We've seen a number of comments and questions on Twitter regarding a recent Trustwave CA Policy Update to our legal repository (https://ssl.trustwave.com/CA). This update discusses a subordinate root revocation. This is a proactive revocation, of the only certificate we issued for these purposes, that is the result of careful consideration in light of recent policy changes and the changing PKI landscape.
This single certificate was issued for an internal corporate network customer and not to a 'government', 'ISP' or to 'law enforcement'. It was to be used within a private network within a data loss prevention (DLP) system. The subordinate certificate was subject to a Certification Practice Statement (CPS), Subscriber Agreement and Relying Party Agreement crafted by Trustwave after an audit of the customer physical security, network security, and security policies.
The system was created using dedicated hardware device designed for SSL proxy and acceleration, with a FIPS-140-2 Level 3 compliant Hardware Security Module (HSM) (http://en.wikipedia.org/wiki/Hardware_security_module) for subordinate root storage and for the purpose of private key generation of the re-signed SSL certificates. This means that once the trusted subordinate root was placed into the device it could not be extracted.
Additionally, when the system would accept an outbound SSL connection from within the customer network, and negotiate the session with the server outside the customers network, the private key for the resulting re-signed SSL certificate (that is presented to the internal network) would be generated in the HSM and only live for the duration of the SSL request. No party had access to the re-signed SSL certificate private keys at any time, nor could they gain access to them. This is what prevented the customer from being able to perform ad hoc issuance of certificate for any domain and use them outside of this hardware and infrastructure.
Trustwave has decided to be open about this decision as well as stating that we will no longer enable systems of this type and are effectively ending this short journey into this type of offering.
We take information security very seriously as a trusted CA and we felt that a few clarifications were in order to help everyone understand our actions.