanism for manual review is not defined, but
allows for a more exhaustive verification, automatic denial (such as
'georgewb...@thisisnottheofficialbushdomain.com', I presume), or
immediate acceptance (under some unknown criteria).]]

On the right-hand side (sitename) part of the email address must be
either the name of the web site [[NB: this suggests that it must be,
for example, 'hec...@www.mozillafoundation.org' instead of
'hec...@mozillafoundation.org']], or the name of a [[??What is an
FAI??]] and another entity.  [[NB: presumably 'gmail.com' would be the
'name of another entity', but I'm still unable to parse this
sentence.]]

To Certigna: I am very sorry if I have mangled the meaning of your CPS
through the apparently-automated translation.

 This begins phase 2 of the public discussion of the request from
 Certigna to add the Certigna CA root certificate to Mozilla.

Thank you, Kathleen.  (And thank you, Frank, for getting Mozilla to
hire her. :))

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Re: Certigna Root Inclusion Request

2009-02-16 Thread Yannick LEPLARD



Le 14 févr. 09 à 15:09, Frank Hecker a écrit :


Yannick LEPLARD wrote:
Another alternative is to publish just those portions of the CPS  
that address the question of email verification, and have your  
auditor confirm to us that the section(s) in question are from the  
CPS that was referenced in your audit.


Frank
This is a good alternative for us. If everybody agree with, we can  
send you the fair portion of CPS in english and our auditor will  
confirm you the genuineness of the document.


To repeat what I wrote elsewhere: This plan is acceptable to us.
Fran



We are working on the translation and we make contact with the auditor.
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Re: Certigna Root Inclusion Request

2009-02-14 Thread Frank Hecker

Yannick LEPLARD wrote:
Another alternative is to publish just those portions of the CPS that 
address the question of email verification, and have your auditor 
confirm to us that the section(s) in question are from the CPS that 
was referenced in your audit.


Frank


This is a good alternative for us. If everybody agree with, we can send 
you the fair portion of CPS in english and our auditor will confirm you 
the genuineness of the document.


To repeat what I wrote elsewhere: This plan is acceptable to us.
Fran

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Re: Certigna Root Inclusion Request

2009-02-12 Thread Yannick LEPLARD
First of all, i would like to express my astonishment about the  
discussion phase.
It sounds like Mozilla's discussion how to evaluate the CAs /   
changes to do in the benchmarks  rather than a Certigna discussion.


We asked for inclusion in Mozilla on 2007 (august).
Mozilla agrees with ETSI 102 042 (like Apple and Microsoft. We are in  
these two systems).

There was a long technical verification phase made by three people :
Gervase Markham, Frank Hecker, and Kathleen Wilson.
And now, it seems to be a reconsideration of ETSI 102 042.

About CP /CPS :
I think a public CP and a audit of compliance with a reference norm  
(like ETSI, WebTrust, ... ) provide garantees to third party.
CPS and other internal documents are checked by auditors (and they  
control that the company do what is written !).
They contain know-how of the company (technical and organizational  
measurements), and don't have to be published.


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Re: Certigna Root Inclusion Request

2009-02-12 Thread Eddy Nigg

On 02/12/2009 12:31 PM, Yannick LEPLARD:

First of all, i would like to express my astonishment about the
discussion phase.
It sounds like Mozilla's discussion how to evaluate the CAs / changes
to do in the benchmarks  rather than a Certigna discussion.


Yes, unfortunately we make the mistake again and again by not changing 
the subject line when discussing (un)related issues. However this is a 
discussion group as compared to Bugzilla.



There was a long technical verification phase made by three people :
Gervase Markham, Frank Hecker, and Kathleen Wilson.
And now, it seems to be a reconsideration of ETSI 102 042.


No, only Kathleen has reviewed and gathered the information about your 
CA. Unfortunately there was a backlog which Mozilla is now working up.


The issue at hand is not the audit criteria of ETSI per se, but the 
disclosure of your practices. I think this is the first time that a CA 
wasn't willing to disclose the practice statement.




About CP /CPS :
I think a public CP and a audit of compliance with a reference norm
(like ETSI, WebTrust, ... ) provide garantees to third party.
CPS and other internal documents are checked by auditors (and they
control that the company do what is written !).


Right, and in order to judge what your CA is doing we would like to know 
about it. Please note that WebTrust requires public disclosure of the 
practices.



They contain know-how of the company (technical and organizational
measurements), and don't have to be published.


Well, considering that the top 20 CAs all disclosed their practices, I 
can't see which know-how you are trying to protect, but if you are doing 
something completly different than all the others than it's perhaps 
reason more to know about it.


Please also note that ETSI doesn't require particular validation methods 
upon which we can be assumed that you are compliant to the Mozilla CA 
policy. And I really wonder if you didn't had to disclose the CPS to 
Microsoft as well.



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Re: Certigna Root Inclusion Request

2009-02-12 Thread Frank Hecker

Eddy Nigg wrote:

On 02/11/2009 07:19 PM, Yannick LEPLARD:

So What should we do ?
Should we ask our auditor a certified document about our practices for
e-mail validation ?


Yannick, what are the chances to publish the CPS? Please note that all 
CAs which have been included into Mozilla NSS during the last few years 
published their CPS, this is common practice.


To add to Eddy's question: If there is Certigna-confidential information 
in the CPS that is not relevant to the questions we have, you could 
publish a version of the CPS with the confidential material redacted [1].


