[gnso-rds-pdp-wg] international law enforcement association resolution regarding domain registration data
Paul Keating
paul at law.es
Thu Apr 27 18:07:37 UTC 2017
All good questions but I would like to start with the scope of the. Urrent laws as it applies to current Whois data.
Sincerely,
Paul Keating, Esq.
> On Apr 27, 2017, at 7:47 PM, allison nixon <elsakoo at gmail.com> wrote:
>
> I'm sure everyone's schedules are quite busy, and they will manage.
>
> We need a proper legal authority here because it's potentially falsely being presumed that the use of WHOIS data is illegal and noncompliant in the first place. We simply do not know if that is a factual premise. We also need to take into account laws other than the EU privacy laws, and laws outside the EU. A number of exemptions exist within these privacy laws and those people throwing around the legal arguments accusing this of being illegal don't seem to ever mention that fact. We need an unbiased legal expert.
>
> What if a country is trying to enforce a law that is deemed distasteful (violates human rights, etc), and their registrant is located within the country? does the gatekeeper have grounds to deny them the ability to enforce their own laws against their own people, and if so when?
>
> How does WHOIS play into other areas of compliance, such as know-your-customer, complying with sanctions, anti-money laundering, HIPPAA, PCI, etc? Is complying to one law more important than complying to another, if one had to choose?
>
> Will the gatekeeper comply with anti-trust laws?
>
> How does privacy law prohibit information collection on registrants yet collect detailed PII info on queriers and subject them to audit? What happens if the gatekeeper is hacked into for those audit logs? What happens if the gatekeeper receives a national security letter?
>
> All of these are legal questions that need to be answered without bias and with full understanding of the facts.
>
>
>
>
>
>> On Thu, Apr 27, 2017 at 12:42 PM, Stephanie Perrin <stephanie.perrin at mail.utoronto.ca> wrote:
>> And we need to have a lengthy discussion about precisely who that legal expert might be. It appears that many of our members are prepared to reject the views of the Data Protection Authorities themselves, who took the time out of their extraordinarily busy schedules to come and speak with us in Copenhagen.
>>
>> Stephanie Perrin
>>
>>> On 2017-04-27 09:14, Gomes, Chuck via gnso-rds-pdp-wg wrote:
>>> We as a WG have not requested funds for a legal expert, but I don’t know what staff has built into the Draft FY18 budget.
>>>
>>>
>>>
>>> Marika – Did the Policy Team build any funds into the Draft FY18 budget for legal experts?
>>>
>>>
>>>
>>> Note that this is a very time sensitive issue because the comment period on the Draft FY18 Operating Plan and Budget ends tomorrow.
>>>
>>>
>>>
>>> Lisa/Marika/Amr – Please prepare a draft comment on the Budget that the Leadership Team or me as Chair could send on Friday in this regard. If funds have not been proposed for such expenses, I think we should at a minimum raise the issue in the public comment forum even if there is not time to propose specific details.
>>>
>>>
>>>
>>> Chuck
>>>
>>>
>>>
>>> From: gnso-rds-pdp-wg-bounces at icann.org [mailto:gnso-rds-pdp-wg-bounces at icann.org] On Behalf Of Paul Keating
>>> Sent: Thursday, April 27, 2017 7:55 AM
>>> To: Greg Shatan <gregshatanipc at gmail.com>; Volker Greimann <vgreimann at key-systems.net>
>>> Cc: RDS PDP WG <gnso-rds-pdp-wg at icann.org>
>>> Subject: [EXTERNAL] Re: [gnso-rds-pdp-wg] international law enforcement association resolution regarding domain registration data
>>>
>>>
>>>
>>> Has the WG requested funds to retain a legal expert to educate us on the actual laws at issue?
