TSCP Comments on draft-ietf-pkix-authorityclearanceconstraints-02.txt

["Rob Sherwood" <Rob.Sherwood@xxxxxxxxxxx>]

I am writing this message on behalf of the TSCP (http://www.tscp.org),
to present our thoughts on the draft specification "Clearance Attribute
and Authority Clearance Constraints Certificate Extension"
(draft-ietf-pkix-authorityclearanceconstraints-02.txt). Based on review
of the specification with our TSCP membership and discussion of the
proposal, we wish to raise the following concerns regarding this
specification:

1. Firstly, there is no articulation of intent for use of this standard
in an implementation. It is unclear whether this is a solution in search
of a problem, or whether a use case has been articulated. Given the
close relationship between the CertiPath/TSCP membership and the DoD, we
are concerned that the unknown use case may impact the certificate
profile or policy currently implemented within the A&D Community.
Accordingly, the A&D community represented in the TSCP would like to
have visibility regarding the intent of the standard. 

2. In many cases, individuals are forbidden to disclose the fact that
they hold a clearance. This proposal, if adopted for use in human
subscriber certificates, would either force violation of this rule or
create the need for individuals to maintain multiple certificates.

3. The list of clearances (ClassList) is incorrect. It appears to be a
mixture of clearances and data sensitivity markings. This makes the
intent of the specification unclear, as it seems to be applicable to
both individuals and resource managers.

4. Clearance level declarations are incomplete. Declaration of clearance
without investigation level (NACI, Poly, etc) and issuer (DoD, Treasury,
etc.) is insufficient to determine what resources may be shared.

5. A specification of sensitivity/clearance in a certificate may be
useful for device certs or attribute certs, as a way to ensure that
networks of a certain classification are closed, and that communication
within and between them is protected, however the issues with the
clearance list suggest that this proposal may not serve this need.

We are not necessarily opposed to the specification, but we would first
like to understand the details of the intent behind the specification,
and would like to discuss the issues with the draft specification
documented above.

Robert Sherwood 
Design Authority | Transglobal Secure Collaboration Authority
13530 Dulles Technology Dr, Ste 200, Herndon, VA 20171
PH +1.703.793.7705 (W) +1.703.362.2329 (M)