Another alternative is to publish just those portions of the CPS that 
address the question of email verification, and have your auditor 
confirm to us that the section(s) in question are from the CPS that was 
referenced in your audit.


Frank

[1] For anyone interested, the US National Security Agency has published 
a useful set of guidelines for how to properly redact Microsoft Work 
documents published as PDF files:


  http://www.fas.org/sgp/othergov/dod/nsa-redact.pdf


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Re: Certigna Root Inclusion Request

2009-02-12 Thread Yannick LEPLARD


Another alternative is to publish just those portions of the CPS  
that address the question of email verification, and have your  
auditor confirm to us that the section(s) in question are from the  
CPS that was referenced in your audit.


Frank


This is a good alternative for us. If everybody agree with, we can  
send you the fair portion of CPS in english and our auditor will  
confirm you the genuineness of the document.


( I think our CPS is not very different from others, but it refers to  
a lot of internal documents. )



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Re: Certigna Root Inclusion Request

2009-02-12 Thread Eddy Nigg

On 02/12/2009 05:13 PM, Yannick LEPLARD:


This is a good alternative for us. If everybody agree with, we can send
you the fair portion of CPS in english and our auditor will confirm you
the genuineness of the document.



In my opinion this would solve the problem. I would like to request that 
the auditor confirms that their audit statement confirms the exact 
extracts of the CPS. I also would like to request to include all 
relevant bits for domain control validation in addition to email. 
Additionally if code signing was part of the CPS during your audit, also 
the bits relating to code signing.


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Re: Certigna Root Inclusion Request

2009-02-11 Thread Eddy Nigg

On 02/11/2009 06:20 AM, Frank Hecker:

Ian G wrote:

The policy says, we need published information, *eg* the CPS.

Not, CPS must be published.


Yes, exactly. We typically use the CPS and/or CP because almost all CAs
publish those documents; however there is no requirement that the
information published by the CA be in the form of a CPS or CP.


But it must have relevance to what was audited, no? If the document 
wasn't an official and binding part of the audit, it shouldn't be used 
in this context either I think. Nor shouldn't it be provided and 
published after the audit was performed.




Speaking personally, I think think that it is good practice for CAs to
publish a CPS. If a CA has private information relating to detailed
internal processes that it does not wish to make public, I suggest that
it put such material in a separate CA operations manual that is
internal-only.


That's of course what CAs usually do. They disclose those procedures to 
the auditor, but not publicly. WebTrust has a defined set of criterion 
about what exactly needs to be disclosed publicly. In this respect I 
question the usefulness of the ETSI audit criteria and I 
suggest/recommend to make the publishing of the CPS a requirement in the 
Mozilla CA policy. I assumed wrongly that this is a requirement by the 
audit criterion which Mozilla accepts.



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Re: Certigna Root Inclusion Request

2009-02-11 Thread Frank Hecker

Eddy Nigg wrote:
Well no, than any CA can write whatever it feels in such a document 
which would be entirely non-binding and not audited.


Yes in theory, but I'm not convinced that this is a real risk in 
practice. In the past we've had several cases where we've accepted 
public statements by CAs that went beyond what was in their CPS or CP. 
In some cases these were clarifications of CP/CPS langusge, in other 
cases they covered stuff that was not in the CP or CPS at all. In a 
number of cases the CAs updated (or committed to update) their CP/CPS to 
reflect their supplementary statements, and for purposes of our 
evaluation we accepted the statements in advance of their actually 
completing an audit against the new CPS.


So, again, I'm not prepared to make a blanket statement that we must 
always have a published CPS and cannot rely on documents apart from the CPS.


Frank

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Re: Certigna Root Inclusion Request

2009-02-11 Thread Eddy Nigg

On 02/11/2009 04:12 PM, Frank Hecker:

Yes in theory, but I'm not convinced that this is a real risk in
practice. In the past we've had several cases where we've accepted
public statements by CAs that went beyond what was in their CPS or CP.
In some cases these were clarifications of CP/CPS langusge, in other
cases they covered stuff that was not in the CP or CPS at all.


Clarifications I think yes. Something which isn't in the CPS must be 
easily verifiable, something critical and not covered in the CPS is in 
my opinion not sufficient.



In a
number of cases the CAs updated (or committed to update) their CP/CPS to
reflect their supplementary statements, and for purposes of our
evaluation we accepted the statements in advance of their actually
completing an audit against the new CPS.


Yes, also this is in my opinion sufficient, but there are some problems. 
First Mozilla hasn't been on record to follow up - neither on EV nor on 
other matters. Second we need to draw a clear line here...I believe that 
CAs weren't approved generally if they couldn't demonstrate clearly 
through their published CPS and audit statements compliance to the 
Mozilla CA policy. Some CAs were sent back to the drawing board for 
fixing. I believe this case isn't any different.




So, again, I'm not prepared to make a blanket statement that we must
always have a published CPS and cannot rely on documents apart from the
CPS.



Yes, everything within reasons. But that should be established during 
information gathering and perhaps receive your approval prior to 
arriving here. It should be disclosed during the presentation statement 
at the list and such a document shouldn't be provided AFTER it gets to 
the comments and review week here. This clearly means, there is no audit 
behind it, it would be just hot air.


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Re: Certigna Root Inclusion Request

2009-02-11 Thread Ian G

On 11/2/09 05:20, Frank Hecker wrote:

Ian G wrote:

The policy says, we need published information, *eg* the CPS.

