Minutes of the December 17-18, 1997 Meeting of the Technical Advisory Committee to Develop a Federal Information Processing Standard for the Federal Key Management Infrastructure Wednesday, December 17, 1997 A quorum being present, the seventh meeting of the Committee was called to order at 9:05 a.m. by the Chair, Dr. Stephen Kent. In addition to the Chair, members present were: Joe Alexander, Josh Benaloh, David Carman, Santosh Chokhani, Paul Clark, John Edwards, Mark Etzel, Ken Konechy, Bill Franklin, Roger French, Daniel Harkins, Richard Hite, Russ Housley, Paul Lambert, Mike Markowitz, Mike Matyas, and Joe Pato. Government liaisons in attendance were: Elaine Barker, Clem Boyleston, Dianne Dunshee, Barbara Kirsch, Bruce Kutz, Julie Lever, Jan Manning, John Sabo, and Miles Smid. Also attending was Mark Bohannon of the Department of Commerce. Ed Roback, Executive Secretary, welcomed everyone and reviewed the agenda for the two day meeting, which was comprised of a series of working group reports, ensuing discussion, and editing of draft requirements. (See Reference #1.) Special mention was made of the need to complete and file the confidential financial disclosure forms with the Secretary before the next TAC meeting. As with all TAC meetings, the entire meeting was conducted in open, public session. Dr. Kent's Opening Remarks Dr. Kent began by thanking the three members for their demonstrations/ informal briefings of the prior day. Next, turning to the draft work products of the WGs, Dr. Kent noted that the language needs to be more "compliance oriented" (i.e., to provide sufficient information for use by a testing organization to determine conformance to the standard.) As was mentioned in October, the WG documents need to be cross-reviewed for consistency and the TAC needs to review the drafts in order to ascertain whether anything is missing. Federal Liaison Perspectives - Mark Bohannon Before proceeding to the WG reports, Dr. Kent asked Mark Bohannon, Chief Counsel for the Technology Administration at the U.S. Department of Commerce, to provide the TAC with a summary of a meeting of the TAC federal liaisons held on November 18. The meeting was held to address three issues which arose at the TAC's October meeting: applicability of the KR standard, tiering and interoperability. (See reference for prepared presentation.) Mr. Bohannon stated that the government's policy is that key recovery will be used whenever cryptography is used for confidentiality purposes. The liaisons agreed that it would be inappropriate to include a tier in the standard that was not approved for government use. The liaisons suggested two tiers, a principal distinguishing feature between the two being whether key recovery is "always on" or is on by default but could be administratively disabled. Regarding interoperability, the liaisons thought that given TAC's timeframe, and early stage of key recovery technology, interoperability protocols (e.g., between a key recovery requester and KRA) need not be requirements of the initial TAC recommendations if they will delay the TAC's progress. On the topic of time criticality, Mr. Bohannon stated that agencies are pushing to have a FIPS developed in order for them to proceed with their planned and pending agency procurements. Therefore, he is hoping for the TAC to deliver a document to the Secretary in February. He reminded the group that this standard will likely have a two year review period in order to accommodate technology changes that may occur. Working Group #1 (Framework) Status Report - Roger French Mr. French gave a briefing on the efforts of this group since the last meeting. WG#1 had distributed their material prior to the TAC meeting, but no comments were received. (See references.) The issue of tiering needs to be addressed quickly. He suggested that there be one central compiler of all the working group reports and have them incorporated into one draft document. Miles Smid volunteered that NIST would be willing to gather all of the inputs and produce one single draft document, if requested. Working Group #2 (Security Models) Status Report - Josh Benaloh Dr. Benaloh began by noting his appreciation for the work of Santosh Chokhani and Diane Dunshee in turning the WG#2's goals in FIPS language. He feels that an appropriate framework and skeleton are now in place. Jan Manning and Diane Dunshee developed a matrix of security requirements (see references) which was distributed and the subject of much discussion later in the meeting. Working Group #5 (Interoperability) Status Report - Paul Clark The working group had a handout in the meeting material package. Interoperability requirements were "exported" to WG#1 and WG#2. Question on protocol for interoperability was raised by Paul Clark. He asked what the the liaisons' point of view was on this issue. The general feeling seemed to be, in short, if interoperability specifications can be provided without holding up the TAC's progress, that would be welcomed. Working Group #8 (Documentation and Assurance) Briefing - Santosh Chokhani Prepared handout material of his group's efforts was distributed (see references). Mr. Chokhani plans to address comments made