Minutes of the April 22-23, 1998 Meeting of the Technical Advisory Committee to Develop a Federal Information Processing Standard for the Federal Key Management Infrastructure Wednesday, April 22, 1998 A quorum being present, the ninth meeting of the Committee was called to order at 9:15 a.m. by the Chairman, Dr. Stephen Kent, at the Tremont House Hotel, Boston, Massachusetts. As with all other TAC meetings, all sessions were open to the public. In addition to the Chairman, members present were: Josh Benaloh, Tom Cahill, Dave Carman, Santosh Chokhani, Paul Clark, Jack Edwards, Mark Etzel, Daniel Harkins, Richard Hite, Mike Markowitz, Mike Matyas, Joe Pato, and Don Rothwell. Government liaisons in attendance were Elaine Barker, Clem Boyleston, Tony DiClemente, Diane Dunshee, Julie Lever, Jan Manning, and John Sabo. Also attending was Mark Bohannon, Chief Counsel for the Technology Administration, of the Department of Commerce. Ed Roback reviewed the agenda for the two-day meeting and the handout materials. (See references.) The Chairman then proceeded to discuss his goal for the meeting as reaching agreement on the spirit of what is in each of the sections and as much agreement as possible on the specific wording. Diane Dunshee reported on results of the government liaisons' work to address the questions raised by the TAC at the February meeting (which Dr. Benaloh had drafted). (See references.) Highlights included a discussion of the liaisons' view that a system administrator function is needed, and whether a switch should be present to allow user and administrator choices for key recovery (KR). A user option for key recovery selection or de-selection is permissible if the system administrator has not made the use or non-use of KR mandatory. Ms. Dunshee continued with an explanation of the need for higher security for KRAs and why the liaisons felt that compliance with FIPS 140-1, level 2 was therefore warranted. During these discussions, the Chairman expressed concern that many of the government responses did not completely describe the basic underlying requirement, but were, rather, at the level of derived requirements. It would help the TAC's work if the basic requirements were completely described and understood. Next followed a lengthy discussion of the issue of receiver validation. The need for specific examples of how this might be achieved was identified. Dr. Markowitz raised the need to clarify whether the validation was done for only the recipient in question or all recipients. After discussion, there appeared to be agreement that the validation under discussion was for the specific receiver. Dr. Kent then reviewed plans for the rest of the TAC meeting. First the TAC would conduct a top-level review of the document, then a more detailed review of each section, and finally focus on sections that the TAC determines require more attention. With no members of the public expressing interest in addressing the Board, the lunch break ensued. Following the lunch break, the Chairman began the section by section review. Overview. Regarding section 1, he noted that there should be a discussion of what is in the rest of the FIPS and what is outside the scope of the FIPS (e.g., operational security issues for a KRA). He agreed to re-draft the overview section. (ACTION - Dr. Kent) Mr. Roback pointed out that such issues could also be addressed in the accompanying letter to the Secretary. There followed a discussion of an observation made by Mr. Harkins that much of the document seems to imply that the endpoint of the encryption is the same as the endpoint of the communications. He noted that he does not see sufficient justification for KR for other than end-to-end communications. Mr. Harkins will draft text to address this issue for the TAC's consideration. (ACTION - Mr. Harkins) It was noted that the terms "recovery data medium" and "encrypted data medium" need to be edited out of the document. Also, the discussion of interoperability in the overview will be eliminated, as there are currently three separate discussions of interoperability, not counting the section prepared by the Chairman and inadvertently omitted in the consolidated draft. Security Model. The Chairman began by inquiring exactly what the section was intended to accomplish. Dr. Matyas replied that it will let readers map an existing KR system to the model and let the model give insight into KR that might go beyond any particular technique. Dr. Kent noted that the model should concretely define what each of the functions entails. For example, review and remove functional requirements from Section 5 that should belong in Section 2. Interoperability should also show up in Section 2. It would be a natural place to describe what the interoperability issues are in this environment rather than have sections 4 and 7 describe them separately. It was also suggested that the requirements be referenced by a numbering sequence and collectively listed at the end of the document so as to insure that none of the requirements are overlooked. It was also suggested, without disagreement, that the requirements in the FIPS should be sequentially numbered. (ACTION - NIST) The TAC then briefly discussed the remaining section topics in the outline, and a roadmap to reorganizing the document was prepared and distributed by the Chairman. (See references.) KRS Components/Products - This section could be turned into an appendix, with the exception of the Sections 3.1.1 through 3.1.3 which will be put into another section somewhere. Term of "end-user system" used in figures will be changed to "cryptographic end system." Interoperability - Sections 4.1 and 4.2 will be removed while 4.3 and 4.4 will be integrated into Section 2.7 (Interoperability) along with previously drafted merial from the Chairman. Functional Requirements -- Some sections will be incorporated into section 2 and some will be incorporated into the security requirements (old section 6, new section 3). Security Requirements -- This section will be revised and become the new section 3. Interoperability Requirements -- Some of these points are also covered in other sections of the report and will be moved or eliminated accordingly. 7.1.7 should be eliminated. 