Not, CPS must be published.


Yes, exactly. We typically use the CPS and/or CP because almost all CAs
publish those documents; however there is no requirement that the
information published by the CA be in the form of a CPS or CP.

Speaking personally, I think think that it is good practice for CAs to
publish a CPS. If a CA has private information relating to detailed
internal processes that it does not wish to make public, I suggest that
it put such material in a separate CA operations manual that is
internal-only.



OK, I made some changes on the wiki and added these words:

https://wiki.mozilla.org/CA:Recommended_Practices#Recommended_practices

  #   (we rely on public documents only).
  # If you do not publish the CP/CPS (not recommended), you will need 
to publish an extract that summarizes the portions that are of most 
interest to us.



This only reflects my understanding of the situation.  Also, I recognise 
that the words on the wiki already almost nailed it, so we are in danger 
of bureaucratic freefall...  Hack away...


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Re: Certigna Root Inclusion Request

2009-02-11 Thread David E. Ross
On 2/10/2009 8:16 PM, Frank Hecker wrote:
 David E. Ross wrote:
 On 2/10/2009 12:06 PM, Frank Hecker wrote:
 If you cannot publish the CPS because it contains private information, I 
 suggest as an alternative that you provide some sort of official 
 Certigna document that summarizes the portions of the CPS that are of 
 most interest to us (i.e., those relating to validation of subcriber 
 information).
 snip
 However, not only should they provide some alternative documentation but
 also that documentation should be considered during the required audit.
 
 My assumption was that if the material in the document was based on the 
 CPS then it would have been covered in the audit, since presumably the 
 audit was based on what was in the CPS.
 
 Frank

If the information is critical for determining whether a CA's root
should be in the certificate store, then the document should be audited.
 In the case at hand, the issue is whether the root should be enabled
for E-mail validation.  Because that issue is addressed in the CPS,
which we cannot see, we don't have any way to judge if the E-mail bit
should be enabled.

With an unaudited supplemental document, we would have no assurance that
Certigna operates in compliance with that document.  We should either
see an audit statement for the supplemental document or a certification
from the auditor or other trusted outside party that the document
substantially echoes the audited CPS.

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Re: Certigna Root Inclusion Request

2009-02-11 Thread David E. Ross
On 2/11/2009 8:43 AM, Ian G wrote:
 On 11/2/09 05:20, Frank Hecker wrote:
 Ian G wrote:
 The policy says, we need published information, *eg* the CPS.

 Not, CPS must be published.
 Yes, exactly. We typically use the CPS and/or CP because almost all CAs
 publish those documents; however there is no requirement that the
 information published by the CA be in the form of a CPS or CP.

 Speaking personally, I think think that it is good practice for CAs to
 publish a CPS. If a CA has private information relating to detailed
 internal processes that it does not wish to make public, I suggest that
 it put such material in a separate CA operations manual that is
 internal-only.
 
 
 OK, I made some changes on the wiki and added these words:
 
 https://wiki.mozilla.org/CA:Recommended_Practices#Recommended_practices
 
#   (we rely on public documents only).
# If you do not publish the CP/CPS (not recommended), you will need 
 to publish an extract that summarizes the portions that are of most 
 interest to us.
 
 
 This only reflects my understanding of the situation.  Also, I recognise 
 that the words on the wiki already almost nailed it, so we are in danger 
 of bureaucratic freefall...  Hack away...
 
 iang

This would then tie into the later section:

*  CAs should supply evidence of their being evaluated according to one
or more of the criteria accepted as suitable per the Mozilla policy.
 . . .
*  All documents supplied as evidence should be publicly
   available.

However, the last sentence should be modified to say:

*  All documents supplied as evidence should be publicly available and
must be addressed in any audit.

I don't have (don't want) an account to update the Wiki.

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Re: Certigna Root Inclusion Request

2009-02-11 Thread Yannick LEPLARD


If the information is critical for determining whether a CA's root
should be in the certificate store, then the document should be  
audited.

In the case at hand, the issue is whether the root should be enabled
for E-mail validation.  Because that issue is addressed in the CPS,
which we cannot see, we don't have any way to judge if the E-mail bit
should be enabled.

With an unaudited supplemental document, we would have no assurance  
that

Certigna operates in compliance with that document.  We should either
see an audit statement for the supplemental document or a  
certification

from the auditor or other trusted outside party that the document
substantially echoes the audited CPS.

--



So What should we do ?
Should we ask our auditor a certified document about our practices for  
e-mail validation ?


Yannick LEPLARD
Directeur RD
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Re: Certigna Root Inclusion Request

2009-02-11 Thread Eddy Nigg

On 02/11/2009 07:12 PM, David E. Ross:

However, the last sentence should be modified to say:

*  All documents supplied as evidence should be publicly available and
must be addressed in any audit.

I don't have (don't want) an account to update the Wiki.



I agree on this definition. Is there anybody objecting to it? (I can 
update the page accordingly).


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Re: Certigna Root Inclusion Request

2009-02-11 Thread Eddy Nigg

On 02/11/2009 07:19 PM, Yannick LEPLARD:

So What should we do ?
Should we ask our auditor a certified document about our practices for
e-mail validation ?


Yannick, what are the chances to publish the CPS? Please note that all 
CAs which have been included into Mozilla NSS during the last few years 
published their CPS, this is common practice.


