Gorry, I've restructured the Privacy Considerations with
https://github.com/anima-wg/anima-brski-prm/pull/151

I split it up into two subsections.

The diff is not too useful for this email, but the resulting section looks like 
this:


# Privacy Considerations {#priv_cons}

The privacy considerations of {{!RFC8995}} also apply for BRSKI-PRM.
Two architectural changes in this document require some additional 
consideration:

* the introduction of the additional component Registrar-Agent
* no TLS between Registrar-Agent and pledge

As logging is recommended to better handle failure situations, it is necessary 
to avoid capturing  sensitive or personal data.
Privacy-preserving measures in logs SHOULD be applied, such as:

* Avoid logging personally identifiable information unless unavoidable.
* Anonymize or pseudonymize data where possible.

## Registrar-Agent identity Privacy Considerations

The credentials used by the Registrar-Agent to sign the data for the pledge 
SHOULD NOT contain any personal information about the owner/operator of the 
Registar-Agent.
So for instance, issuing an EE certificate to the Registrar-Agent that has a 
Subject DN saying something like "Frank Jones' Commissioning Tablet" would be a 
problem.

Therefore, it is recommended to use an EE certificate associated with the 
commissioning device instead of an EE certificate associated with the service 
technician operating the device.
This avoids revealing potentially included personal information to any 
eavesdroppers on the Registrar-Agent/Pledge communication.
Along the Registrar-Agent/Registrar communication path, if TLS 1.2 is used, the 
client certificate details will be revealed to any on path passive attacker.
This is one of the advantages of using TLS 1.3.

## Registar-Agent/Pledge communications

The communication between the pledge and the Registrar-Agent is performed over 
plain HTTP.
HTTPS can not be used as the Pledge's long-term IDevID certificate does not 
contain a SubjectAltName that {{?RFC9525}} DNS-ID verification can use to 
validate the certificate.
In order for this connection to be more secure, the Registrar-Agent would need 
to know precisely which devices (down to the serial number) it expects to 
onboard.
There are some very constrained cases where this might be the case, but for 
many installations, it is not practical.

An active on-path attacker {{onpath}} could trivially impersonate the Pledge at 
the network layer, which is exactly the same situation when not using TLS.
For many installations, a physical cable may be invoved (such as ethernet over 
USB), or a very low power wireless network will be used.
Any active on-path attacker would have to be physically present at the site of 
the device.
Such a physically present attacker could learn the identity of the Pledge by 
simply pretending to be a Registrar-Agent, and asking the device for it's 
identity.
It could equally do this over TLS/HTTPS.

An active on-path attacker can not replace the signed objects that the Pledge 
and Registrar-Agent exchange.

Depending on the requests and responses, the following information is disclosed:

* the Pledge product-serial-number is contained in the trigger message for the 
PVR and in all responses from the pledge.
  This information reveals the identity of the devices being bootstrapped and 
allows deduction of which products an operator is using in their environment.
  As the communication between the pledge and the Registrar-Agent may be 
realized over wireless link, this information could easily be eavesdropped, if 
the wireless network is not encrypted.
  Even if the wireless network is encrypted, if it uses a network-wide key, 
then layer-2 attacks (ARP/ND spoofing) could insert an on-path observer into 
the path.
* the Timestamp data could reveal the activation time of the device.
* the Status data of the device could reveal information about the current 
state of the device in the domain network.

{{tpvr}} describes to optionally apply TLS to protect the communication between 
the Registrar-Agent and the pledge.
The following is therefore applicable to the communication without the TLS 
protection.


--
Michael Richardson <mcr+i...@sandelman.ca>   . o O ( IPv6 IøT consulting )
           Sandelman Software Works Inc, Ottawa and Worldwide




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