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<p>Hi everyone, <br>
</p>
<p>I agree with Collin and Raphaël and just to state a few things I
found lacking as well:</p>
<p>As Collin said, the format is not easily understandable and could
have been cleared, not a lot of information is given on what
"relevant" documents, how many interviews with people or on site
visits were done. </p>
<p>Less than half the personnel took the online survey which to me
seems less than ideal to gather a comprehensive idea of the status
quo. Whether these people were from 2-3 main teams or the
distribution of how many ranged across each team or function is
also unknown which could potentially impact the results of the
survey. <br>
</p>
<p>I would have liked to see more detail of the essentials of the
human rights situation of each country or what they meany by
looking into it instead of a passing reference to the collective
situation. It is not helpful since we can't understand what ICANN
has to mitigate with these situations. </p>
<p>Under the harassment policy, they don't specifically point out
the lack of a anti-sexual harassment policy (I know one is
currently being formulated but it should have been mentioned
anyway I think?)</p>
<p>The report reportedly used the phrase “Well-managed and
standardized procurement practices, guidelines and training are in
place" without elaborating on what these policies and practices
are within the specific context. Its hard to gauge the current
level then at which ICANN is to then understand the work it needs
to put in to improve. <br>
</p>
<p>Just some of thoughts! Please anyone else feel free to add
theirs. <br>
</p>
<p>Best, <br>
</p>
<p>Akriti<br>
</p>
<p><br>
</p>
<div class="moz-cite-prefix">On 18/05/2019 06:38, Raphaël
Beauregard-Lacroix wrote:<br>
</div>
<blockquote type="cite"
cite="mid:CAPZSw-rAi8bkiCQR-BYK_kWwYOjioaFBbxda1CmTKgYLp=dVdQ@mail.gmail.com">
<meta http-equiv="content-type" content="text/html; charset=UTF-8">
<div dir="ltr">Hi all
<div><br>
</div>
<div>In addition to Collin's point on methodology:</div>
<div><br>
</div>
<div>it's never really clear what is the norm in question
against which ICANN's internal policies and practices are
evaluated. <br>
</div>
<div>
<div><br>
</div>
<div>We seem to have a mix of US federal statutes,
international law strictly speaking, "secondary"/softer
international law like ILO recommendations, and then other
stuff of unknown origin.</div>
<div><br>
</div>
<div>Another issue: international human rights law generally
is not the most precise kind of thing. One may have a right
to a safe working environment in some treaty somewhere, but
there is actual lawyering work required to assert that such
a vague statement actually prescribes a concrete norm
applicable to a concrete situation. I have found little or
no such argumentation. It's mostly conclusory, jumping from
vague/ill-defined "human rights" (no textual references of
any sort; at best a mention of ILO.) to concrete rights or
duties.</div>
<div><br>
</div>
<div>One example: ICANN has "well-managed and standardized
procurement practices, guidelines and trainings." That says
very little about what IRH law has to say about procurement,
and the extent by which ICANN abides by those rules.<br>
</div>
</div>
<div><br>
</div>
<div>Another one: s.2.4: "Sick leave, as well as maternity and
paternity leave, are provided according to national law".
Sure. I hope it is! What is national law here? US federal or
California law? Or other law for regional offices? Is there
IHR law on maternity and paternity leave? What does it say?
How does what it says translate into concrete norms? In
general, and in the US? If so, are such norms applicable to a
US entity? <br>
</div>
<div><br>
</div>
<div>And indeed that is not even touching the fact that what is
being discussed here is ICANN's compliance with the whole
universe of human rights, not only those which are actually
applicable to ICANN, a private entity in the US. I get the
idea of doing what they do, I'd just prefer to have things
stated clearly and separated, between compliance which "would
be a good thing" because IHR law talks about it and compliance
which is mandated by actual law (and there is little "actual
law" in the US when it comes to international human rights) </div>
<div><br>
</div>
<div>As for the GDPR, the report seems to imply that ICANN is
bent on applying the GDPR throughout. Is that the case?
