Thank you, Ben,

I think that the last sentence in the following proposed text for the second 
paragraph of the security section could attend your second discuss point:

Depending on local policies, some elements, or, most likely, the whole deposit 
will be considered confidential. As such, the parties SHOULD take all the 
necessary precautions such as encrypting the data at rest and in transit to 
avoid inadvertent disclosure of private data. Regardless of the precautions 
taken by the parties regarding data at rest and in transit, authentication 
credentials MUST NOT be escrowed.

If you agree that this covers your feedback, I will include it in the next 
version of the draft.

Regards,
Gustavo

On 5/21/20, 15:07, "Benjamin Kaduk" <ka...@mit.edu> wrote:

    Hi Gustavo,

    Thanks for the updates!
    I think the mention of the ICANN base agreement in the introduction serves
    to give some examples of well-reviewed procedures for escrow, and is enough
    to resolve my first discuss point.

    I don't see a whole lot that looks relevant to my second point about
    (potential) escrow of authentication credentials, though.  If I remember
    correctly we discussed that the intent was for those to not be included in
    the escrow dumps, but I don't remember whether we talked about putting any
    clarifying text in the document.

    Thanks,

    Ben

    On Wed, May 13, 2020 at 06:45:38PM +0000, Gustavo Lozano wrote:
    > Hi Benjamin,
    > 
    > I think that the latest version of the draft covers your feedback.
    >  
    > Here are the differences between 07 and 08, and 08 and 09:
    > 
https://urldefense.proofpoint.com/v2/url?u=https-3A__tools.ietf.org_rfcdiff-3Furl2-3Ddraft-2Dietf-2Dregext-2Ddata-2Descrow-2D08.txt&d=DwIDaQ&c=FmY1u3PJp6wrcrwll3mSVzgfkbPSS6sJms7xcl4I5cM&r=VbweciUcwYQpIOZDSxl0ezGd1hGDtd-0BvgAgfmwfE0&m=VDCiJAnAswUQ4avJ55sPxmYR4hLKtN9JoiudmZhps0M&s=ilArbwqLMrfNyTwmcvU6fk9KseAXlQKxRccN-kUQhOo&e=
 
    > 
https://urldefense.proofpoint.com/v2/url?u=https-3A__tools.ietf.org_rfcdiff-3Furl2-3Ddraft-2Dietf-2Dregext-2Ddata-2Descrow-2D09.txt&d=DwIDaQ&c=FmY1u3PJp6wrcrwll3mSVzgfkbPSS6sJms7xcl4I5cM&r=VbweciUcwYQpIOZDSxl0ezGd1hGDtd-0BvgAgfmwfE0&m=VDCiJAnAswUQ4avJ55sPxmYR4hLKtN9JoiudmZhps0M&s=iNhLzs77vPa3t0ibX42lkY967mU9pwYMkPEIU1slI1U&e=
 
    > 
    > Thoughts? 
    > 
    > Thank you,
    > Gustavo
    > 
    > On 4/20/20, 18:05, "Benjamin Kaduk" <ka...@mit.edu> wrote:
    > 
    >     Hi Gustavo,
    > 
    >     On Thu, Apr 16, 2020 at 10:26:40PM +0000, Gustavo Lozano wrote:
    >     > Thank you, Benjamin,
    >     > 
    >     > Comments inline, prefixed with GL -.
    >     > 
    >     > Regards,
    >     > Gustavo
    >     > 
    >     > On 4/8/20, 09:01, "Benjamin Kaduk via Datatracker" 
<nore...@ietf.org> wrote:
    >     > 
    >     >     Benjamin Kaduk has entered the following ballot position for
    >     >     draft-ietf-regext-data-escrow-07: Discuss
    >     > 
    >     >     When responding, please keep the subject line intact and reply 
to all
    >     >     email addresses included in the To and CC lines. (Feel free to 
cut this
    >     >     introductory paragraph, however.)
    >     > 
    >     > 
    >     >     Please refer to 
https://urldefense.proofpoint.com/v2/url?u=https-3A__www.ietf.org_iesg_statement_discuss-2Dcriteria.html&d=DwICaQ&c=FmY1u3PJp6wrcrwll3mSVzgfkbPSS6sJms7xcl4I5cM&r=VbweciUcwYQpIOZDSxl0ezGd1hGDtd-0BvgAgfmwfE0&m=XLPt-K5FLKU1oce9PiZyutUV1_UJqbd348-sDIlLCD8&s=9EVCPSTvj9RgWF9Z3e7HBLsbaPg6R2CPwDhbFPM8sEM&e=
 
