[Gnso-epdp-team] For your review - latest version of EPDP Team Final Report

Sun Feb 3 08:58:01 UTC 2019

Thank you very much for this work. I guess you mean to mark the concerns by
4th Feb and not March.

Here are some of my comments:

*Line 1542, Rec 12: Reasonable access should be called "parameters for ".
Why does line 1542 recommends a modified version?*
Comment from KA
We better use the formulation agreed in Toronto in saying " as for the term
"*Reasonable access"pending to further actions on the matter the Team
proposed to use the term " parameter **responding to lawful disclosure
requests" on an interim basis *
*Line 1558, Rec 12: It is worrisome that so much leeway and emphasis has
been given for the implementation phase to clarify the criteria further.*
Comment from KA
*On the contrary we need to clearly describe the sequence of action as
specified in Recommendation *
*Line 1580, Rec 12: When did we agree that a separate guideline/timeline
might be considered for disclosure of personal data in urgent
circumstances? I did record my objection to that.*
Comment from KA
We need to verfy what was agreed from Transcrip and record.
*Line 1589: EPDP recommends that working on these (disclosure) criteria
start as soon as possible. What does that mean? Are we recommending that
implementation of disclosure criteria start sooner than anything else? *
Comment from KA
No. There is not such understanding of the term " as soon as possible "
meaning to establish order of priority in dealing several items or taking
actions on several items
*Rec 12 in general: all the "access" language has to be replaced with
disclosure requests. *
*Comment from Kavouss *
See my comments above in stating for the time being on  an interin basis
such replacement  is being proposed.*NO PERMANENT REPLACE IS ACCEPTABLE *

*Line 1936, Rec 13: Joint Controller Agreement language is removed,
providing no rationale.  Other than Chris Disspain's point of view and the
US government reasoning, as I say I don't see objections to JCA. If you
have considered the public comments to make this change, please let us
know. If you have considered other factors I would like to know what they
are. *
Comment from Kavouss
This requires further debate to remove or retain to JCA

*Line 2066, Rec 18:  If we are getting rid of data processing agreement
replacing with data protection arrangements (which I don't personally agree
with) then please be consistent throughout the document. Or are we only
getting rid of DPA and JCA only regarding registries and registrars?*
Comment from KA
I agree with the question raised ?
*Line 2129, Rec21: Data processing agreement/ JCA mentioned for Escrows
etc. Are we keeping this language?*
Comment from KA
I also agree with the question raised
Kavouss
*I will send more comments soon. *

On Sun, Feb 3, 2019 at 9:28 AM farzaneh badii <farzaneh.badii at gmail.com>
wrote:

>
>
> Thank you very much for this work. I guess you mean to mark the concerns
> by 4th Feb and not March.
>
> Here are some of my comments:
>
> Line 1542, Rec 12: Reasonable access should be called "parameters for
> responding to lawful disclosure requests". Why does line 1542 recommends a
> modified version?
>
> Line 1558, Rec 12: It is worrisome that so much leeway and emphasis has
> been given for the implementation phase to clarify the criteria further.
>
> Line 1580, Rec 12: When did we agree that a separate guideline/timeline
> might be considered for disclosure of personal data in urgent
> circumstances? I did record my objection to that.
> Line 1589: EPDP recommends that working on these (disclosure) criteria
> start as soon as possible. What does that mean? Are we recommending that
> implementation of disclosure criteria start sooner than anything else?
>
> Rec 12 in general: all the "access" language has to be replaced with
> disclosure requests.
>
> Line 1936, Rec 13: Joint Controller Agreement language is removed,
> providing no rationale.  Other than Chris Disspain's point of view and the
> US government reasoning, as I say I don't see objections to JCA. If you
> have considered the public comments to make this change, please let us
> know. If you have considered other factors I would like to know what they
> are.
>
> Line 2066, Rec 18:  If we are getting rid of data processing agreement
> replacing with data protection arrangements (which I don't personally agree
> with) then please be consistent throughout the document. Or are we only
> getting rid of DPA and JCA only regarding registries and registrars?
>
> Line 2129, Rec21: Data processing agreement/ JCA mentioned for Escrows
> etc. Are we keeping this language?
>
> I will send more comments soon.
>
>
>
>
>
>
>
>
>
>
>
> Farzaneh
>
>
> On Fri, Feb 1, 2019 at 6:10 PM Marika Konings <marika.konings at icann.org>
> wrote:
>
>> Dear EPDP Team,
>>
>>
>>
>> Please find attached for your review the latest version of the Final
>> Report. In relation to section 5, EPDP Team Responses to Charter Questions
>> & Recommendations, please note that those sections highlighted in green are
>> considered finalized for inclusion in the Final Report, sections in blue
>> are still under review / consideration (but these do include the latest
>> language, unless indicated differently).
>>
>>
>>
>> For substantive issues or concerns, please flag these on the mailing list
>> by *Monday 4 March COB* so that these can be included in the meeting
>> agendas for next week. If you want to reference specific parts of the
>> report, please use the line numbering of the attached pdf version. For any
>> minor edits / updates, please use the google doc:
>> https://docs.google.com/document/d/1sVZ9odV0qK1Bk8a4bDwWe5RW_PBzOnYBhHW_GnLL8jw/edit?ts=5c4f07ef.
>> On the wiki (see https://community.icann.org/x/VZwWBg), we have also
>> posted a Word and clean version for those of you that prefer that format.
>>
>>
>>
>> As you review the Final Report, we want to remind you of Kurt’s message
>> that also seem to apply here: “study the balancing that went into this and
>> be ready to accept wording in cases where it does not match your own
>> choice”.
>>
>>
>>
>> As a reminder, revisions to the data elements workbooks to ensure
>> alignment with EPDP recommendations are being undertaken by a small team
>> which is expected to share the results of its work shortly.
>>
>>
>>
>> Best regards,
>>
>>
>>
>> Caitlin, Berry and Marika
>>
>>
>>
>> *Marika Konings*
>>
>> *Vice President, Policy Development Support – GNSO, Internet Corporation
>> for Assigned Names and Numbers (ICANN) *
>>
>> *Email: marika.konings at icann.org <marika.konings at icann.org>  *
>>
>>
>>
>> *Follow the GNSO via Twitter @ICANN_GNSO*
>>
>> *Find out more about the GNSO by taking our interactive courses
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>>
>>
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