Meaning, is ICANN seeking to "apply" the GDPR as if it were a
EU-based entity? Fully and thoroughly? Even in all its
transactions and relations that have absolutely nothing to do
with the EU? (think US-based employees). Maybe I just missed
something, but I felt that the whole GDPR discussion was
limited to WHOIS. </div>
<div><br>
</div>
<div>A nice weekend to all, </div>
<br class="gmail-Apple-interchange-newline">
</div>
<br>
<div class="gmail_quote">
<div dir="ltr" class="gmail_attr">On Thu, May 16, 2019 at 2:18
PM Collin Kurre <<a href="mailto:collin@article19.org"
target="_blank" moz-do-not-send="true">collin@article19.org</a>>
wrote:<br>
</div>
<blockquote class="gmail_quote" style="margin:0px 0px 0px
0.8ex;border-left:1px solid rgb(204,204,204);padding-left:1ex">
<div bgcolor="#FFFFFF">
<p><font face="Helvetica, Arial, sans-serif">Dear
colleagues,</font></p>
<p><font face="Helvetica, Arial, sans-serif">ICANN Org has
published the Human Rights Impact Assessment carried out
on its operations. Find the announcement and link to the
report here: </font><br>
<font face="Helvetica, Arial, sans-serif"><font
face="Helvetica, Arial, sans-serif"><span
style="font-size:10pt"><a
href="https://www.icann.org/news/announcement-2-2019-05-15-en"
target="_blank" moz-do-not-send="true">https://www.icann.org/news/announcement-2-2019-05-15-en</a>
<br>
</span></font></font></p>
<p><font face="Helvetica, Arial, sans-serif">I personally
find the formatting of the report to be rather
confusing. At first read, I would have liked to see
additional focus on the methodology and substance of the
assessment itself. An explanation about how impacts were
measured and prioritized would have been good, along
with additional details about the "Impact Assessment
Frameworks" developed for each of the four assessment
areas (Human Resources, Event Planning, Procurement, and
Security Operations). <br>
</font></p>
<p><font face="Helvetica, Arial, sans-serif">Please share
any additional thoughts or questions you may have and I
will relay them to ICANN Staff and Löning, the
assessment practitioner. <br>
</font></p>
<p><font face="Helvetica, Arial, sans-serif">On a related
note, for those of you who missed the CCWP-HR call
yesterday, new guidance has been produced about how to
complete our PDP Human Rights Impact Assessment tool.
[0] It can be found attached to this email as a PDF, or
in the second tab of the Sub Pros trial HRIA:
<a
class="gmail-m_6719084960942291174gmail-m_-766848052154585430moz-txt-link-freetext"
href="https://docs.google.com/spreadsheets/d/1EKpMCef8kiZ2tJE2AU78q9_oeJehGbR7bWpQ5wt7D5I/edit?usp=sharing"
target="_blank" moz-do-not-send="true">https://docs.google.com/spreadsheets/d/1EKpMCef8kiZ2tJE2AU78q9_oeJehGbR7bWpQ5wt7D5I/edit?usp=sharing</a>
<br>
</font></p>
<p><font face="Helvetica, Arial, sans-serif">As always, feel
free to leave comments or make any updates or
modifications as you see fit. Akriti and I are working
on the final report of this first trial run, and will be
in touch shortly about the next assessments. Let us know
if you'd like to get involved in this work —
particularly if you're already engaging in PDPs!<br>
</font></p>
<p><font face="Helvetica, Arial, sans-serif">Kind regards,<br>
Collin <br>
</font></p>
<p><font face="Helvetica, Arial, sans-serif"><span
style="font-size:10pt">[0] Find a retrospective of
past HRIA iterations here:
<a
class="gmail-m_6719084960942291174gmail-m_-766848052154585430moz-txt-link-freetext"
href="https://community.icann.org/display/gnsononcomstake/Meeting+Notes?preview=/53772757/104238303/CCWP-HR%20Feb19%20meeting.pdf"
target="_blank" moz-do-not-send="true">https://community.icann.org/display/gnsononcomstake/Meeting+Notes?preview=/53772757/104238303/CCWP-HR%20Feb19%20meeting.pdf</a>
<br>
</span></font></p>
<pre class="gmail-m_6719084960942291174gmail-m_-766848052154585430moz-signature" cols="72">--
Collin Kurre
Digital Program Officer
ARTICLE 19</pre>
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