Hi Gustavo,

I think that proposed text will work; please go ahead and include it in the
next vesrion of the draft.

Sorry for the slow response,

Ben

On Fri, May 22, 2020 at 07:26:03PM +0000, Gustavo Lozano wrote:
> 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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