RE: What does "No Stipulation" mean, and when is it OK to use it in CP/CPS?

2018-10-19 Thread Tim Hollebeek via dev-security-policy
I think blank sections should be disallowed. The entire purpose of "No stipulation" is to make it clear that the omission of content was intentional. With regards to some of these sections being useful, I agree that a good CPS contains more than the minimum content required from the BRs. I

RE: What does "No Stipulation" mean, and when is it OK to use it in CP/CPS?

2018-10-24 Thread Tim Hollebeek via dev-security-policy
That may be true, but I don't see any upside for using that date. If you need to make a minor CPS update in early January for any reason, you now have additional work. I think late December policy changes should be avoided as a general rule. -Tim > -Original Message- > From:

RE: What does "No Stipulation" mean, and when is it OK to use it in CP/CPS?

2018-10-23 Thread Tim Hollebeek via dev-security-policy
I agree with you, but December 31 is a particularly horrible compliance deadline. Perhaps January 31? -Tim > -Original Message- > From: dev-security-policy On > Behalf Of Wayne Thayer via dev-security-policy > Sent: Monday, October 22, 2018 6:00 PM > To: Kathleen Wilson > Cc:

RE: Concerns with Dun & Bradstreet as a QIIS

2018-09-27 Thread Tim Hollebeek via dev-security-policy
I'm glad you added the smiley, because in my experience CAs have rarely, if ever, have had any discretion in such matters. Nor do we (DigiCert) particularly want to, to be honest. I prefer clear, open, and transparent validation rules that other CAs can't play games with. Whitelisting and

RE: Concerns with Dun & Bradstreet as a QIIS

2018-09-28 Thread Tim Hollebeek via dev-security-policy
Perhaps a simple first step is to mandate disclosure of which information source was used for validation. Then if someone uses Google Maps or similar, People Who Pay Attention To Such Things can start a public discussion about whether the source is a QIIS, and whether the certificate is

RE: Concerns with Dun & Bradstreet as a QIIS

2018-10-01 Thread Tim Hollebeek via dev-security-policy
Getting the whitelist figured out and workable will take a while. Disclosure could happen much faster. And I’m curious why you think it would be unauditable. It seems pretty straightforward to verify such disclosures. It think both ideas are worth considering. There’s no reason we

RE: What does "No Stipulation" mean, and when is it OK to use it in CP/CPS?

2018-10-09 Thread Tim Hollebeek via dev-security-policy
RFC 3647 disagrees: "Rather, a particular CP or CPS may state "no stipulation" for a component, subcomponent, or element on which the particular CP or CPS imposes no requirements or makes no disclosure." " It is recommended that each and every component and subcomponent be included in a CP

RE: Concerns with Dun & Bradstreet as a QIIS

2018-09-26 Thread Tim Hollebeek via dev-security-policy
There have been previous discussions about this very issue at CA/Browser Forum Validation Working Group meetings (see also draft Ballot 225). I think it is widely recognized that the rules around QIISs are far too weak and in need of improvement. I actually recently asked Kirk to add an item on

RE: AlwaysOnSSL web security issues

2019-01-16 Thread Tim Hollebeek via dev-security-policy
Here's the article we published on this subject a while ago: https://www.digicert.com/blog/keeping-subscribers-safe-partner-best-practices/ -Tim > -Original Message- > From: dev-security-policy > On Behalf Of Jeremy Rowley via dev-security-policy > Sent: Thursday, January 10, 2019 4:47

RE: Violation report - Comodo CA certificates revocation delays

2018-12-17 Thread Tim Hollebeek via dev-security-policy
I don't think we've commented on this before, but I'll note that sending an e-mail from the e-mail address listed as the contact address on a website is not one of the approved methods of showing ownership or control of a website as specified in section 3.2.2.4. The approved methods of validating

RE: DNS fragmentation attack subverts DV, 5 public CAs vulnerable

2018-12-18 Thread Tim Hollebeek via dev-security-policy
The problem is that the attackers get to choose the CA they use, so multi-perspective validation doesn't provide any benefits unless everyone has to do it. I brought it up several times at the validation working group and as a discussion topic at the Shanghai face to face, but unfortunately there

RE: AW: Incident Report DFN-PKI: Non-IDNA2003 encoded international domain names

2019-01-24 Thread Tim Hollebeek via dev-security-policy
I think the assertion that the commonName has anything to do with what the user would type and expect to see is unsupported by any of the relevant standards, and as Rob noted, having it be different from the SAN strings is not in compliance with the Baseline Requirements. It's also deprecated.

