[Gnso-epdp-team] Financial sustainability issues of the SSAD

[Janis Karklins]

Dear Team colleagues,
I have received the following answer from Goran on my e-mail related to
SSAD cost estimate:

*Dear Janis,*



*Thank you for sending these questions regarding cost estimates for a SSAD.
Should the EPDP come to consensus on an SSAD model, we believe it is part
of ICANN org’s public responsibility to ensure that it is cost efficient
by, for example, issuing RFPs and taking other steps to ensure the system
is appropriately resourced to ensure the security and stability of the
world’s Internet users. As you know, ICANN takes seriously its mission,
which includes a longstanding, historic commitment to Registration
Directory Services. As such, the development of a possible Unified Access
Model is extremely important and the EPDP has a very important role to play
in recommending policy, including identifying a financial model. *



*Be assured that we have begun work on these estimates. Given the holiday
schedule and resource constraints, we will work as expeditiously as
possible to provide the team with input on these questions as we do not
wish to be a barrier to the EPDP’s continued progress on its work. To
deliver these estimates, the team working on the cost estimate is
formulating some questions about the EPDP’s assumptions. We would like to
discuss these with the EPDP when you are in LA in January. *



*For your information, we are examining the following costs:*



   - *Developing technical specifications*
   - *System development*
   - *System support/maintenance (including enhancements and bug fixing)*
   - *System operation (e.g., customer support, other human resource
   operators, system operation)*
   - *And periodic auditing*



*Before delving too far into this exercise, we want to confirm that ICANN
org understands the three models for which you are seeking estimates. Could
you please clarify how these three models align with the three models as
described in the EPDP Phase 2’s Draft Initial Report? We understand
generally that one of the models is a fully centralized Unified Access
Model, while another would be a ticketing system that would receive
requests through a central gateway and distribute them to the contract
parties for responses. *



*In addition to these efforts, we’d also like to discuss the possibility of
engaging a consultant with expertise in developing cost estimates for such
systems, if the EPDP should find this input useful.*



*Thank you again. We look forward to your reply.*



*Best,*



*Göran*


I suggest that we discuss this reply in one of the next calls prior the
next f2f meeting in LA.

Best regards

JK

On Sat, Nov 23, 2019 at 8:30 AM Janis Karklins <karklinsj at gmail.com> wrote:

> Goran,
>
> I am writing you in my capacity of the Chair of the EPDP Phase 2 Team to
> seek input on financial sustainability issues if the SSAD.
>
> The EPDP Phase 2 Team is considering the financial sustainability of the
> System for Standardized Access/Disclosure (SSAD) currently being
> deliberated. This will likely involve ICANN managing or operating a
> centralized system to facilitate requests for disclosure of non-public gTLD
> registration data.
>
>  The Team is contemplating how considerable cost implications would be to
> develop, operationalize and run such a System. The EPDP currently considers
> principles on which such a system may be based. Work is still in progress,
> but the Team is discussing principles such as:
>
> 1.            The SSAD should operate on a cost-neutral basis. No party
> should operate or seek to operate this service as a for-profit service, as
> this would invite abuse and manipulation of the SSAD functions.
>
> 2.            Costs to operate the SSAD should be borne by the *direct*
> beneficiaries of the service. The costs of SSAD should not be transferred
> to Data Subjects (Registrants), either directly via fees from ICANN or
> indirectly via fees to Contracted Parties who provide the SSAD with data
> and bear the legal risks of disclosures.
>
> In the absence of responses from both the EPDP letter to the Board, and to
> the Strawberry Team’s query as presented to the European Data Protection
> Board, the EPDP team is not in a position to consider a single model for
> the potential SSAD. Accepting that financial sustainability is a vital
> consideration for the initial report, and as we have not yet determined the
> model for the SSAD, we must therefore present the financial sustainability
> of each of the general model types so far postulated:
>
>    - Fully Centralized (e.g. with ICANN at the core)
>    - Centralized Accreditation and request portal, distributed
>    decision-making, with final response via Centralized portal (e.g. CZDS).
>    - Central Gateway, with distributed review and disclosure
>
> The Team understands that a cost analysis is difficult to conduct while
> the exact details of the SSAD are still being determined. We hope that
> looking at existing systems such as TMCH or CZDS might provide useful
> baselines and identify dependent assumptions that impact cost models. CZDS,
> for example, is itself a centralized system for access to data (in this
> case zone file data), sharing many similarities with the SSAD being
> contemplated.
>
> Equally, financial sustainability analysis of the UAM could provide same
> useful indications for Team’s deliberations.
>
> In order to understand if it is possible for the SSAD to adhere to these
> crucial principles, we are requesting ICANN Org’s help in understanding all
> the likely costs associated with both the development and the ongoing
> operation of the SSAD. Once we understand the anticipated costs, we would
> expect to propose a credentialing and transaction fee structure which would
> pay for the System and allow us to better understand the cost/benefit
> balance of the SSAD as a whole.
>
> Your input on financial sustainability issues will be highly appreciated.
>
> Best regards
>
> JK
>
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