7.2 will be attached to another section. Some requirements in 7.1 will be moved to Section 2, others to the security requirements section. Assurance Requirements -- Minor revisions will be made; this section will become the new section 4. Appendix A -- This section will contain examples, as needed, to assist developers and vendors in understanding the KR model. Appendix B -- This appendix will describe a recommended key recovery block format as guidance that standards bodies [or government designers] may refer to when they employ encapsulation. Appendix C -- This will contain X509v3 certificate extensions and a profile for other extension employed in such certificates. This current draft is a starting point, but there is a need for more work. Appendix D -- This will contain illustrative examples of how key recovery enabled systems can be designed to maximize interoperability, both with systems that do not implement key recovery, and with systems that implement different key recovery schemes. Dr. Kent then discussed how the TAC could address issues the following day. Four groups would be needed: 1) Section #2, (Dr. Matyas and Ms. Barker to coordinate), 2) Sections 3.1.1 - 3.1.3 (Mr. Carman to coordinate), 3) Section #6 (Ms. Dunshee to coordinate) and 4) Interoperability and Overview (Dr. Kent). The meeting was then recessed for the day at 5:00 p.m. Thursday, April 23, 1998 The meeting was reconvened at 9:15 a.m. on Thursday, April 23, 1998. A public attendee, Daniel J. Greenwood, Deputy General Council for Commonwealth of Massachusetts, commented that they are very interested at the State level in the encryption effort and its potential effects on State and local business. He said that they had participated in the recent CRISIS report done by the NRC. He stated that while the Commonwealth has no formal position on key recovery issues, they believe that this FIPS will be a very important issue to States. He offered to review the draft and provide feedback to the Committee prior to its next meeting, if such an option were available and appropriate, or during public comment periods. Next, the committee separated into small groups and revisited separate sections of the draft document, as planned the previous day. They reconvened as a committee at 11:30 a.m. to begin discussion of the editorial changes made by the individual groups. Dr. Kent's rewrite of the overview now consists of three pieces, starting with several paragraphs of a general introductory nature followed by 1.1 -- scope of the standard; 1.2 a roadmap to the standard; 1.3 security levels of the requirement, 1.4 security assurance levels. New draft format will consist of Section 1: Introduction; Section 2: Model; Section 3: Security Requirement and Section 4: Security Assurance Requirements. These sections will be followed by the appendices. Ms. Barker reported on the changed proposed to Section 2. Dave Carman reported on the changes proposed to Section 3 (the new section 2), which will address mappings, section 2.9 will address KR techniques drawing upon the language currently in 3.1.1 to 3.1.3. Paul Clark discussed 7.l.l and 7.1.4 and other sections to be handed off to Section 2. Mr. DiClemente stated that the KRR-KRA requirement should have a standardized format for the law enforcement agencies to follow. There was discussion whether this meant a single format for all or a single standardized format per system. (This was tied to the liaisons' response to Question 8.) He also raised the issue regarding the affordability of dealing with such systems, particularly at the state and local levels. Another major concern is electronic authentication of the request as well as the likely need to get multiple session keys as a result of a single authorization request. Finally, he noted that in section 7.4.2, authority should be added (e.g., the Fourth Amendment). Diane Dunshee reported on the output of the group review of the security requirements section. Common criteria references in this section will be deleted. Section 6.1.1.8 will also be deleted. Following lunch, the TAC turned its attention to three issues: 1) system versus function level compliance, 2) partial compliance, and 3) security assurance. Dr. Benaloh had earlier raised the issue of whether the FIPS would provide a means to validate a system as conforming versus conforming only at a functional level. It was agreed that the TAC could not properly address this issue in the FIPS and thus would consider raising the issue in the TAC's transmittal letter to the Secretary. On the issue of partial compliance, which was raised during the discussion of the liaisons' answers to the TAC's questions, there was no immediate agreement on how to proceed, but three options were identified: 1) only identified functions would be submitted for evaluation, all else ignored, 2) there would have to be a capability to turn off the non-compliant modes of KR functions if compliant modes of KR functions are activated, and 3) a product could not be considered as conformant if it has a KR function for which it does not have a compliant mode. Dr. Kent asked that Dr. Etzel put together text describing each alternative for the TAC to discuss in June. (ACTION - Dr. Etzel) Following this was a discussion of the three assurance levels in Section 8 and how they should be reconciled with the two functional security levels. It was decided that the standard would not provide for multiple assurance levels for each functional level. Dr. Chokhani would, in general, revise the section to map the highest assurance level to functional level 2, the mid-level assurance to the functions involved in a KRR or KRA and the lowest level assurance to the rest of the functions. (ACTION - Dr. Chokhani) Mr. Roback reviewed a proposed TAC timeline that he developed. (See references.) Section coordinators are to submit their revised section to NIST by May 14, 1998. (ACTION - Dr. Kent, Ms. Dunshee, Ms. Barker/Dr. Matyas, Dr. Chokhani, Mr. Carman, and Dr. Clark) The Chairman requested that when TAC members review the revised draft, should they identify particular issues which would result in a non-concurrence, they should bring specific suggested changes that, if adopted, would result in their support of the draft. (ACTION - Members) In member discussions with the Chairman, it was discussed and decided that at the June meeting the committee would review the document section by section for a vote as well as to take a vote on the document as a whole. (Votes will be taken if there is not concurrence.) Members were asked to submit topics and draft text for the transmittal letter to the Chairman and Mr. Roback by June 1, 1998. (ACTION - Members) The meeting was adjourned at 3 p.m. References (on file with the Secretariat) 1. Draft assembled standard 2. Interoperability Draft from WG#5 3. Government Liaison Answers to February TAC Questions 4. Proposed Timeline to Completion 5. Dr. Kent's revised Interoperability section (as distributed) 6. Roadmap outline for WG work on 4/23 7. Agenda 8. Federal Register Meeting announcement