RE: Possible DigiCert in-addr.arpa Mis-issuance

2019-02-27 Thread Tim Hollebeek via dev-security-policy
> On 27/02/2019 00:10, Matthew Hardeman wrote: > > Is it even proper to have a SAN dnsName in in-addr.arpa ever? > > > > While in-addr.arpa IS a real DNS heirarchy under the .arpa TLD, it > > rarely has anything other than PTR and NS records defined. > > > > While there is no current use, and the

RE: Incident Report - Entrust Datacard issued certificates with the incorrect Organization Name

2019-03-15 Thread Tim Hollebeek via dev-security-policy
What is the rationale for waiting until March 20th for revocation given that the issue was noticed on March 7th? -Tim > -Original Message- > From: dev-security-policy On > Behalf Of Bruce via dev-security-policy > Sent: Friday, March 15, 2019 4:59 PM > To:

RE: AW: Incident Report DFN-PKI: Non-IDNA2003 encoded international domain names

2019-01-25 Thread Tim Hollebeek via dev-security-policy
> On 2019-01-24 20:19, Tim Hollebeek wrote: > > I think the assertion that the commonName has anything to do with what > > the user would type and expect to see is unsupported by any of the > > relevant standards, and as Rob noted, having it be different from the > > SAN strings is not in

RE: CA handling of contact information when reporting problems

2019-08-22 Thread Tim Hollebeek via dev-security-policy
DigiCert currently has a policy of not publishing the names of those who report things to us without their permission. It just seems like the right thing to do. If we do find that people are abusing that protection to selectively harass people that they personally have issues with, we may need

RE: Use of Certificate/Public Key Pinning

2019-08-22 Thread Tim Hollebeek via dev-security-policy
So, pinning is an extremely complicated topic that I've always wanted to write a blog post about, but have never had the time to do it. It happens fairly regularly that we have to assist a company that has painted themselves into a corner with a poorly thought out pinning scheme. In my

RE: DigiCert OCSP services returns 1 byte

2019-09-12 Thread Tim Hollebeek via dev-security-policy
So, this is something that would be helpfully clarified via either an IETF draft, or clarifications in the BRs. There are various things in the OCSP RFCs and even the BRs that can be read as precluding good OCSP responses for pre-certificates, although the situation is unclear since the

RE: DigiCert OCSP services returns 1 byte

2019-09-13 Thread Tim Hollebeek via dev-security-policy
r > > Subject: Re: DigiCert OCSP services returns 1 byte > > On 12/09/2019 20:48, Tim Hollebeek via dev-security-policy wrote: > > So, this is something that would be helpfully clarified via either an > > IETF draft, > > There's already a 6962-bis draft [1] in I

RE: DigiCert OCSP services returns 1 byte

2019-09-13 Thread Tim Hollebeek via dev-security-policy
On Thu, Sep 12, 2019 at 3:49 PM Tim Hollebeek via dev-security-policy mailto:dev-security-policy@lists.mozilla.org> > wrote: So, this is something that would be helpfully clarified via either an IETF draft, or clarifications in the BRs. There are various things in the OCSP RFCs

RE: DigiCert OCSP services returns 1 byte

2019-09-19 Thread Tim Hollebeek via dev-security-policy
t; >> Sent: Friday, September 13, 2019 4:22 AM > >> To: Tim Hollebeek ; Jeremy Rowley > >> ; Alex Cohn > >> Cc: mozilla-dev-security-pol...@lists.mozilla.org; Wayne Thayer > >> > >> Subject: Re: DigiCert OCSP services returns 1 byte > >>

RE: DigiCert OCSP services returns 1 byte

2019-09-19 Thread Tim Hollebeek via dev-security-policy
> Thanks Wayne. You're right. > > (I read the "SHOULD NOT" requirement, forgot it had been superseded, and > didn't read further. I wonder if it would be reasonable to remove the > superseded requirement from the BRs now, given that it was superseded over > 6 years ago?) Removing out of date

