[gnso-rds-pdp-wg] more possible requirements

[Victoria Sheckler]

Please see below re more possible requirements from the GAC initial comments to the initial PPSAI Report (https://gacweb.icann.org/download/attachments/27132037/PSWG%2BGAC%20comments%20proxy%20privacy%20accreditation%20issues%5B1%5D.pdf?version=1&modificationDate=1442394018112&api=v2)


-          Commercial registrants should receive less privacy protection than non-commercial registrants



-          law enforcement should be defined as follows: “Law Enforcement Authority” is defined as “law enforcement, consumer protection, quasi-governmental or other similar authorities designated from time to time by the national or territorial government of the jurisdiction in which the privacy or proxy service provider is established or maintains a physical office.” To the extent this definition could be viewed as suggesting that P/P service providers need only respond to law enforcement authorities within their own jurisdiction, the PSWG urges the P/P Working Group to consider revising this definition. Malicious conduct involving domains often takes place across borders and the definition of law enforcement should recognize the multi-jurisdictional aspects of investigative and enforcement activities in order to promote protecting the public no matter where they are located. If such revisions are made, the Working Group should consider a requirement that a P/P service consult with its local law enforcement authorities in the event it receives a request from a foreign authority (to ensure that the local authorities believe that the request is a proper request from a recognized foreign authority).”



-          There is a need for confidentiality in ongoing LEA investigations.
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