provide for the termination of the agreement under specified
circumstances and conditions. Events considered to constitute a
"force majeure" may include so-called "Acts of God," wars,
terrorism, strikes, natural disasters, failures of suppliers or
vendors to perform, or failures of the Internet or other
infrastructure. Force majeure clauses should be drafted so as to
be consistent with other portions of the framework and applicable
service level agreements. For instance, responsibilities and
capabilities for business continuity and disaster recovery may
place some events within the reasonable control of the parties,
such as an obligation to maintain backup electrical power in the
face of power outages.
4.9.17. Other Provisions
This subcomponent is a "catchall" location where additional
responsibilities and terms can be imposed on PKI participants that do
not neatly fit within one of the other components or subcomponents of
the framework. CP and CPS writers can place any provision within
this subcomponent that is not covered by another subcomponent.
5. Security Considerations
According to X.509, a certificate policy (CP) is "a named set of
rules that indicates the applicability of a certificate to a
particular community and/or class of applications with common
security requirements." A CP may be used by a relying party to help
in deciding whether a certificate, and the binding therein, are
sufficiently trustworthy and otherwise appropriate for a particular
application.
The degree to which a relying party can trust the binding embodied in
a certificate depends on several factors. These factors can include
the practices followed by the certification authority (CA) in
authenticating the subject; the CA’s operating policy, procedures,
and technical security controls, including the scope of the
subscriber’s responsibilities (for example, in protecting the private
key), and the stated responsibilities and liability terms and
conditions of the CA (for example, warranties, disclaimers of
warranties, and limitations of liability).
This document provides a framework to address technical, procedural,
personnel, and physical security aspects of Certification
Authorities, Registration Authorities, repositories, subscribers, and
relying party cryptographic modules, in order to ensure that the
certificate generation, publication, renewal, re-key, usage, and
revocation is done in a secure manner. Specifically, Section 4.3
Identification and Authentication (I&A); Section 4.4 Certificate
Life-Cycle Operational Requirements; Section 4.5 Facility Management,
and Operational Controls; Section 4.6 Technical Security Controls;
Section 4.7 Certificate CRL, and OCSP Profiles; and Section 4.8
Compliance Audit and Other Assessment, are oriented towards ensuring
secure operation of the PKI entities such as CA, RA, repository,
subscriber systems, and relying party systems.
6. Outline of a Set of Provisions
This section contains a recommended outline for a set of provisions,
intended to serve as a checklist or (with some further development) a
standard template for use by CP or CPS writers. Such a common
outline will facilitate:
(a) Comparison of two certificate policies during cross-
certification or other forms of interoperation (for the purpose
of equivalency mapping).
(b) Comparison of a CPS with a CP to ensure that the CPS faithfully
implements the policy.
(c) Comparison of two CPSs.
In order to comply with the RFC, the drafters of a compliant CP or
CPS are strongly advised to adhere to this outline. While use of an
alternate outline is discouraged, it may be accepted if a proper
justification is provided for the deviation and a mapping table is
provided to readily discern where each of the items described in this
outline is provided.