by Miles Smid who suggested that a section be added to the security functional and assurance requirements stating that these requirements can be met using FIPS 140-1 level n and TCSEC or Common Criteria profile Y, plus the following additional TCSEC or CC requirements, plus the following key recovery unique requirements. (See referenced e-mail note distributed at meeting, dated 12/10/97). Chairman's Comments Next, the Chairman spent time expressing his views and comments on certain areas of the documents. Overall, there is a need to look at specific sections to better integrate them in to already existing sections. Some sections continue to be written at considerably differing levels of detail. The security requirements section is very well along and in accordance with the output from WG#8. There is a need to add supporting components which are not addressed yet, address the tier issue, and look at the descriptions from a vendor's point-of-view (as in trying to build a compliant component). Dr. Kent also noted that there were a number of significant changes since the last WG#1 product was distributed, which need to be discussed with the larger membership, including the definitions of category 1 and 2, and the table defining what is covered within the scope of the FIPS. Sections 1.1 - 1.3 do not have quite the right flavor for a FIPS. The examples are all RSA-based and need to be more general. The requirements on each of the supporting components need to be refined and expanded. The TAC also needs to review the announcement section. Discussion The Committee then began to review the announcement section, beginning with the working title, "Cryptographic Key Recovery Systems." Since the FIPS will be component-based, there was concern about including the term "system" in title. After much discussion, and examination of alternatives, the TAC agreed to changing the working definition to "Key Recovery Standard." It will be clear from other sections of the announcement that the standard only applied to confidentiality keys. After re-convening following the lunch break, Mr. Roback passed on Mr. Gilmore's regrets at being unable to attend this meeting. He asked that the TAC be re-assured of his continuing keen interest in the TAC's activities. The TAC then proceeded to review the announcement section. Many specific suggestions were made, including the need to revise the draft to reflect the two-year review period, and the use of the terms "audit and monitoring" vice surveillance. Dr. Kent pointed out that particular attention should be paid to the "qualifications" paragraph and perhaps phrased differently in regards to the security parameters. NIST will rework the qualification statement. In discussions regarding the expected time gap between completion of the standard and the establishment of the conformance testing program, Dr. Kent asked that all members let him know if vendors should be able to claim compliance to the standard (before the validation program is in place) as being sufficient for federal agency procurement. (ACTION - ALL MEMBERS) There was considerable discussion as to whether the cryptographic mechanisms used for key recovery should be stronger than (or equal to) the maximum strength of the cryptography being employed for confidentiality protection OR stronger than (or equal to) the minimum strength of the cryptography being employed for confidentiality protection. This led to a discussion of a validating laboratory would compare strengths of various algorithms. After a break, the discussion then turned to the "Security Requirements" matrix. Jan Manning conducted a briefing on the security requirements table covering the key recovery enabled end user product and the key recovery agent. There were language difficulties regarding security requirements and assurance levels, often being mis-equated. A suggestion was made that the matrix include additional tiers. Many edits were suggested and specific areas will be reworded based on input from the members and the liaisons. The remainder of the days agenda was spent going over each element of the security requirements. One particular action item that emerged was for WG#2 to develop a proposed requirement for the strength of authentication mechanism (ACTION - WG#2). The meeting was recessed for the day at 5:40 p.m. Thursday, December 18, 1997 Discussion, cont. The meeting was resumed at 9:05 a.m. Mike Matyas presented a new definition of Tier 1 and Tier 2 characterization. With particular regard to the number of KRAs, he suggested that at Tier 1, one KRA is sufficient, while at the Tier 2, the capability must exist to accomplish KR with one KRA and also with multiple KRAs. He also distributed a draft "Overview" section to put the FIPS in perspective. (See references.) A discussion followed on the need for accompanying guidance for agencies using the FIPS, which the liaisons had also discussed at their November meeting. There is, additionally, a need for an introductory paragraph for the FIPS, which would place the standard in context (e.g., as the risks to organizations grow from the unavailability of information, KRAs are established, which themselves could become targets…) Next, Russ Housley presented his definition of what was meant by the term "confidentiality." Key recovery information must be protected using encryption that is as strong or stronger than the algorithm associated with the recoverable key. Discussion turned to the draft framework sections of the report. First, Dr. Kent brought up the topic of Section 1.4 on systems policy and the correct use of the terminology "systems policy." There is a need for a separate document that has more of a systems flavor, suggested Dr. Kent, since the FIPS is component-focused. When the draft FIPS is delivered to the Secretary, the cover letter should lay out what this FIPS covers, and what other supporting documents/guidance the TAC suggests are necessary. Also, the qualification section of the document could also include similar information of explanation. Elaine Barker will draft a sample paragraph to cover this. (ACTION - Ms. Barker) Additionally, it was suggested that the appendix contain a section similar to the systems policy section. A guidance appendix would cover a lot of these issues that the TAC thinks are important, like the systems policy issue, and that the users will find it very helpful until another guidance document can be developed, suggested Mr. Smid. Two different kinds of methods may be necessary offered Dr. Benaloh: 1) a concise list of mandatory options imbedded in the document as well perhaps listed independently for quick reference and 2) a list of mandatory options for affirmation that a product may provide an option and still be FIPS compliant. An agreement was reached that Section 1.4 will be pared down and include an outline for policy that government and agencies would make use of and made into an appendix to the FIPS. Dr. Benaloh stressed the need for the FIPS to clearly state that products may have many other options and still be FIPS-compliant. Members are to provide comments on section 1.4 to Dr. Benaloh as soon as possible and he will develop a draft appendix. (ACTION - Members) Prior to the lunch break, Dr. Etzel observed that the TAC is doing a good job of starting to tackle the major issues, but not all of them have yet been identified or resolved. This led to a discussion of whether the TAC will be ready for a vote in February for delivery of a product to the Secretary. Dr. Kent indicated his desire to meet that goal, since the Secretary clearly desires the TAC's work by then, as Mr. Bohannon indicated earlier; however, a show of hands expressed unanimity among TAC members that this would be impossible to achieve. Concerns were discussed about the quality and completeness of the technical work which could be delivered in February. Discussion then moved on to review of section 1.5 on Interoperability. It was agreed that private key escrow is an acceptable approach to having FIPS compliant products. Dr. Matyas discussed his key recovery enablement process vugraph [Figure 1 in Section l.2] and stated that the recovery information medium could be the same in the many different mediums, and does not have to be directly associated. There was concern on the part of members as to the inclusiveness of the current model. Further discussion lead to the editing of this diagram and additional text to be added to section 1.2 to clarify the terminology used to refer to the key recovery process. The Chairman asked each of the document section authors to prepare their sections in appropriate MS Word format with appropriate numbering to facilitate ease of consistent editing of future versions. It was also suggested that those members who plan to attend the RSA conference in January think about the possibility of holding informal working groups meetings while there. The committee voted that there should be no requirements on end systems interoperability as part of this FIPS. Dr. Benaloh asked the federal liaisons how important interoperability is to this FIPS. He feels that there is a good bit of work to be done on this section of the report and the amount of time required to do a good job and meet the time frame that the Secretary of Commerce has requested for a deliverable. The remainder of the afternoon session was spent discussing the interpretation of what was meant by the terms interoperability. Chairman Kent volunteered to draft some requisite characteristics for interoperability and send distribute copies to the members for discussion at the next meeting. (ACTION - Dr. Kent) No members of the public wished to address the TAC during the designated period. The Secretary will look into the possibility of having the next meeting dates extended in order to accomplish more work. (ACTION - Ed Roback) After expressing his appreciation for the continuing participation of the members and liaisons, Dr. Kent adjourned the meeting at 3:45 p.m. References (on file with the Secretariat) #1 - Agenda & Federal Register Announcement #2 - Mr. Bohannon's prepared presentation #3 - Framework WG materials (WG #1) #4 - Security Model WG, including "Security Requirements" matrix (WG#2) #5 - Interoperability WG (WG #5) Draft #6 - Documentation and Assurance WG materials (WG #8) #7 - Dr. Chokhani's e-mail note of 12/10/97 #8 - Draft "Overview" section