    >     >     for more information about IESG DISCUSS and COMMENT positions.
    >     > 
    >     > 
    >     >     The document, along with other ballot positions, can be found 
here:
    >     >     
https://urldefense.proofpoint.com/v2/url?u=https-3A__datatracker.ietf.org_doc_draft-2Dietf-2Dregext-2Ddata-2Descrow_&d=DwICaQ&c=FmY1u3PJp6wrcrwll3mSVzgfkbPSS6sJms7xcl4I5cM&r=VbweciUcwYQpIOZDSxl0ezGd1hGDtd-0BvgAgfmwfE0&m=XLPt-K5FLKU1oce9PiZyutUV1_UJqbd348-sDIlLCD8&s=Avsh9DG_m3aLijuq_I7ulh5IMkYG78XIOq1Puctc2ZU&e=
 
    >     > 
    >     > 
    >     > 
    >     >     
----------------------------------------------------------------------
    >     >     DISCUSS:
    >     >     
----------------------------------------------------------------------
    >     > 
    >     >     Let's have a discussion about the overall plans for providing 
guidance
    >     >     on mechanisms for (e.g.) cryptographic confidentiality and 
integrity
    >     >     protection of data both in transit and at-rest,
    >     >     authentication/authorization requirements, etc..  In 
particular, what
    >     >     it's appropriate and necessary to include in this document vs. 
other
    >     >     documents, and how to provide some specific general baseline 
guidance
    >     >     that can be used in the absence of conflictinc scenario-specific
    >     >     deployment requirements.  Some further details in the COMMENT 
section,
    >     >     but in general, it seems like there should be some 
"off-the-shelf"
    >     >     mechanism that can be used without a need for every deployment 
to do a
    >     >     custom thing, for cases where there are not custom 
requirements.  It may
    >     >     not need to be part of this document, but we should have a plan 
for
    >     >     where it will be.
    >     > 
    >     >     Also, it's not clear to me whether we expect escrow of
    >     >     credentials/verifiers used to authenticate/authorize fourth 
parties that
    >     >     perform operations (e.g., registrations) at the registry (see 
comment on
    >     >     Section 3), and that is pretty important for knowing what 
security
    >     >     requirements to place on the escrow'd data.
    >     > 
    >     > 
    >     > GL - 
    >     > 
    >     > I interpret your message:
    >     > 
    >     >     A new draft could provide the guidelines to implement an escrow 
service that requires strong security controls. 
    >     > 
    >     > In the gTLD space, the legal agreements and processes (e.g. 
accreditation, etc.) that govern escrow services make the need for this new 
draft low priority. However, other parties (e.g., ccTLDs) interested in 
implementing an escrow service could benefit from such a document.
    > 
    >     Maybe we could keep a reference to (e.g.) "Specification 2" of the 
ICANN
    >     base registry agreement outside of the Implementation Status section 
(that
    >     will be removed upon pulbication), to give readers a sense for what 
kind of
    >     prior art there is.
    > 
    >     > If the IESG does not object to this idea, probably the current 
security section in the draft could work with a few tweaks.
    > 
    >     I do not see a reason why someone would object.  (I assume that the
    >     "tweaks" would include things like specifying to use TLS 1.3 or 
something
    >     specific in order to meet the various checking requirements.)
    > 
    > 
    >     That said, my main question in the first paragraph here was to get a 
sense
    >     for what has already been done and what plans there are for future 
work.
    >     Given the existence of ICANN's document and a potential plan to write 
our
    >     own generic document, I don't feel a strong need to put specific
    >     protocol/mechanism guidance in this document, provided that we can 
refer to
    >     one or both of the aforementioned items (whether as "WIP" or 
otherwise).
    > 
    >     >     
----------------------------------------------------------------------
    >     >     COMMENT:
    >     >     
----------------------------------------------------------------------
    >     > 
    >     >     I agree with Roman that the link to the charter is tenuous; 
perhaps this
    >     >     is a "data format for files exchanged between registration 
entities that
    >     >     needs extraction from EPP or RDAP", but it's not a perfect fit.
    >     > 
    >     >     Section 1
    >     > 
    >     >        The goal of data escrow is higher resiliency of registration
    >     >        services, for the benefit of Internet users.  The 
beneficiaries of a
    >     >        registry are not just those registering information there, 
but all
    >     >        relying parties that need to identify the owners of objects.
    >     > 