1. INTRODUCTION
1.1 Overview
1.2 Document name and identification
1.3 PKI participants
1.3.1 Certification authorities
1.3.2 Registration authorities
1.3.3 Subscribers
1.3.4 Relying parties
1.3.5 Other participants
1.4 Certificate usage
1.4.1. Appropriate certificate uses
1.4.2 Prohibited certificate uses
1.5 Policy administration
1.5.1 Organization administering the document
1.5.2 Contact person
1.5.3 Person determining CPS suitability for the policy
1.5.4 CPS approval procedures
1.6 Definitions and acronyms
2. PUBLICATION AND REPOSITORY RESPONSIBILITIES
2.1 Repositories
2.2 Publication of certification information
2.3 Time or frequency of publication
2.4 Access controls on repositories
3. IDENTIFICATION AND AUTHENTICATION (11)
3.1 Naming
3.1.1 Types of names
3.1.2 Need for names to be meaningful
3.1.3 Anonymity or pseudonymity of subscribers
3.1.4 Rules for interpreting various name forms
3.1.5 Uniqueness of names
3.1.6 Recognition, authentication, and role of trademarks
3.2 Initial identity validation
3.2.1 Method to prove possession of private key
3.2.2 Authentication of organization identity
3.2.3 Authentication of individual identity
3.2.4 Non-verified subscriber information
3.2.5 Validation of authority
3.2.6 Criteria for interoperation
3.3 Identification and authentication for re-key requests
3.3.1 Identification and authentication for routine re-key
3.3.2 Identification and authentication for re-key after revocation
3.4 Identification and authentication for revocation request
4. CERTIFICATE LIFE-CYCLE OPERATIONAL REQUIREMENTS (11)
4.1 Certificate Application
4.1.1 Who can submit a certificate application
4.1.2 Enrollment process and responsibilities
4.2 Certificate application processing
4.2.1 Performing identification and authentication functions
4.2.2 Approval or rejection of certificate applications
4.2.3 Time to process certificate applications
4.3 Certificate issuance
4.3.1 CA actions during certificate issuance
4.3.2 Notification to subscriber by the CA of issuance of
certificate
4.4 Certificate acceptance
4.4.1 Conduct constituting certificate acceptance
4.4.2 Publication of the certificate by the CA
4.4.3 Notification of certificate issuance by the CA to other
entities
4.5 Key pair and certificate usage
4.5.1 Subscriber private key and certificate usage
4.5.2 Relying party public key and certificate usage
4.6 Certificate renewal
4.6.1 Circumstance for certificate renewal
4.6.2 Who may request renewal
4.6.3 Processing certificate renewal requests
4.6.4 Notification of new certificate issuance to subscriber
4.6.5 Conduct constituting acceptance of a renewal certificate
4.6.6 Publication of the renewal certificate by the CA
4.6.7 Notification of certificate issuance by the CA to other
entities
4.7 Certificate re-key
4.7.1 Circumstance for certificate re-key
4.7.2 Who may request certification of a new public key
4.7.3 Processing certificate re-keying requests
4.7.4 Notification of new certificate issuance to subscriber
4.7.5 Conduct constituting acceptance of a re-keyed certificate
4.7.6 Publication of the re-keyed certificate by the CA
4.7.7 Notification of certificate issuance by the CA to other
entities
4.8 Certificate modification
4.8.1 Circumstance for certificate modification
4.8.2 Who may request certificate modification
4.8.3 Processing certificate modification requests
4.8.4 Notification of new certificate issuance to subscriber
4.8.5 Conduct constituting acceptance of modified certificate
4.8.6 Publication of the modified certificate by the CA
4.8.7 Notification of certificate issuance by the CA to other
entities
4.9 Certificate revocation and suspension
4.9.1 Circumstances for revocation
4.9.2 Who can request revocation
4.9.3 Procedure for revocation request
4.9.4 Revocation request grace period
4.9.5 Time within which CA must process the revocation request
4.9.6 Revocation checking requirement for relying parties
4.9.7 CRL issuance frequency (if applicable)
4.9.8 Maximum latency for CRLs (if applicable)
4.9.9 On-line revocation/status checking availability
4.9.10 On-line revocation checking requirements
4.9.11 Other forms of revocation advertisements available