>>>
>>>
>>>
>>> From: <gnso-rds-pdp-wg-bounces at icann.org> on behalf of Greg Shatan <gregshatanipc at gmail.com>
>>> Date: Thursday, April 27, 2017 at 12:38 AM
>>> To: Volker Greimann <vgreimann at key-systems.net>
>>> Cc: RDS PDP WG <gnso-rds-pdp-wg at icann.org>
>>> Subject: Re: [gnso-rds-pdp-wg] international law enforcement association resolution regarding domain registration data
>>>
>>>
>>>
>>> We also need to be very clear about the limits of the legal requirements of applicable law, and the various options available for dealing with the law. There's no need to overcomply. Indeed it would be quite unreasonable to do so.
>>>
>>>
>>>
>>> Just as paying the lowest calculable income tax is perfectly legitimate, so is complying with the law in the least disruptive way possible.
>>>
>>>
>>>
>>> Greg
>>>
>>>
>>>
>>> Greg Shatan
>>> C: 917-816-6428
>>> S: gsshatan
>>> Phone-to-Skype: 646-845-9428
>>> gregshatanipc at gmail.com
>>>
>>>
>>>
>>> On Wed, Apr 26, 2017 at 1:06 PM, Volker Greimann <vgreimann at key-systems.net> wrote:
>>>
>>> I wish it were so simple. "Doing harm" is not necessary to be in violation with applicable law. Just like jaywalking, speeding on an empty road or crossing a red light carries a fine regardless of whether harm was done, privacy law too does not care about an actual harm.
>>>
>>> We need to be very clear about the legal requirements when we define the limits of what can be done with the data we collect, and by whom.
>>>
>>> Volker
>>>
>>>
>>>
>>> Am 26.04.2017 um 18:43 schrieb John Horton:
>>>
>>> Greg, well said. And Tim, well said. And I'll strongly +1 Michael Hammer as well. I agree with the "do no harm" philosophy -- I'm not convinced that some of the proposed changes (e.g., those outlined in the EWG report) wouldn't cause more harm than the existing, admittedly imperfect, system. As I've said before, the importance of tools like Reverse Whois isn't only direct -- it's derivative as well. (If you enjoy the benefits of those of us who fight payment fraud, online abuse and other sorts of malfeasance, you have reverse Whois among other tools to thank.) Privacy laws in one part of the world are a factor we need to be aware of, among other factors.
>>>
>>>
>>>
>>> On Wed, Apr 26, 2017 at 9:07 AM nathalie coupet via gnso-rds-pdp-wg <gnso-rds-pdp-wg at icann.org> wrote:
>>>
>>> +1
>>>
>>>
>>>
>>> Nathalie
>>>
>>>
>>>
>>> On Wednesday, April 26, 2017 12:02 PM, Victoria Sheckler <vsheckler at riaa.com> wrote:
>>>
>>>
>>>
>>> +1
>>>
>>> Sent from my iPhone
>>>
>>>
>>> On Apr 26, 2017, at 8:56 AM, Greg Shatan <gregshatanipc at gmail.com> wrote:
>>>
>>> Thanks for weighing in, Tim. Since this is a multistakeholder process, everyone is assumed to come in with a point of view, so don't be shy. At the same time, if stakeholders cling dogmatically to their points of view the multistakeholder model doesn't work.
>>>
>>>
>>>
>>> As for being out on a limb:
>>>
>>> We haven't decided what data will be "private" and for which registrants (e.g., based on geography or entity status)
>>> We haven't decided there will be "gated" access and what that might mean, both for policy and practicality
>>> The question shouldn't be whether we will be "allowing third parties access to harvest, repackage and republish that data," but how we should allow this in a way that balances various concerns. Eliminating reverse Whois and other such services is not a goal of this Working Group.
>>> Our job should be to provide the greatest possible access to the best possible data, consistent with minimizing risk under reasonable interpretations of applicable law. We need to deal with existing and incoming privacy laws (and with other laws) as well, but not in a worshipful manner; instead it should be in a solution-oriented manner. This is not, after all, the Privacy Working Group. I'll +1 Michael Hammer: Rather than starting from a model of justifying everything and anything from a privacy perspective, I would suggest that it would be much more appropriate, other than technical changes such as moving towards using JSON, to require justification and consensus for any changes from the existing model(s) of WHOIS.
