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Re: draft-ietf-ltans-dssc-00 comments
Susanne
that doesn't make sense from either EU Laws or those of the US as well.
Sorry if this is a like a bucket of very cold water in the face, but its
time to wake up and smell the coffee... Any long term document storage and
management protocol MUST take into account any and all laws which would
constrain the operations and formulation of the proofing models it (said
protocol) produces.
And within that global requirement, all evidence-standards pretty much
require a 'full chain of custody' to be proven and without that, their
content will not be admissible in the US Courts and any Court's the US has
Joint Judicial MRA's with(Mutual Recognition Agreements). As such the
entire chain of custody and each signing and resigning needs to be resolved
and proven or there is an imperfect history for the LTANS protected file.
While this may seem like its not something that is important the 'setting
aside of this requirement' will in the US Make LTANS unusable since the
Court's wont accept it as a reliable method of storing information. That
means the ETSI TSA recommendation is PROBABLY also in jeopardy since it
clearly violates the intent and scope of those same laws as well...
The funniest part is that this WG wants to take the word (and the consensus)
of technical people who have NO EXPERIENCE in pursuing legal recourse for IP
issues or the complexity and pain of that process, which is typical for the
IETF... "We know everything" & "Our consensus is always right".
The reality here is that without specific and very particular controls and
legal processes LTANS isn't going to get used anywhere because the Audit
Community cannot take the chance that the client's who use LTANS's wont be
able to prove anything with it.
Todd Glassey
----- Original Message -----
From: "Susanne Okunick" <susanne.okunick@xxxxxxxxxxxxxxxxx>
To: "Tobias Gondrom" <tgondrom@xxxxxxxxxxxx>
Cc: <ietf-ltans@xxxxxxx>
Sent: Monday, September 10, 2007 6:50 AM
Subject: RE: draft-ietf-ltans-dssc-00 comments
Hello Tobias,
we agree with all of your remarks. Thanx.
We also don't see any complications regarding the legislation (at least
German law requires the renewal of signatures).
We are going to adapt our draft in this way, that a policy should also
contain expired algorithms. So for verfication only the current policy
is needed.
Best regards
Thomas and Susanne
Hi Thomas, Susanne, Todd, Carl and all,
Maybe a few thoughts about the discussed items:
Starting with the simple things:
I agree with Carls assessment that for the verification the critical
information is the policy stating which algorithms had been valid from
date a to date b. Period.
I understand your idea of providing older policies to support the fact
that an archive service did operate correctly, but this is not the main
reason for the policy in the verification process.
The main use for the policy is that any verification party can use it
and check an ERS or other signatures whether any of the used algorithms
had been broken before they were renewed. (this is a precise
mathematical test, and does not automatically imply careless handling of
the archive system).
For the verification party only this hard facts count: Has the signature
been renewed in time or not, defined by the current policy.
(the old policies may indicate a wrong-doing of the archive system or
justify its actions but they must not influence the evaluation of
"valid"/"not-valid".
(comment: and if it happens that the policy issuing authority
retrospectively shortens the timespan of an algorithm, this will be for
a reason which should not be ignored.)
Concerning the issuing of the policy: I think that to prove its
authenticity and integrity it should be sufficient to sign it (via CMS)
by the authority (e.g. NIST, German Bundesnetzagentur, ...)
I can not see any real problematic legal inter-country related
implications.
A signature must be valid in the country where it is presented to the
court.
Which includes the renewal done with ERS must be so as well.
In court the judge will call upon the guidance of the countries security
authority (in case of US this would be NIST) to decide whether
algorithms are secure or have been broken and when. If these authorities
publish this statement in the form of a signed policy, this would be a
clear and reliable statement. (today they publish this in unsigned pdf
and on paper)
Dito in other countries.
(obviously as these judgements of algorithms can vary between countries,
an archiving service would have the duty to watch carefully for
algorithm lifetime announcements the local national bodies corresponding
to its stored documents make)
Best regards, Tobias
--
___________________________________________________________
Dipl.-Math.(FH) Susanne Okunick
Fraunhofer Institute for Secure Information Technology
Department Transaction and Document Security
Rheinstraße 75, 64295 Darmstadt, Germany
phone ++49 / (0)6151 869 60005, fax ++49 / (0)6151 869 322
homepage: http://www.sit.fraunhofer.de
___________________________________________________________
The electronic Signature is certified by the Fraunhofer CA:
http://pki.fraunhofer.de/FhG-CA-Certs/FhG-CA_v2_cert.der
___________________________________________________________