4.9.12 Special requirements re key compromise
4.9.13 Circumstances for suspension
4.9.14 Who can request suspension
4.9.15 Procedure for suspension request
4.9.16 Limits on suspension period
4.10 Certificate status services
4.10.1 Operational characteristics
4.10.2 Service availability
4.10.3 Optional features
4.11 End of subscription
4.12 Key escrow and recovery
4.12.1 Key escrow and recovery policy and practices
4.12.2 Session key encapsulation and recovery policy and practices
5. FACILITY, MANAGEMENT, AND OPERATIONAL CONTROLS (11)
5.1 Physical controls
5.1.1 Site location and construction
5.1.2 Physical access
5.1.3 Power and air conditioning
5.1.4 Water exposures
5.1.5 Fire prevention and protection
5.1.6 Media storage
5.1.7 Waste disposal
5.1.8 Off-site backup
5.2 Procedural controls
5.2.1 Trusted roles
5.2.2 Number of persons required per task
5.2.3 Identification and authentication for each role
5.2.4 Roles requiring separation of duties
5.3 Personnel controls
5.3.1 Qualifications, experience, and clearance requirements
5.3.2 Background check procedures
5.3.3 Training requirements
5.3.4 Retraining frequency and requirements
5.3.5 Job rotation frequency and sequence
5.3.6 Sanctions for unauthorized actions
5.3.7 Independent contractor requirements
5.3.8 Documentation supplied to personnel
5.4 Audit logging procedures
5.4.1 Types of events recorded
5.4.2 Frequency of processing log
5.4.3 Retention period for audit log
5.4.4 Protection of audit log
5.4.5 Audit log backup procedures
5.4.6 Audit collection system (internal vs. external)
5.4.7 Notification to event-causing subject
5.4.8 Vulnerability assessments
5.5 Records archival
5.5.1 Types of records archived
5.5.2 Retention period for archive
5.5.3 Protection of archive
5.5.4 Archive backup procedures
5.5.5 Requirements for time-stamping of records
5.5.6 Archive collection system (internal or external)
5.5.7 Procedures to obtain and verify archive information
5.6 Key changeover
5.7 Compromise and disaster recovery
5.7.1 Incident and compromise handling procedures
5.7.2 Computing resources, software, and/or data are corrupted
5.7.3 Entity private key compromise procedures
5.7.4 Business continuity capabilities after a disaster
5.8 CA or RA termination
6. TECHNICAL SECURITY CONTROLS (11)
6.1 Key pair generation and installation
6.1.1 Key pair generation
6.1.2 Private key delivery to subscriber
6.1.3 Public key delivery to certificate issuer
6.1.4 CA public key delivery to relying parties
6.1.5 Key sizes
6.1.6 Public key parameters generation and quality checking
6.1.7 Key usage purposes (as per X.509 v3 key usage field)
6.2 Private Key Protection and Cryptographic Module Engineering
Controls
6.2.1 Cryptographic module standards and controls
6.2.2 Private key (n out of m) multi-person control
6.2.3 Private key escrow
6.2.4 Private key backup
6.2.5 Private key archival
6.2.6 Private key transfer into or from a cryptographic module
6.2.7 Private key storage on cryptographic module
6.2.8 Method of activating private key
6.2.9 Method of deactivating private key
6.2.10 Method of destroying private key
6.2.11 Cryptographic Module Rating
6.3 Other aspects of key pair management
6.3.1 Public key archival
6.3.2 Certificate operational periods and key pair usage periods
6.4 Activation data
6.4.1 Activation data generation and installation
6.4.2 Activation data protection
6.4.3 Other aspects of activation data
6.5 Computer security controls
6.5.1 Specific computer security technical requirements
6.5.2 Computer security rating
6.6 Life cycle technical controls
6.6.1 System development controls
6.6.2 Security management controls
6.6.3 Life cycle security controls
6.7 Network security controls
6.8 Time-stamping
7. CERTIFICATE, CRL, AND OCSP PROFILES
7.1 Certificate profile
7.1.1 Version number(s)
7.1.2 Certificate extensions
7.1.3 Algorithm object identifiers
7.1.4 Name forms
7.1.5 Name constraints
7.1.6 Certificate policy object identifier
7.1.7 Usage of Policy Constraints extension
7.1.8 Policy qualifiers syntax and semantics
7.1.9 Processing semantics for the critical Certificate Policies
extension
7.2 CRL profile
7.2.1 Version number(s)