>>>
>>>
>>>
>>> Finally, while our purpose is not to maintain anyone's economic interest, economic interests may well be aligned with policy interests. Assuming that economic interests are at odds with policy interests is just as dangerous as assuming that policy interests are served by maximizing economic interests.
>>>
>>>
>>>
>>> Greg
>>>
>>>
>>>
>>> Greg Shatan
>>> C: 917-816-6428
>>> S: gsshatan
>>> Phone-to-Skype: 646-845-9428
>>> gregshatanipc at gmail.com
>>>
>>>
>>>
>>> On Wed, Apr 26, 2017 at 11:28 AM, Dotzero <dotzero at gmail.com> wrote:
>>>
>>> Adding to what Tim and Allison wrote.
>>>
>>> As a starting point, I've had an account with DomainTools in the past and will likely have one in the future, although I don't currently have one.
>>>
>>> There are other organizations and individuals which consume/aggregate whois data so I don't think that for the purposes of this discussion the focus should be on just DomainTools. I know researchers and academics who use this data to analyze all sorts of things. As has been pointed out, there are all sorts of folks staking out positions because of their economic (and other) interests without necessarily being transparent about those interests.
>>>
>>> It should be remembered that the Internet is an agglomeration of many networks and resources, some public and some private. At the same time, it is simply a bunch of technical standards that people and organizations have agreed to use to interact with each other. In many cases, the ultimate solution to abuse is to drop route. To the extent that good and granular information is not readily available, regular (innocent) users may suffer as owners and administrators of resources act to protect those resources and their legitimate users from abuse and maliciousness. The reality is that most users of the internet utilize a relatively small subset of all the resources out there. For some, a service like Facebook IS the Internet.
>>>
>>> It may also incite a tendency towards returning to a model of walled gardens. At various points I have heard discussions about the balkanization of the internet, with things like separate roots, etc. People should think very carefully about what they are asking for because they may not be happy with it if they actually get it.
>>>
>>> Rather than starting from a model of justifying everything and anything from a privacy perspective, I would suggest that it would be much more appropriate, other than technical changes such as moving towards using JSON, to require justification and consensus for any changes from the existing model(s) of WHOIS.
>>>
>>> Michael Hammer
>>>
>>> On Wed, Apr 26, 2017 at 10:27 AM, allison nixon <elsakoo at gmail.com> wrote:
>>>
>>> Thank you for your email Tim.
>>>
>>> Full disclosure(because I believe in being transparent about this sort of thing), we do business with Domaintools and use their tools to consume whois data.
>>>
>>> "i'll close by saying I think Allison's point about economic value has merit. yes, the point of the WG is not to protect anyone's economic interest. I agree 100% with that statement and will disagree with anyone who thinks the future of DomainTools or other commercial service should have one iota of impact on this discussion."
>>>
>>> I will however disagree vehemently with you on this point. It is obvious that many of the arguments to cut off anonymous querying to WHOIS data are economically motivated. Financial concerns are cited numerous times in approved documents. I also believe the "vetting" process is likely to become a new revenue stream for someone as well. A revenue stream with HIGHLY questionable privacy value-add.
>>>
>>> Every dollar of income for the Domaintools company and others like it come from their clients, who see a multiplier of value from it. That means for every dollar spent on the entire whois aggregator industry means that a much larger amount of money is saved through prevented harms like fraud, abuse, and even fake medications which kill people.
>>>
>>> I think it is extremely important to identify what critical systems rely on whois (either directly or downstream), and determine if we are ready to give up the utility of these systems.