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Re: Certigna Root Inclusion Request

2009-02-11 Thread Ian G

On 11/2/09 21:29, Eddy Nigg wrote:

On 02/11/2009 07:12 PM, David E. Ross:

However, the last sentence should be modified to say:

* All documents supplied as evidence should be publicly available and
must be addressed in any audit.

I don't have (don't want) an account to update the Wiki.



I agree on this definition. Is there anybody objecting to it? (I can
update the page accordingly).




I object.

All documents supplied to Mozilla is within a Mozilla context.

Audit does an audit context.  The two are different.  Don't mix them; 
most all audits are done according to defined audit criteria, such as 
WebTrust or ETSI or DRC.


Asking an auditor to sign off on random documents that have nothing to 
do with the criteria, the audit world and the direct process raises 
questions.  I would claim that no (or few) auditors to date has been 
asked to verify a CA according to Mozilla review.


If you want evidence quality documents then ask for a notary?

iang



PS: I for one would definately champion rewriting the WebTrust process 
but this is not the way to do it.

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Re: Certigna Root Inclusion Request

2009-02-11 Thread Kyle Hamilton
A notary does not verify content, a notary verifies identity.

What we need is an opinion (hey!  using your own terminology, Ian,
that means AUDIT, and thus AUDITOR) that the document substantially
reflects the CP/CPS.  If not an auditor, who would you suggest to do
it, given that a notary isn't authoritative for opinions other than on
the signer having shown identity?

I think the entire CA approval process is completely FUBARed.  I think
Mozilla has managed to paint itself into a corner from which people
like Ian will not let it escape, and has thus been bullied and
intimidated into accepting things into its root program that are
analytically damaging to the PKI and the pursuit of commerce to be
enabled by it.  I also believe that it has allowed commerce to
define its operations and criteria for far too long.

-Kyle H

On Wed, Feb 11, 2009 at 3:37 PM, Ian G i...@iang.org wrote:
 On 11/2/09 21:29, Eddy Nigg wrote:

 On 02/11/2009 07:12 PM, David E. Ross:

 However, the last sentence should be modified to say:

 * All documents supplied as evidence should be publicly available and
 must be addressed in any audit.

 I don't have (don't want) an account to update the Wiki.


 I agree on this definition. Is there anybody objecting to it? (I can
 update the page accordingly).



 I object.

 All documents supplied to Mozilla is within a Mozilla context.

 Audit does an audit context.  The two are different.  Don't mix them; most
 all audits are done according to defined audit criteria, such as WebTrust or
 ETSI or DRC.

 Asking an auditor to sign off on random documents that have nothing to do
 with the criteria, the audit world and the direct process raises questions.
  I would claim that no (or few) auditors to date has been asked to verify a
 CA according to Mozilla review.

 If you want evidence quality documents then ask for a notary?

 iang



 PS: I for one would definately champion rewriting the WebTrust process but
 this is not the way to do it.
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Re: Certigna Root Inclusion Request

2009-02-11 Thread Eddy Nigg

On 02/12/2009 01:37 AM, Ian G:

I object.


OK, then back to square one.



All documents supplied to Mozilla is within a Mozilla context.


Huuu?



Audit does an audit context. The two are different. Don't mix them; most
all audits are done according to defined audit criteria, such as
WebTrust or ETSI or DRC.


Yes, and Mozilla relies on them, period.



Asking an auditor to sign off on random documents that have nothing to
do with the criteria, the audit world and the direct process raises
questions.


Right, that's why CAs MUST publish their CPS.


I would claim that no (or few) auditors to date has been
asked to verify a CA according to Mozilla review.


Not Mozilla Review, but if we want to facilitate other documents 
beyond CSP than I have no problem accepting them if an auditor agrees to 
confirm those documents. It's really not our problem.




If you want evidence quality documents then ask for a notary?


No, what has that to do with it?



PS: I for one would definately champion rewriting the WebTrust process
but this is not the way to do it.


PS: PS: Why not? Go for it. Talk to them.


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Re: Certigna Root Inclusion Request

2009-02-11 Thread Ian G

On 12/2/09 00:58, Kyle Hamilton wrote:

A notary does not verify content, a notary verifies identity.


Actually I meant a notary rather than a notary public, but the
difference is moot.



What we need is an opinion (hey!  using your own terminology, Ian,
that means AUDIT, and thus AUDITOR) that the document substantially
reflects the CP/CPS.  If not an auditor, who would you suggest to do
it, given that a notary isn't authoritative for opinions other than
on the signer having shown identity?



Right, that's on the other point.  It would be entirely valid to ask for
the AUDITOR to attest (or otherwise) that the extract substantially or
otherwise reflected the CPS, *iff* one were that concerned.

(I would not be that paranoid, and I claim you will get a better system
if you don't demand a priori audit opinion over this document.  The
ground breaking work in this was done by Rothschild  Stiglitz, 1976,
and the latter shared in the nobel prize awarded for asymmetric markets
for the consequent rewriting of two industries around their work on
declarations.)

However, the statement originally suggested goes far further, it says
*all documents*.



I think the entire CA approval process is completely FUBARed.



Well, Ok, we may share some drinks on that.  I'd prefer to say it is a
good starting point for a better system, but your more blunt description
will win you more friends !


I think Mozilla has managed to paint itself into a corner from which
people like Ian will not let it escape, and has thus been bullied
and intimidated into accepting things into its root program that are
analytically damaging to the PKI and the pursuit of commerce to be
enabled by it.  I also believe that it has allowed commerce to
define its operations and criteria for far too long.