    >     >     Only relying parties that need to identify *owners* 
specifically (as
    >     >     opposed to consuming other registered data)?
    >     > 
    >     > GL - I think the following text addresses your comment, do you 
agree?
    >     > 
    >     > The goal of data escrow is higher resiliency of registration 
services, for the benefit of Internet users.  The beneficiaries of a registry 
are not just those registering information there, but also the users of 
services relying on the registry data.
    > 
    >     I agree, thanks.
    > 
    >     >        In the context of domain name registries, registration data 
escrow is
    >     >        a requirement for generic top-level domains and some country 
code
    >     >        top-level domain managers are also currently escrowing data. 
 There
    >     >        is also a similar requirement for ICANN-accredited domain 
registrars.
    >     > 
    >     >     Are there easy references for these requirements being 
requirements?
    >     > 
    >     > GL - I understand your comment: adding the documents where the 
requirements for escrow are defined for gTLDs as informative references in the 
draft. Am I correct?
    > 
    >     Yes.  (I guess I should have read this part before I wrote above 
about the
    >     ICANN stuff.)
    > 
    >     >     Section 2
    >     > 
    >     >        Watermark.  If the Timeline Watermark of an Incremental 
Deposit were
    >     >        to cover the Timeline Watermark of another (Incremental or
    >     >        Differential) Deposit since the last Full Deposit, the more 
recent
    >     >        deposit MUST contain all the transactions of the earlier 
deposit.
    >     > 
    >     >     Do we define what it means for one Timeline Watermark to 
"cover" another?
    >     > 
    >     > GL - I think the following text addresses your comment, do you 
agree?
    >     > 
    >     > If the Timeline Watermark of an Incremental Deposit were to cover 
(i.e., one or more Incremental or Differential deposits exist for the period 
between the Timeline Watermark of a Full and an Incremental or Differential 
Deposit) the Timeline Watermark of another Incremental or Differential Deposit 
since the last Full Deposit, the more recent deposit MUST contain all the 
transactions of the earlier deposit.
    > 
    >     That should work, yes.
    > 
    >     >     Section 3
    >     > 
    >     >        Specifications covering the objects used by registration
    >     >        organizations shall identify the format and contents of the 
deposits
    >     >        a registry has to make, such that a different registry would 
be able
    >     >        to rebuild the registration services of the former, without 
its help,
    >     >        in a timely manner, with minimum disruption to its users.
    >     > 
    >     >     Rebuilding registration *services* as opposed to just 
*operation* sounds
    >     >     like it will require also escrowing credentials/credential 
verifiers
    >     >     used to authenticate to the registration organization in order 
to make
    >     >     use of such services. 
    >     > 
    >     > GL - Not necessarily. For example, in the case of a domain 
Registry, a domain Registrar could re-set the credential verifier. 
    >     > 
    >     >     Such credentials would of course need very
    >     >     careful protection both in transit and at rest, in order to 
avoid
    >     >     compromising the integrity of the primary operations of the 
current
    >     >     registration organization.
    >     > 
    >     > GL - Correct, escrowing of credentials/credential verifiers require 
strong security controls. See my suggestion at the DISCUSS section of this 
email.
    > 
    >     Okay, it seems like we are in agreement :)
    > 
    >     >        Given the requirement for confidentiality and the importance 
of
    >     >        accuracy of the information that is handled in order to offer
    >     >        registration services, parties using this specification 
shall define
    >     >        confidentiality and integrity mechanisms for handling the
    >     >        registration data.
    >     > 
    >     >     Do we have any recommendations/examples of such mechanisms in 
the
    >     >     pipeline?
    >     > 
    >     > GL - Not that I am aware of.
    >     > 
    >     >        Specifications covering the objects used by registration
    >     >        organizations shall not include in the specification 
transient
    >     >        objects that can be recreated by the new registry, 
particularly those
    >     >        of delicate confidentiality, e.g., DNSSEC KSK/ZSK private 
keys.
    >     > 
    >     >     I'm not sure this is going to be terribly helpful guidance for