7.2.2 CRL and CRL entry extensions
7.3 OCSP profile
7.3.1 Version number(s)
7.3.2 OCSP extensions
8. COMPLIANCE AUDIT AND OTHER ASSESSMENTS
8.1 Frequency or circumstances of assessment
8.2 Identity/qualifications of assessor
8.3 Assessor’s relationship to assessed entity
8.4 Topics covered by assessment
8.5 Actions taken as a result of deficiency
8.6 Communication of results
9. OTHER BUSINESS AND LEGAL MATTERS
9.1 Fees
9.1.1 Certificate issuance or renewal fees
9.1.2 Certificate access fees
9.1.3 Revocation or status information access fees
9.1.4 Fees for other services
9.1.5 Refund policy
9.2 Financial responsibility
9.2.1 Insurance coverage
9.2.2 Other assets
9.2.3 Insurance or warranty coverage for end-entities
9.3 Confidentiality of business information
9.3.1 Scope of confidential information
9.3.2 Information not within the scope of confidential information
9.3.3 Responsibility to protect confidential information
9.4 Privacy of personal information
9.4.1 Privacy plan
9.4.2 Information treated as private
9.4.3 Information not deemed private
9.4.4 Responsibility to protect private information
9.4.5 Notice and consent to use private information
9.4.6 Disclosure pursuant to judicial or administrative process
9.4.7 Other information disclosure circumstances
9.5 Intellectual property rights
9.6 Representations and warranties
9.6.1 CA representations and warranties
9.6.2 RA representations and warranties
9.6.3 Subscriber representations and warranties
9.6.4 Relying party representations and warranties
9.6.5 Representations and warranties of other participants
9.7 Disclaimers of warranties
9.8 Limitations of liability
9.9 Indemnities
9.10 Term and termination
9.10.1 Term
9.10.2 Termination
9.10.3 Effect of termination and survival
9.11 Individual notices and communications with participants
9.12 Amendments
9.12.1 Procedure for amendment
9.12.2 Notification mechanism and period
9.12.3 Circumstances under which OID must be changed
9.13 Dispute resolution provisions
9.14 Governing law
9.15 Compliance with applicable law
9.16 Miscellaneous provisions
9.16.1 Entire agreement
9.16.2 Assignment
9.16.3 Severability
9.16.4 Enforcement (attorneys’ fees and waiver of rights)
9.16.5 Force Majeure
9.17 Other provisions
7. Comparison to RFC 2527
This framework represents an incremental improvement over RFC 2527.
The new framework benefits from the experience gained in the course
of deploying CP and CPS documents under RFC 2527. Further, this new
framework is based on coordination with the American Bar Association
Information Security Committee within the Section of Science and
Technology Law. The ISC wrote the PKI Assessment Guidelines [ABA2],
which embodies a great deal of technical, business, and legal
experience in PKI operations. In particular, representatives of the
ISC made changes to the framework to better suite it to the legal
environment and make it more accessible to lawyers.
>From a technical perspective, the changes to the RFC 2527 framework
were minimal and incremental, rather than revolutionary. Sections
3-7 have largely been preserved, with modest reorganization and new
topics. For example, the new framework includes a revision of
Section 4 of the framework to include a full treatment of the
certificate life-cycle, the addition of key escrow, key
encapsulation, and key recovery policies and practices, and OCSP.
Section 2 audit functions now appear alone in Section 8, and Section
2 focuses exclusively on repository functions. The business and
legal matters in RFC 2527’s Section 2 now appear in a new Section 9.
From a legal perspective, the new Section 9 is useful because it
places topics in the framework in an ordering that is similar to
software licensing and other technology agreements and thus is
familiar to technology lawyers. Moreover, the framework as a whole
can double as a framework for a subscriber, relying party, or other
PKI-related agreement. The changes are intended to make legal review
of, and input into, CP and CPS documents more efficient. Section 9
also adds new legal topics, such as the privacy of personal
information, liability terms, and duration of the effectiveness of
the document.