>>>
>>> We also need to identify the value of the ability to anonymously query whois and what that loss of privacy will mean as well. While I obviously do not make many queries anonymously(although our vendor has their own privacy policy), I understand this is important especially to those researching more dangerous actors. Why would $_COUNTRY dissidents want to query domains when their opponents would surely be hacking into the audit logs for this?
>>>
>>>
>>>
>>> On Apr 25, 2017 11:41 PM, "Chen, Tim" <tim at domaintools.com> wrote:
>>>
>>> "And I hope more stakeholders in this multi-stakeholder process will come forward with their own perspectives, as they will differ from mine."
>>>
>>>
>>>
>>> happy to do so. DomainTools is clearly a stakeholder in this debate. and we have a fair amount of experience around the challenges, benefits and risks of whois data aggregation at scale.
>>>
>>>
>>>
>>> from the beginning of this EWG/RDS idea we've stood down bc i didn't believe our opinion would be seen as objective-enough given our line of business. but it is apparent to me having followed this debate for many weeks now, that this is a working group of individuals who all bring their own biases into the debate. whether they care to admit that to themselves or not. so we might as well wade in too. bc I think our experience is very relevant to the discussion.
>>>
>>>
>>>
>>> i'll do my best to be as objective as I can, as a domain registrant myself and as an informed industry participant.
>>>
>>>
>>>
>>> since our experience is working with security minded organizations, that is the context with which I will comment.
>>>
>>>
>>>
>>> since this is an ICANN working group, I start with the ICANN mission statement around the security and stability of the DNS. I find myself wanting to fit this debate to that as the north star. i do not see the RDS as purpose driven to fit the GDPR or any region-specific legal resolution. but I do see those as important inputs to our discussion.
>>>
>>>
>>>
>>> from a security perspective, my experience is that the benefits of the current Whois model, taken with this lens, far outweigh the costs. again, I can only speak from my experience here at DomainTools, and obviously under the current Whois regime. This is not to say it cannot be improved. From a data accuracy perspective alone there is enormous room for improvement as I think we can all agree. every day I see the tangible benefits to security interests, which for the most part are "doing good", from the work that we do. when I compare that to the complaints that we get bc "my PII is visible in your data", it's not even close by my value barometer (which my differ from others'). this is relevant bc any future solution will be imperfect as I have mentioned before. as Allison and others point out we need to measure the harm done by any new system that may seek to solve one problem (privacy?) and inadvertently create many more. since this group is fond of analogies I'll contribute one from the medical oath (not sure if this is just U.S.) "first, do no harm".
>>>
>>>
>>>
>>> i'll close by saying I think Allison's point about economic value has merit. yes, the point of the WG is not to protect anyone's economic interest. I agree 100% with that statement and will disagree with anyone who thinks the future of DomainTools or other commercial service should have one iota of impact on this discussion. but I also think "it's too expensive" or "it's too hard" are weak and dangerous excuses when dealing with an issue like this which has enormous and far reaching consequences for the very mission of ICANN around the security and stability of our internet.
>>>
>>>
>>>
>>> Tim
>>>
>>>
>>>
>>> On Mon, Apr 24, 2017 at 3:50 PM, allison nixon <elsakoo at gmail.com> wrote:
>>>
>>> Thanks for the documentation in your earlier email. While I understand that's how things are supposed to work in theory, it's not implemented very widely, and unless there is enforcement, then it's unlikely to be useful at all.
>>>
>>>
>>>
>>>
>>>
>>>
>>>
>>> "as a given, we put ourselves in a certain position in terms of the actions we can and cannot recommend. We can make similar statements focused on registry operators, registrars, or any other stakeholder in this space. If we all approach this WG's task with the goal of not changing anything, we're all just wasting our time."
>>>
>>> There are things that people would be willing to change about WHOIS. Changes purely relating to the data format would not be as controversial. Changing to that RDAP json format would probably be an agreeable point to most here.
