CA:RootTransferPolicy

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Root Transfer Policy

The purpose of this page is to document Mozilla’s expectations when the ownership of an included root certificate changes, the organization operating the PKI changes, and/or the private keys of the root certificate are moved to a new location. Throughout such a change, the operation of the root certificate’s private keys and certificate issuance must continue to meet the requirements of Mozilla’s CA Certificate Policy.

In general terms, an organization operating a root certificate included in Mozilla's program should be re-audited and notify Mozilla whenever there is a material change. The rest of this page discusses some instances that would be considered material changes.

Change in Legal Ownership

An example of a change in legal ownership is when one company buys another. This does not necessarily imply that the root certificate's private key will be physically moved to another location. It also does not necessarily imply that there will be a change in operation of the root certificate's private key and certificate hierarchy.

Another example of a change in legal ownership is when an organization buys a root certificate's private key. Such a transition may involve physically relocating the private key, and may involve a change in the key personnel who operate the root certificate's private key and the certificate hierarchy.

An organization operating a root certificate included in Mozilla's program should notify Mozilla whenever there is a change in legal ownership, and should inform Mozilla about resulting changes to the CP and/or CPS.

An organization operating a root certificate included in Mozilla's program should notify Mozilla whenever there is going to be a change of ownership of an included root certificate's private key. The organization who is transferring ownership of the root certificate’s private key must ensure that the transfer recipient is able to fully comply with Mozilla’s CA Certificate Policy. The original organization will continue to be responsible for the root certificate's private key until the transfer recipient has provided Mozilla with their Primary Point of Contact, CP/CPS documentation, and audit statement confirming successful transfer of the root certificate.

Whenever the private key of an included root certificate is going to be physically moved to a new location, the steps outlined in the Physical Relocation section below should be followed. Whenever the organization (i.e. key personnel) operating the private key of an included root certificate is going to change, the steps outlined in the Personnel Changes section below should be followed.

Physical Relocation

Physical relocation of a root certificate's private key may occur when an organization:

• Moves their private keys to another location owned by the same organization.
• Transfers the private keys to another organization that already operates other root certificates included in Mozilla’s program.
• Transfers the private keys to another organization that does not currently operate root certificates included in Mozilla’s program.

Whenever a root certificate's private key is going to be physically relocated, the organizations involved should take the following steps, and immediately notify Mozilla if a problem occurs.

1. Make sure the annual audit statements are current, and notify Mozilla of the pending change.
2. Create a transfer plan (and legal agreement if more than one organization is involved) and have it reviewed by the auditors.
   • For example, the transfer ceremony should have a documented ceremony witnessed by auditors and recorded (for posterity), with a physical exchange of the HSM and a physical exchange of the multi-party authorization keys.
3. Stop new certificate issuance at the current site before the transfer begins.
4. Have an audit performed at the current site to confirm when the root certificate is ready for transfer, and to make sure the key material is properly secured.
5. At the new site perform an audit to confirm that the transfer was successful, that the private key remained secure throughout the transfer, and that the root certificate is ready to resume issuance (i.e. a PITRA; just as we expect any new root to be audited).
6. Send updated CP/CPS and the PITRA statement to Mozilla.
7. The regular annual audit statements are still expected to happen within a timely manner, or the root cert may be removed.

When the physical relocation involves moving the certificate's private key to another organization, the original organization who is transferring the root certificate’s private key must ensure that the transfer recipient is able to fully comply with Mozilla’s CA Certificate Policy. The original organization will continue to be responsible for the root certificate until the transfer recipient has provided Mozilla with their Primary Point of Contact, CP/CPS documentation, and audit statement confirming successful transfer of the root certificate.

The new organization that received the root certificate's private key must follow Mozilla’s CA Certificate Policy, and send Mozilla links to the public-facing CP/CPS documentation and annual audit statements.

The agreement between the original organization and new organization must take the Websites (SSL/TLS), Email (S/MIME), and Code Signing trust bit settings into account, and the original CA must inform Mozilla if one or more of the trust bits should be turned off. Of course, to turn on a trust bit the new organization will have to go through Mozilla's root change process.

Personnel Changes

Personnel changes may include one or more of the following.

• Operation of the PKI is transferred to a different organization that is already operating root certificates included in Mozilla’s program.
• Operation of the PKI is transferred to a different organization that does not currently operate a root certificate included in Mozilla’s program.
• The organization operating the PKI remains the same, but the organization personnel report to a new management structure.

If transferring the operation of the PKI to a different organization involves physically moving the root certificate's private key, then the steps outlined in the Physical Relocation section above must be followed.

In all cases, the CA who is transferring the operation of the PKI must ensure that the transfer recipient is able to fully comply with Mozilla’s CA Certificate Policy. The original CA will continue to be responsible for the root certificate until the new organization has provided Mozilla with their Primary Point of Contact, CP/CPS documentation, and audit statement confirming successful transfer of the root.

The new organization operating the PKI must follow Mozilla’s CA Certificate Policy, and send Mozilla links to the public-facing CP/CPS documentation and annual audit statements.