Section 1 of the new framework is largely the same as RFC 2527,
although it increases coverage of PKI participants by breaking out
subscribers from relying parties and adding a section for other
participants. It changes the "applicability" section to one covering
appropriate and prohibited uses of certificates. Also, it moves CPS
approval procedures from RFC 2527’s Section 8.3 into a collected
policy administration section. Finally, Section 1.6 adds a place to
list definitions and acronyms.
Section 2 of the new framework is a reorganization of Section 2.6 of
the old framework. Section 3 of the new framework is based on a
division of the old Section 3.1 into two parts for naming and
identification and authentication issues. It adds new issues, such
as the permissibility of pseudonyms and anonymity. Old Section 4
topics on audit logging, record archives, key changeover, compromise
and disaster recovery, and CA termination have moved to Section 5.
The remaining Section 4 topics have been expanded and reorganized to
cover a complete certificate lifecycle. New topics include items
implicit in the RFC 2527 Section 4, but now explicit, such as
certificate application processing, certificate modification, and the
end of subscription.
New Sections 5.1 through 5.3 are almost identical to their
counterparts in RFC 2527. The remainder of the new Section 5 is the
topics moved from RFC 2527’s Section 4, in the order that they
appeared in Section 4. Section 6 of the new framework is almost the
same as the old Section 6, with some exceptions, such as the
consolidation of old Section 6.8 (cryptographic module engineering
controls) into Section 6.2.1 (now called "cryptographic module
standards and controls") and the addition of time-stamping in a new
Section 6.8. Section 7 is almost identical to the old Section 7, the
major change being the addition of a section covering OCSP profile.
Section 8 is almost identical to RFC 2527’s Section 2.7.
New Section 9 contains business and legal topics that were covered in
RFC 2527’s Section 2, including fees, financial responsibility,
confidentiality, and intellectual property. It adds a section on the
privacy of personal information, which has become a significant
policy issue. The "liability" Section 2.2 in RFC 2527 now appears in
Sections 9.6 through 9.9, covering representations and warranties,
disclaimers, limitations of liability, and indemnities. Section 9.10
adds a section concerning the duration of the effectiveness of
documentation. Section 9.12 collects terms concerning the way in
which a document (CP, CPS, agreement, or other document) may be
amended, formerly appearing in Section 8.1. Section 9 includes
"legal boilerplate" topics, some of which were in the old Section 2.
Finally, Section 9.17 is a catch-all "other provisions" section where
drafters can place information that does not fit well into any other
section of the framework.
The following matrix shows the sections in the old RFC 2527 framework
and their successor sections in the new framework.
ORIGINAL RFC 2527 NEW RFC SECTION
SECTION
------------------------------------------------------
1. Introduction 1.
------------------------------------------------------
1.1 Overview 1.1
------------------------------------------------------
1.2 Identification 1.2
------------------------------------------------------
1.3 Community and
Applicability 1.3
------------------------------------------------------
1.3.1 Certification
Authorities 1.3.1
------------------------------------------------------
1.3.2 Registration Authorities 1.3.2
------------------------------------------------------
1.3.3 End entities 1.3.3,
1.3.4
------------------------------------------------------
1.3.4 Applicability 1.4, 4.5
------------------------------------------------------
1.4 Contact Details 1.5
------------------------------------------------------
1.4.1 Specification Administration
Organization 1.5.1
------------------------------------------------------
1.4.2 Contact Person 1.5.2
------------------------------------------------------
1.4.3 Person Determining CPS
Suitability for the Policy 1.5.3
------------------------------------------------------
2. General Provisions 2, 8, 9
------------------------------------------------------
2.1 Obligations 2.6.4
------------------------------------------------------
2.1.1 1A Obligations Integrated
throughout
portions of the
framework that
apply to CAs
------------------------------------------------------
2.1.2 RA Obligations Integrated
throughout
portions of the
framework that
apply to RAs
------------------------------------------------------
2.1.3 Subscriber Obligations 4.1.2, 4.4, 4.5,
4.5.1, 4.6.5,
4.7.5, 4.8.1,
4.8.5, 4.9.1,
4.9.2, 4.9.13,
4.9.15, 5., 6.,