    >     >     non-domain-name data.  I am acutely aware that cryptographic 
(symmetric
    >     >     and/or private) keys are not the only type of data that this 
could apply
    >     >     to, but it is the only type that I know of a concise/precise 
description
    >     >     for.  E.g., "cryptographic key material that is vital to the 
integerity
    >     >     and/or security of operation of the registry and the systems 
that rely
    >     >     on it but that is not vital to the continuity of operations 
(e.g.,
    >     >     DNSSEC KSK/ZSK private keys)".
    >     > 
    >     >     Also, I would assume that the authenticatoin credentials I 
mention above
    >     >     would not qualify for this requirement, since they are not 
things that
    >     >     can be recreated by the new registry.
    >     > 
    >     >        Details that are a matter of policy should be identified as 
such for
    >     >        the benefit of the implementers.
    >     > 
    >     >     (For human consumption or machine consumption?)
    >     > 
    >     > GL - Both. For example, in draft-ietf-regext-dnrd-objects-mapping, 
there is an object to specify aspects of policy for machine consumption.
    > 
    >     Ah, thanks for the pointer.
    > 
    >     >     Section 4
    >     > 
    >     >     Could we maybe use the section title "Conventions Used in This
    >     >     Document"?  "General Conventions" could be interpreted as 
intended for a
    >     >     broader scope, though based on (e.g.) RFC 8748 I don't think 
that's the
    >     >     intent.
    >     > 
    >     > GL - Agree, changed the title to "Conventions Used in This 
Document" in the new version of the draft.
    >     > 
    >     >     Section 5
    >     > 
    >     >        registry.  The deposits are represented in XML.  Only the 
format of
    >     >        the objects deposited is defined, nothing is prescribed 
about the
    >     >        method used to transfer such deposits between the registry 
and the
    >     >        escrow agent or vice versa.
    >     > 
    >     >     nit: comma splice.
    >     > 
    >     > GL - Fixed in new version of the draft.
    >     > 
    >     >     Also, we said earlier that "parties using this specification 
shall
    >     >     define confidentiality and integrity mechanisms for handling the
    >     >     registration data" without, AFAICT, conditions on when that 
should be
    >     >     done.  So in some sense we do prescribe properties of the 
method used
    >     >     for transfer, if I'm reading that correctly.
    >     > 
    >     > GL - The sentence on section 5 is about not prescribing the 
transport mechanism.
    >     > 
    >     >     Section 5.1.1
    >     > 
    >     >        A REQUIRED <watermark> element contains the data-time 
corresponding
    >     >        to the Timeline Watermark of the deposit.
    >     > 
    >     >     I will offer a third opinion, that this was meant to be 
dateTime.
    >     > 
    >     > GL - Correct, changed to date-time in the new version of the draft.
    >     > 
    >     >     Section 5.1.2
    >     > 
    >     >     I'm confused about the relationship between the <objURI> 
elements in the
    >     >     <rdeMenu> and the objects in the <deletes> and <contents> 
elements -- is
    >     >     <rdeMenu> just a list of "here are all objects that this update
    >     >     touchers", with the details in the other sections?
    >     > 
    >     > GL - Correct. You may want to take a look at the examples in 
draft-ietf-regext-dnrd-objects-mapping for further clarity.
    > 
    >     Ah, that does look helpful, thanks.  Is there a way we could 
reference that
    >     document from this one as an example application?
    > 
    >     >     Section 5.1.4
    >     > 
    >     >        If an object is present in the <contents> section of several 
deposits
    >     >        (e.g.  Full and Differential) the registry data from the 
latest
    >     >        deposit (as defined by the Timeline Watermark) SHOULD be 
used when
    >     >        rebuilding the registry.
    >     > 
    >     >     Why is this not a MUST?
    >     > 
    >     > GL - To cover the case when the more recent differential deposit is 
deemed to be invalid, and a previous differential deposit needs to be used for 
rebuilding a registry.
    >     > 
    >     >     Section 6.1
    >     > 
    >     >     Why is there a 13-character maximum for the deposit ID?
    >     >     But client IDs range from 3 to 16 characters (which seems kind 
of short
    >     >     as a maximum, especially if a registrar wants to use a domain 
name as an
    >     >     identifier)?
    >     > 
    >     > GL - Inherited from EPP.
    > 
    >     I don't have a great sense for how strongly the EPP heritage justifies