I'd agree with ... some of that :)  I also wonder what you mean by
commerce ... but more drinks required.

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Re: Certigna Root Inclusion Request

2009-02-11 Thread Ian G

On 12/2/09 01:17, Eddy Nigg wrote:

On 02/12/2009 01:37 AM, Ian G:



Audit does an audit context. The two are different. Don't mix them; most
all audits are done according to defined audit criteria, such as
WebTrust or ETSI or DRC.


Yes, and Mozilla relies on them, period.



Yes, it's just another relying party to an audit opinion, just like any 
other user.  This means it gets to read the opinion.


It doesn't get to stipulate any conditions.  (Maybe it should, that's 
another story.)  Imagining conditions doesn't help.




Asking an auditor to sign off on random documents that have nothing to
do with the criteria, the audit world and the direct process raises
questions.


Right, that's why CAs MUST publish their CPS.



I agree this whole thing would go away if all CAs published their CPSs. 
 But reasons have been outlined why this is not the case, and Mozilla 
(/Frank) has decided that's OK.


It's their review, as you mentioned above.



I would claim that no (or few) auditors to date has been
asked to verify a CA according to Mozilla review.


Not Mozilla Review, but if we want to facilitate other documents
beyond CSP than I have no problem accepting them if an auditor agrees to
confirm those documents. It's really not our problem.



Well, that depends on our metrics of success and efficiency.  For my 
part, I think it good to hold down costs and only add burden where there 
is a commensurate benefit.


If a CA provides a document, there is no commensurate benefit in asking 
the auditor to play notary for them.  Indeed, there is a benefit in 
asking them to provide documents as is knowing that a future auditor 
can read the submissions and verify the claims made.  And, as those 
provided documents are there and form part of the public record, there 
is plenty of scope for later verification.




PS: I for one would definately champion rewriting the WebTrust process
but this is not the way to do it.


PS: PS: Why not? Go for it. Talk to them.




lol I see you also have a copy of OSS's sabotage manual :)


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Re: Certigna Root Inclusion Request

2009-02-11 Thread Eddy Nigg

On 02/12/2009 01:58 AM, Kyle Hamilton:

...and has thus been bullied and
intimidated into accepting things into its root program that are
analytically damaging to the PKI


I believe - and that's another reason why I'm here, that this can be 
reversed and improved. It requires some work and we've came already 
close in the past to actually achieve some results.



enabled by it.  I also believe that it has allowed commerce to
define its operations and criteria for far too long.


Commerce or not, here is another interesting one: 
https://bugzilla.mozilla.org/show_bug.cgi?id=477783


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Re: Certigna Root Inclusion Request

2009-02-10 Thread Yannick LEPLARD
Le 9 févr. 09 à 20:54, Eddy Nigg a écrit :On 02/09/2009 09:35 PM,kathleen95...@yahoo.com:Of course. I will await your next post to this discussion.Just browsing through the various documents and I noticed the following so far.It seems to me that the code signing bit *should not* be activated, it should be reflected in the "Pending" page as well.The initial comment was written on august 2008, and now we have code signingcertificates, and it appears in our CP/CPS.Email validation seems to me ambiguous at least and apparently not defined in their CP/CPS. Neither is domain ownership/control validation defined as I understand.Yes it is not defined in our CP but in our internal operational processesand in our CPS too.Unfortunately, CPS are not published (they described internal technical andorganizational measurements)RA operators must obtain guarantee than the e-mail address is owned by therequester.It's difficult in fact to make such controls. In practice the name of therequester must appear in the left part of the e-mail address... If not, RAoperators are likely to get proof of possession (the request can be rejectedin case of doubt). For employees it's easier : the name of the suscriber anddomain name of the company can be easily checked.It's the same for domain ownership/control :RA operators verify the names of owner, administrator... in databases (like whois).They visit the website to look at the content, and the request can be rejected if any doubt.Repeated requests for translating the relevant parts have not been complied. Comments in this respect (bug 393166, comment 15, d) ) have no relevance to the question asked and your questions in comment 13 have partly not been answered, in particular 2.d. Besides a general denial in regards of problematic practices, no details have been provided.-Our DV SSL certificates have maximum expiration time of 3 years in thefuture.- Software private keys are generated on the suscriber computer with asigned applet- When the suscriber is using a smartcard, the private key is generatedonboard.In particular I couldn't find out for how long their certificates are valid and how S/MIME certificates are provided to the subscriber ("We send the certificate to the subscriber by mail").- Certificates are valid 1, 2 or 3 years.- S/MIME certificates are provided to the suscriber by email (not mail,sorry). the suscriber must agree with the certificate and send a returnreceipt with certificate eacceptance.There is a signed applet for the suscriber to ask for a certificate, and toinstall the issued certificate.Overall I think there is very little information available about this CA (in English) and I'm hesitant to continue without a more thorough review of critical aspects.We are at the same level than the DCSSI CA that was approved a few days ago.On february 2009, the 5th, we obtain the compliance with PRIS/RGS for ourCAs ( and our CP, CPS are compliant with the exemplifications CP/CPS ofhttp://www.mozilla.org/projects/security/certs/pending/#DCSSI)( cf :http://www.references.modernisation.gouv.fr/outil-de-suivi-des-qualifications-et-des-referencements-des-offres-de-certificats)Mr Bouchet from LSTI is the lead auditor mandated by the french government for the ETSI and PRIS/RGS audits.If case of doubt about our practices, you can obtain more informations from himHis phone number is : +33 1 30 61 50 60--RegardsYannick LEPLARDDirecteur RD20, allée de la râperie59650 Villeneuve d'Ascqtél. : 03 20 79 24 09fax. : 03 20 34 20 52www.dhimyotis.frCe mail est signé électroniquement grâce à un certificat Certigna. Il a valeur légale.Pour plus d'informations, rendez-vous surwww.certigna.fr.--
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Re: Certigna Root Inclusion Request