>>>
>>>
>>>
>>> There are two different major points of contention here. The first is the data format, second is the creation of a new monopoly and ceding power to it. By monopoly I mean- who are the gatekeepers of "gated" access? Will it avoid all of the problems that monopolies are historically prone to? Who will pay them? It seems like a massive leap of faith to commit to this without knowing who we are making the commitment to.
>>>
>>>
>>>
>>>
>>>
>>> "I do not believe it is this WG's responsibility to protect anyone's
>>>
>>> commercial services if those things are basically in response to
>>> deficiencies in the existing Whois protocol. "
>>>
>>>
>>>
>>> From my understanding of past ICANN working groups, registrars have fought against issues that would have increased their costs. And the destruction of useful WHOIS results(or becoming beholden to some new monopoly) stand to incur far more costs for far larger industries. So this shouldn't surprise you. If those economic concerns are not valid then I question why the economic concerns of registrars are valid.
>>>
>>>
>>>
>>> If entire industries are built around a feature you would consider a "deficiency", then your opinion may solely be your own. And I hope more stakeholders in this multi-stakeholder process will come forward with their own perspectives, as they will differ from mine.
>>>
>>>
>>>
>>>
>>>
>>>
>>>
>>>
>>>
>>>
>>>
>>> "Not trying to hamstring the WG. Just asking if this is not something that has already been solved.."
>>>
>>> Hi Paul,
>>>
>>>
>>>
>>> It's an interesting thought. This document was recommended to me as one that was approved in the past by the working group that outlined what the resulting system might look like. I'm still learning and reading about these working groups and what they do, and this document is massive.
>>>
>>>
>>>
>>> https://www.icann.org/en/syste m/files/files/final-report-06j un14-en.pdf
>>>
>>>
>>>
>>> In the document, it says: "Central to the remit of the EWG is the question of how to design a system that increases the accuracy of the data collected while also offering protections for those Registrants seeking to guard and maintain their privacy."
>>>
>>>
>>>
>>> One of the things I notice is that any talk about actually increasing accuracy of whois info- via enforcement- is vigorously opposed in this group, and it's merely assumed that people will supply better quality data under the new system.
>>>
>>>
>>>
>>> Throughout the document it talks about use-cases and features (whois history, reverse query, etc), which are indeed identical to the features of the whois aggregators of current day. Such a system would replace them. Will the service quality be as good?
>>>
>>>
>>>
>>> On page 63 it gets into thoughts on who would be "accredited" to access the gated whois data. Every proposed scenario seems to recognize the resulting system will need to handle a large query volume from a large number of people, and one proposes accrediting bodies which may accredit organizations which may accredit individuals. It even proposes an abuse handling system which is also reminiscent in structure to how abuse is handled currently in our domain name system. Many of these proposed schemes appear to mimic the ways that the hosting industry and registrar industry operate, so we can expect that the patterns of abuse will be equally frequent, especially if higher quality data is supplied.
>>>
>>>
>>>
>>> The proposed scenarios all paint a picture of "gated" access with very wide gates, while simultaneously representing to domain purchasers that their data is safe and privacy protected. And this is supposed to *reduce* the total number of privacy violations? This doesn't even appeal to me as a consumer of this data.
>>>
>>>
>>>
>>> Whoever sets up this system also stands to inherit a lot of money from the soon-to-be-defunct whois aggregation industry. They would certainly win our contract, because we would have no choice. All domain reputation services, anti-spam, security research, etc, efforts will all need to pay up.
>>>
>>>
>>>
>>>
>>>
>>>
>>>
>>> After being supplied with the above document, I also saw a copy of a rebuttal written by a company that monitors abusive domains. I strongly agree with the sentiments in this document and I do not see evidence that those concerns have received fair consideration. While I do not see this new gatekeeper as an existential threat, I do see it as a likely degradation in the utility i do see from whois. To be clear, we do not do any business with this company.