    >     keeping the (artificial) limit, i.e., whether any non-domain-name 
usage of
    >     this mechanism would benefit much from longer identifiers.
    > 
    >     >         <!-- A RDE version number is a dotted pair of decimal 
numbers -->
    >     >         <simpleType name="versionType">
    >     >           <restriction base="token">
    >     >             <pattern value="[1-9]+\.[0-9]+"/>
    >     >             <enumeration value="1.0"/>
    >     >           </restriction>
    >     >         </simpleType>
    >     > 
    >     >     I assume the <pattern> is there to give the overall structure 
that
    >     >     subsequently defined <enumeration>s will adhere to?
    >     > 
    >     > GL - Correct.
    >     > 
    >     >     I see the rrType defined but not used anywhere; is it still 
needed in
    >     >     this document?
    >     > 
    >     > GL- The element is used in 
https://urldefense.proofpoint.com/v2/url?u=https-3A__tools.ietf.org_html_draft-2Dietf-2Dregext-2Ddnrd-2Dobjects-2Dmapping&d=DwIDaQ&c=FmY1u3PJp6wrcrwll3mSVzgfkbPSS6sJms7xcl4I5cM&r=VbweciUcwYQpIOZDSxl0ezGd1hGDtd-0BvgAgfmwfE0&m=8HUUPMzc75s9UE1V5gfdMVutMywATqGNU1WgLrT_Zqo&s=iYw77kgL26humLs0O00-I6G-NTOlGIOk2iBivV7qWoI&e=
 . The element is in the schema for backward compatibility. There is a comment 
in the schema explaining that these are auxiliary elements.
    > 
    >     What prevents moving the definition to that other document?
    > 
    >     >     Section 10
    >     > 
    >     >        Authentication of the parties passing data escrow deposit 
files is
    >     >        also of the utmost importance.  The escrow agent SHOULD 
properly
    >     >        authenticate the identity of the registry before accepting 
data
    >     >        escrow deposits.  In a similar manner, the registry SHOULD
    >     >        authenticate the identity of the escrow agent before 
submitting any
    >     >        data.
    >     > 
    >     >     I am failing to come up with a scenario in which these SHOULDs 
would be
    >     >     violated; should they be MUSTs instead?  (I'd like for the 
"encrypting
    >     >     the data" in the previous paragraph to be a MUST as well, but 
that case
    >     >     is less clear-cut.)
    >     > 
    >     > GL - I will change the authentication SHOULDs to MUSTs in the new 
version of the draft.
    >     > 
    >     >        Additionally, the registry and the escrow agent SHOULD use 
integrity
    >     >        checking mechanisms to ensure the data transmitted is what 
the source
    >     >        intended.  Validation of the contents by the escrow agent is
    >     > 
    >     >     It seems like if there are no integrity checks then the escrow 
mechanism
    >     >     is not really fit for purpose -- can't this be MUST?
    >     > 
    >     > GL - Sounds good, I will change this to a MUST.
    >     > 
    >     >     Section 11
    >     > 
    >     >        This specification defines a format that may be used to 
escrow
    >     >        personal data.  The process of data escrow is governed by a 
legal
    >     >        document agreed by the parties, and such legal document must 
regulate
    >     >        the particularities regarding the protection of personal 
data.
    >     > 
    >     >     "Regulate the particularities" is an interesting phrase, as it 
merely
    >     >     specifies that some restrictions be made, but nothing about the 
nature
    >     >     of them.  Shouldn't we be saying something like "ensure that
    >     >     privacy-sensitive and/or personal data receives appropriate 
protection"?
    >     > 
    >     > GL - I think the following text addresses your comment, do you 
agree?
    >     > 
    >     > This specification defines a format that may be used to escrow 
personal data.  The process of data escrow is governed by a legal document 
agreed by the parties, and such legal document must ensure that 
privacy-sensitive and/or personal data receives the required protection.
    > 
    >     Yes, thanks!
    > 
    >     >     Section 14, 15, 16
    >     > 
    >     >     Could we not reuse the same deposit-id for different examples?
    >     >     (Also, using 20191017001 with a watermark date of 2019-10-18
    >     >     midnight-UTC is perhaps unnecessary cognitive dissonance.)
    >     > 
    >     > GL - Agree, I will change this.
    >     > 
    >     >     Is it appropriate to use the urn:ietf:params:xml:ns:rdeObj[N] 
namespaces
    >     >     in the examples, vs. a dedicated "example" namespace?
    >     > 
    >     > GL - Agree, I will change this to the example URN namespace.
    > 
    >     Thanks for this and all the other clarifications and updates that I 
didn't
    >     specifically respond to!
    > 
    >     -Ben
    > 

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