RE: DigiCert OCSP services returns 1 byte

2019-09-19 Thread Tim Hollebeek via dev-security-policy
Subject: Re: DigiCert OCSP services returns 1 byte On Thu, Sep 19, 2019 at 1:52 PM Tim Hollebeek via dev-security-policy mailto:dev-security-policy@lists.mozilla.org> > wrote: I think that's fine as Mozilla and/or the CABF can and should override RFCs when it makes sense to

RE: [FORGED] Re: How Certificates are Verified by Firefox

2019-12-04 Thread Tim Hollebeek via dev-security-policy
Someone really should write up "AIA chasing considered harmful". It was disputed at the TLS session at IETF 105, which shows that the reasoning behind it is not as widely understood as it needs to be, even among TLS experts. I'm very appreciative of Firefox's efforts in this area. Leveraging

RE: Terms and Conditions that use technical measures to make it difficult to change CAs

2020-04-16 Thread Tim Hollebeek via dev-security-policy
Generally, I'm in favor of transparency requirements, and many of Ryan's ideas would be useful or interesting to pursue. Transparency is often the first and best step towards improving business practices. And the entire purpose of a CPS is to disclose the business practices that implement a

RE: Acceptable forms of evidence for key compromise

2020-03-17 Thread Tim Hollebeek via dev-security-policy
I agree with Corey on this. I was disappointed that the LAMPS discussion two years ago was not as helpful as it could have been. For what it's worth, while we generally try to accept any reasonable proof of key compromise, we have seen quite a large variety of things sent to us. This includes

RE: About upcoming limits on trusted certificates

2020-03-17 Thread Tim Hollebeek via dev-security-policy
> On 3/11/20 3:51 PM, Paul Walsh wrote: > > Can you provide some insight to why you think a shorter frequency in > domain validation would be beneficial? > > To start with, it is common for a domain name to be purchased for one year. > A certificate owner that was able to prove ownership/control

Terms and Conditions that use technical measures to make it difficult to change CAs

2020-03-16 Thread Tim Hollebeek via dev-security-policy
Hello, I'd like to start a discussion about some practices among other commercial CAs that have recently come to my attention, which I personally find disturbing. While it's perfectly appropriate to have Terms and Conditions associated with digital certificates, in some circumstances,

RE: SECURITY RELEVANT FOR CAs: The curious case of the Dangerous Delegated Responder Cert

2020-07-02 Thread Tim Hollebeek via dev-security-policy
So, from our perspective, the security implications are the most important here. We understand them, and even in the absence of any compliance obligations they would constitute an unacceptable risk to trustworthiness of our OCSP responses, so we have already begun the process of replacing the ICAs

RE: Policy 2.7.1: MRSP Issue #192: Require information about auditor qualifications in the audit report

2020-11-05 Thread Tim Hollebeek via dev-security-policy
Ben, We're concerned that these changes could unintentionally prevent many new auditors from being able to conduct audits, despite being Qualified Auditors. The problem is that CAs will understandably be very hesitant to use a new auditor, as they cannot risk having an audit conducted, and

RE: Policy 2.7.1: MRSP Issue #153: Cradle-to-Grave Contiguous Audits

2020-11-05 Thread Tim Hollebeek via dev-security-policy
So, I'd like to drill down a bit more into one of the cases you discussed. Let's assume the following: 1. The CAO [*] may or may not have requested removal of the CAC, but removal has not been completed. The CAC is still trusted by at least one public root program. 2. The CAO has destroyed the

RE: Policy 2.7.1: MRSP Issue #152: Add EV Audit exception for Policy Constraints

2020-11-06 Thread Tim Hollebeek via dev-security-policy
In the definition of EV TLS Capable, I'd move the last bullet up to the top. This is because the definition is inherently recursive, and it's easy to miss that if the recursion rule isn't first. For example, I had a question about whether "revoked" meant just the certificate itself, or whether

RE: Clarification request: ECC subCAs under RSA Root

2021-03-10 Thread Tim Hollebeek via dev-security-policy
I know where this kind of requirement is coming from ... it's a common requirement in key management systems, but they generally operate in worlds that are completely different from the Web PKI. Even there, it often causes more problems than it solves. I've spent more of my life dealing with the

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