2009-02-10 Thread David E. Ross
On 2/10/2009 6:25 AM, Yannick LEPLARD wrote:
 
 Le 9 févr. 09 à 20:54, Eddy Nigg a écrit :
 
 On 02/09/2009 09:35 PM, kathleen95...@yahoo.com 
 mailto:kathleen95...@yahoo.com:
 Of course. I will await your next post to this discussion.


 Just browsing through the various documents and I noticed the following so 
 far.

 It seems to me that the code signing bit *should not* be activated, it 
 should 
 be reflected in the Pending page as well.
 
 The initial comment was written on august 2008, and now we have code signing
 certificates, and it appears in our CP/CPS.
 


 Email validation seems to me ambiguous at least and apparently not defined 
 in 
 their CP/CPS. Neither is domain ownership/control validation defined as I 
 understand.
 
 Yes it is not defined in our CP but in our internal operational processes
 and in our CPS too.
 Unfortunately, CPS are not published (they described internal technical and
 organizational measurements)
 RA operators must obtain guarantee than the e-mail address is owned by the
 requester.
 It's difficult in fact to make such controls. In practice the name of the
 requester must appear in the left part of the e-mail address... If not, RA
 operators are likely to get proof of possession (the request can be rejected
 in case of doubt). For employees it's easier : the name of the suscriber and
 domain name of the company can be easily checked.
 
 It's the same for domain ownership/control : 
 RA operators verify the names of owner, administrator... in databases (like 
 whois).
 They visit the website to look at the content, and the request can be 
 rejected 
 if any doubt.
 


 Repeated requests for translating the relevant parts have not been complied. 
 Comments in this respect (bug 393166, comment 15, d) ) have no relevance to 
 the question asked and your questions in comment 13 have partly not been 
 answered, in particular 2.d. Besides a general denial in regards of 
 problematic practices, no details have been provided.
 
 - Our DV SSL certificates have maximum expiration time of 3 years in the
 future.
 
 - Software private keys are generated on the suscriber computer with a
 signed applet
 - When the suscriber is using a smartcard, the private key is generated
 onboard.
 
 
 In particular I couldn't find out for how long their certificates are valid 
 and how S/MIME certificates are provided to the subscriber (We send the 
 certificate to the subscriber by mail).
 
 - Certificates are valid 1, 2 or 3 years.
 
 - S/MIME certificates are provided to the suscriber by email (not mail,
 sorry). the suscriber must agree with the certificate and send a return
 receipt with certificate eacceptance.
 There is a signed applet for the suscriber to ask for a certificate, and to
 install the issued certificate.
 


 Overall I think there is very little information available about this CA (in 
 English) and I'm hesitant to continue without a more thorough review of 
 critical aspects.
 
 We are at the same level than the DCSSI CA that was approved a few days ago.
 On february 2009, the 5th, we obtain the compliance with PRIS/RGS for our
 CAs ( and our CP, CPS  are compliant with the exemplifications CP/CPS  of
 http://www.mozilla.org/projects/security/certs/pending/#DCSSI
  )
 
 ( cf :
 http://www.references.modernisation.gouv.fr/outil-de-suivi-des-qualification
 s-et-des-referencements-des-offres-de-certificats
  )
 
 
 Mr Bouchet from LSTI is the lead auditor mandated by the french government 
 for 
 the ETSI and PRIS/RGS audits.
 If case of doubt about our practices, you can obtain more informations from 
 him
 His phone number is : +33 1 30 61 50 60

You state . . . CPS are not published . . . 

Repeatedly, the WebTrust Program for Certification Authorities
indicates that the CPS is PUBLISHED.  This means it is made available to
the public, to both those who have certificates and those who trust
those certificates.  If you were audited in conformance with WebTrust
criteria, how did you pass the audit without publishing your CPS?

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Re: Certigna Root Inclusion Request

2009-02-10 Thread Eddy Nigg

On 02/10/2009 04:25 PM, Yannick LEPLARD:


The initial comment was written on august 2008, and now we have code signing
certificates, and it appears in our CP/CPS.


To my understanding the audit wasn't performed with those changes.



Yes it is not defined in our CP but in our internal operational processes
and in our CPS too.
Unfortunately, CPS are not published (they described internal technical and
organizational measurements)


This must be stated in the CPS and publicly disclosed. I'm sorry, but in 
my opinion this is insufficient and will most likely not work.




RA operators must obtain guarantee than the e-mail address is owned by the
requester.
It's difficult in fact to make such controls.


Email validation isn't too difficult to implement, however we have seen 
various times that this isn't done sufficiently or correctly.




- Software private keys are generated on the suscriber computer with a
signed applet


This is interesting! Can you provide us some more information about this 
applet? Can I test it somewhere?




We are at the same level than the DCSSI CA that was approved a few days ago.


Each CA is looked at independently and each CA has its own CP/CPS, audit 
etc.


