[cabf_validation] [EXTERNAL] Draft Ballot SCXX: Improve OU validation requirements

[Paul van Brouwershaven]

This is the latest version of the proposed ballot to strengthen the validation requirements of the OU field:

#### 3.2.2.1.1 Organizational Unit
If the Subject Identity Information is to include an organizational unit, then it MUST be preceded or followed by a whitespace and one of the words “unit”, “department”, “division”, “group”, “service", "system", "center", "office", “school”, “faculty”, "administration", "operations” in singular or plural form; or an unambiguous certified translation of the equivalent in a language other than English.

The CA MUST verify the existence of the organizational unit using an Organizational Chart provided by the human resource offices of the Applicant or that is signed by a listed officer of Applicant.

If a word in the value holds an active registration in the ‘WIPO Global Brand Database’ or a local business register the CA MUST only include these registered values when the CA has verified the right of usage in relation to the Applicant in accordance with Section 3.2.

The value SHALL not be abbreviated unless this would exceed the maximum length of the `subject:organizationalUnitName` field, in which case it SHALL only use locally accepted abbreviation.

i. __Certificate Field:__ `subject:organizationalUnitName` (OID: 2.5.4.11)
   __Required/Optional:__
   __Optional__ if the `subject:organizationName` field is present.
   __Prohibited__ if the `subject:organizationName` is absent.
   __Contents:__ If present, the `subject:organizationalUnitName` field MUST contain the Subject's organizational unit name as verified under Section 3.2.2.1.1.

________________________________
From: Validation <validation-bounces at cabforum.org> on behalf of Dimitris Zacharopoulos (HARICA) via Validation <validation at cabforum.org>
Sent: Monday, November 23, 2020 21:11
To: Ryan Sleevi <sleevi at google.com>
Cc: CA/Browser Forum Validation SC List <validation at cabforum.org>
Subject: Re: [cabf_validation] [EXTERNAL] Draft Ballot SCXX: Improve OU validation requirements


Thank for the detailed response. It summarizes Google's viewpoint on several issues, including Identity.

On 23/11/2020 8:45 μ.μ., Ryan Sleevi wrote:
The Baseline Requirements do not, nor have they ever, permitted CAs to include unverified, self-attested information. Every piece of information included in a certificate has a requirement to be validated by the CA, as captured by 7.1.2.4 of the BRs, as well as more specific individual requirements. It is unfortunate that a CA needs to be reminded of this, or of the principles and motivations, and this applies equally to LEI, OU, or any other field or data the CA might imagine here.

The validation rules for OU are already in the BRs (7.1.4.2.2 i). They have been there for years. It has always been self-attested information. The CA had to "implement a process that prevents an OU attribute from including a name, DBA, tradename, trademark, address, location, or other text that refers to a specific natural person or Legal Entity unless the CA has verified this information in accordance with Section 3.2 and the Certificate also contains subject:organizationName, subject:givenName, subject:surname, subject:localityName, and subject:countryName attributes, also verified in accordance with Section 3.2.2.1."

I would like to highlight that 7.1.2.4 allows for "other fields and extensions" but during the organizationIdentifier discussion, you had expressed a preference that if this validated information were to be included, it should be in an extension rather than the subjectDN.

Regarding the LEI, of course the CA would need to verify/validate the information included in the extension; I never implied that information would not be validated. In my previous post, I mentioned that "BRs allow custom extensions to be defined by CAs (and how CAs validate this information)", so I hope we're in agreement that this is still currently allowed, if a CA meets everything listed in 7.1.2.4.

To use an example, if a CA were to define in its CP/CPS an extension that follows exactly the description of the cabfOrganizationIdentifier as described in section 9.8.2 of the EV Guidelines (my previous example was flawed), describe the same EVG validation rules for that extension and include this extension in an OV Certificate, wouldn't that be compliant with the BRs?


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