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Re: Certigna Root Inclusion Request

2009-02-10 Thread Ian G

On 10/2/09 16:42, :


The initial comment was written on august 2008, and now we have code
signing
certificates, and it appears in our CP/CPS.


To my understanding the audit wasn't performed with those changes.


In general terms, and without commenting at all on the current case, 
here are a few observations.  I think this is another area where there 
is a misunderstanding as to the role of audit.


a.  Time.  There is always some element of change between the last audit 
and current practice.  Audits are snapshots of the past not proofs 
over the present nor future.  And, there is an expectation that audits 
are repeated over time, the new guy has to have something to work with. 
 Also, factor in 40 week + distro delays, and consider asking CAs to 
sit on their hands for a year or so.


b.  The emphasis of the audit is over whether management has put in 
place policies and procedures, sticks to them.  Any check over 
particular activities is not there to audit those activities in 
themselves but to provide evidence of the policies and procedures in 
general as a reliable guide to the reading public.


E.g., they do what they write, they write what they do.

d.  Having said that, a specific audit criteria may state a check is 
needed on X.  One would have to go back and read WebTrust to see if it 
has a criteria on X==codesigning.  That still doesn't change the other 
issues, but it may give you something to rely on when it comes to 
codesigning specifically.


c.  One of the policies and practices that audits look at is generally 
whether CPSs and so forth are updated according to a reliable regime. 
Of course, we can really only do that when we see that change is done, 
so this is actually a positive chance for the next auditor to check the 
progress.  I say this with some relish, because extracting good evidence 
is quite hard when most things are just written because the auditor says 
it is needed, and then ignored forever more..




That's my view at the moment, I'm looking forward to others!

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Re: Certigna Root Inclusion Request

2009-02-10 Thread Yannick LEPLARD





We are at the same level than the DCSSI CA that was approved a few  
days ago.


Each CA is looked at independently and each CA has its own CP/CPS,  
audit etc.




I just wanted to explain that DCSSI is the french government CA,
and PRIS/RGS is the new highest level standard for french CAs.

It is ETSI TS 102 042 compliant, and ETSI 101 456 compliant for  
qualified signing certificates.


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Re: Certigna Root Inclusion Request

2009-02-10 Thread Yannick LEPLARD


You state . . . CPS are not published . . . 

Repeatedly, the WebTrust Program for Certification Authorities
indicates that the CPS is PUBLISHED.  This means it is made  
available to

the public, to both those who have certificates and those who trust
those certificates.  If you were audited in conformance with WebTrust
criteria, how did you pass the audit without publishing your CPS?



we have ETSI TS 102 042 audits and only CP have to be published.


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Re: Certigna Root Inclusion Request

2009-02-10 Thread Eddy Nigg

On 02/10/2009 06:30 PM, Ian G:

a. Time. There is always some element of change between the last audit
and current practice. Audits are snapshots of the past not proofs over
the present nor future.


So far correct.


And, there is an expectation that audits are
repeated over time, the new guy has to have something to work with.


Correct, but it's not audited - whatever it is.


Also, factor in 40 week + distro delays, and consider asking CAs to sit
on their hands for a year or so.


No, did anybody suggest that and where?


b. The emphasis of the audit is over whether management has put in place
policies and procedures, sticks to them. Any check over particular
activities is not there to audit those activities in themselves but to
provide evidence of the policies and procedures in general as a reliable
guide to the reading public.


No, that statement is basically bullshit :-)

Particular activities are audited including evidence of the specific 
policies and procedures.



d. Having said that, a specific audit criteria may state a check is
needed on X. One would have to go back and read WebTrust to see if it
has a criteria on X==codesigning. That still doesn't change the other
issues, but it may give you something to rely on when it comes to
codesigning specifically.


Wrong! If the CPS doesn't mention code signing than it's not audited. No 
samples of those procedures are taken by the auditor either. Audits 
pretty much confirm what the CA claims to do.




That's my view at the moment, I'm looking forward to others!



Audits are very specific and you can forget about the general 
references. As such we have precedence in this respect (in particular 
code signing).



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Re: Certigna Root Inclusion Request

2009-02-10 Thread Frank Hecker

Eddy Nigg wrote:

On 02/10/2009 04:25 PM, Yannick LEPLARD:

snip
RA operators must obtain guarantee than the e-mail address is owned by 
the

requester.
It's difficult in fact to make such controls.


Email validation isn't too difficult to implement, however we have seen 
various times that this isn't done sufficiently or correctly.


Note that the official Mozilla policy doesn't attempt to dictate exactly 
what mechanisms a CA uses to verify ownership of email addresses, it 
simply requires that the CA takes reasonable measures to verify this.


We can quibble about whether particular measures are reasonable or 
not. However traditionally the major concerns we've had were with CAs 
that did not have any CPS or CP language at all about verifying email 
addresses.


Frank

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Re: Certigna Root Inclusion Request

2009-02-10 Thread Eddy Nigg

On 02/10/2009 10:19 PM, Frank Hecker:

Email validation isn't too difficult to implement, however we have
seen various times that this isn't done sufficiently or correctly.


Note that the official Mozilla policy doesn't attempt to dictate exactly
what mechanisms a CA uses to verify ownership of email addresses, it
simply requires that the CA takes reasonable measures to verify this.


Correct. I haven't attempted to dictate about how to do it, but we've 
seen cases where it's not done at all.


However some (affected) CAs turned directly to me for advice in the past 
concerning email validation and I provided my suggestions and advice. 
Some of them might still be subscribed to this list btw.


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Re: Certigna Root Inclusion Request

2009-02-10 Thread David E. Ross
On 2/10/2009 12:06 PM, Frank Hecker wrote:
 Yannick LEPLARD wrote:
 Unfortunately, CPS are not published (they described internal technical and
 organizational measurements)
 
 I acknowledge your comment that ETSI TS 102 042 does not require the CPS 
 to be published. However we depend on public documents to document the 
 exact claims that CAs make and whether these meet our policy 
 requirement. So this causes a problem for us when we do not have access 
 to CPSs and related documents.
 
 If you cannot publish the CPS because it contains private information, I 
 suggest as an alternative that you provide some sort of official 
 Certigna document that summarizes the portions of the CPS that are of 
 most interest to us (i.e., those relating to validation of subcriber 
 information).
 
 Frank
 


THANK YOU!!  That was indeed the point of my earlier comment.

However, not only should they provide some alternative documentation but
also that documentation should be considered during the required audit.

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http://www.rossde.com/

Go to Mozdev at http://www.mozdev.org/ for quick access to
extensions for Firefox, Thunderbird, SeaMonkey, and other
Mozilla-related applications.  You can access Mozdev much
more quickly than you can Mozilla Add-Ons.
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Re: Certigna Root Inclusion Request

2009-02-10 Thread Frank Hecker

Ian G wrote:

The policy says, we need published information, *eg* the CPS.

Not, CPS must be published.


Yes, exactly. We typically use the CPS and/or CP because almost all CAs 
publish those documents; however there is no requirement that the 
information published by the CA be in the form of a CPS or CP.


Speaking personally, I think think that it is good practice for CAs to 
publish a CPS. If a CA has private information relating to detailed 
internal processes that it does not wish to make public, I suggest that 
it put such material in a separate CA operations manual that is 
internal-only.


Frank

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Re: Certigna Root Inclusion Request

2009-02-09 Thread kathleen95014
Certigna’s root inclusion request has been in public discussion for a
week now. No issues or concerns about this request have been raised.

According to https://wiki.mozilla.org/CA:How_to_apply
“If there are no open issues or action items after the first
discussion period, and there is general agreement that you comply with
our policy requirements, then at the Foundation's discretion the
second phase of public discussion may be skipped, the request will be
immediately approved, and the request will move into the inclusion
phase…”

If no issues or concerns are raised in the next couple of days, then I
will post the summary in the bug and request approval for inclusion.

Kathleen
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Re: Certigna Root Inclusion Request

2009-02-09 Thread Eddy Nigg

On 02/09/2009 08:38 PM, kathleen95...@yahoo.com:

Certigna’s root inclusion request has been in public discussion for a
week now. No issues or concerns about this request have been raised.

According to https://wiki.mozilla.org/CA:How_to_apply
“If there are no open issues or action items after the first
discussion period, and there is general agreement that you comply with
our policy requirements, then at the Foundation's discretion the
second phase of public discussion may be skipped, the request will be
immediately approved, and the request will move into the inclusion
phase…”

If no issues or concerns are raised in the next couple of days, then I
will post the summary in the bug and request approval for inclusion.



Kathleen, I request another few days if you allow.


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Re: Certigna Root Inclusion Request

2009-02-09 Thread kathleen95014
Of course. I will await your next post to this discussion.

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Re: Certigna Root Inclusion Request

2009-02-09 Thread Eddy Nigg

On 02/09/2009 09:35 PM, kathleen95...@yahoo.com:

Of course. I will await your next post to this discussion.



Just browsing through the various documents and I noticed the following 
so far.


It seems to me that the code signing bit *should not* be activated, it 
should be reflected in the Pending page as well.


Email validation seems to me ambiguous at least and apparently not 
defined in their CP/CPS. Neither is domain ownership/control validation 
defined as I understand.


Repeated requests for translating the relevant parts have not been 
complied. Comments in this respect (bug 393166, comment 15, d) ) have no 
relevance to the question asked and your questions in comment 13 have 
partly not been answered, in particular 2.d. Besides a general denial in 
regards of problematic practices, no details have been provided. In 
particular I couldn't find out for how long their certificates are valid 
and how S/MIME certificates are provided to the subscriber (We send the 
certificate to the subscriber by mail).


Overall I think there is very little information available about this CA 
(in English) and I'm hesitant to continue without a more thorough review 
of critical aspects.


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Re: Certigna Root Inclusion Request

2009-02-09 Thread Nelson B Bolyard
Eddy Nigg wrote, On 2009-02-09 11:54:
 On 02/09/2009 09:35 PM, kathleen95...@yahoo.com:
 Of course. I will await your next post to this discussion.

 
 Just browsing through the various documents and I noticed the following 
 so far.
 
 It seems to me that the code signing bit *should not* be activated, it 
 should be reflected in the Pending page as well.

Because ?

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Re: Certigna Root Inclusion Request

2009-02-09 Thread Eddy Nigg

On 02/10/2009 03:14 AM, Nelson B Bolyard:

Eddy Nigg wrote, On 2009-02-09 11:54:

On 02/09/2009 09:35 PM, kathleen95...@yahoo.com:

Of course. I will await your next post to this discussion.


Just browsing through the various documents and I noticed the following
so far.

It seems to me that the code signing bit *should not* be activated, it
should be reflected in the Pending page as well.


Because ?



Because their CPS doesn't define code signing.

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