>>>
>>>
>>>
>>> http://mm.icann.org/pipermail/ input-to-ewg/attachments/20130 823/410038bb/LegitScriptCommen tsonICANNEWGWhoisReplacementSt ructure-0001.pdf
>>>
>>>
>>>
>>>
>>>
>>>
>>>
>>> I also found John Bambenek's point in a later thread to be interesting- concentrating WHOIS knowledge solely to one organization allows the country it resides in to use it to support its intelligence apparatus, for example monitoring when its espionage domains are queried for, and targeting researchers that query them (since anonymous querying will be revoked). Nation states already use domains in operations so this monopoly is a perfect strategic data reserve. The fact that this system is pushed by privacy advocates is indeed ironic.
>>>
>>>
>>>
>>>
>>>
>>>
>>>
>>> None of those concerns appear to have been addressed by this group in any serious capacity. Before the addition of new members, I don't think many people had the backgrounds or skillsets to even understand why they are a concern. But I think this is a discussion worth having at this point in time for this group.
>>>
>>>
>>>
>>> On Mon, Apr 24, 2017 at 1:50 PM, Andrew Sullivan <ajs at anvilwalrusden.com> wrote:
>>>
>>> Hi,
>>>
>>> On Mon, Apr 24, 2017 at 07:25:47PM +0200, Paul Keating wrote:
>>> > Andrew,
>>> >
>>> > Thank you. That was helpful.
>>> >
>>> > ""Given this registrant, what other
>>> > domains are registered?" is a solved problem, and has been since the
>>> > early 2000s.²
>>> >
>>> > This is also traceable via alternative means such as consistencies in
>>> > various WHOIS fields such as email, address, name, etc.
>>>
>>> Well, sort of. The email, address, and name fields are _user_
>>> supplied. So they come from the other party to the transaction. The
>>> ROID is assigned by the registry itself. So once you have a match,
>>> you know that you are looking at the same object, only the same
>>> object, and all the same object(s).
>>>
>>> Email addresses in particular are guaranteed unique in the world at
>>> any given time (though not guaranteed as unique identifiers over
>>> time), so they may be useful for these purposes. Take it from someone
>>> named "Andrew Sullivan", however, that names are pretty useless as
>>> context-free identifiers :)
>>>
>>> > In reality finding out answers to questions such as
>>> > yours (above) requires investigation using a plethora of data.
>>>
>>> To be clear, finding out the answer to what I (meant to) pose(d)
>>> requires no plethora of data: it requires a single query and access to
>>> the right repository (the registry). In some theoretical system, the
>>> correct underlying database query would be something like this:
>>>
>>> SELECT domain_roid, domain_name FROM domains WHERE registrant_roid = ?;
>>>
>>> and you put the correct ROID in where the question mark is, and off
>>> you go. That will give you the list of all the domain names, and
>>> their relevant ROIDs, registered by a given registrant contact. At
>>> least one registry with which I am familiar once had a WHOIS feature
>>> that allowed something close to the above, only it would stop after
>>> some number of domains so as not to return too much data. I think the
>>> default was therefore LIMIT 50, but I also think the feature was
>>> eventually eliminated about the time that the ICANN community rejected
>>> IRIS as an answer to "the whois problem".
>>>
>>> What the above will of course not do is help you in the event Bob The
>>> Scammer has created dozens of different contacts for himself by (say)
>>> registering names through many different registrars. I do not believe
>>> that any registry is going to support such a use at least without
>>> access controls, because it can be expensive to answer such things.
>>> So, what you understood me to be asking, I think, is the question I
>>> did _not_ ask: given this human being or organization, what other
>>> domains are registered?" That does require a lot of different data,
>>> and it requires cross-organizational searches, and it requires sussing
>>> out when someone has lied also. Such research is, I agree, completely
>>> outside the scope of what any technical system will ever be able to
>>> offer reliably.
>>>
>>> > An entire
>>> > industry exists for this purpose and I don¹t think we should be
>>> > considering replacing what has already been existing in the cyber security
>>> > marketplace.
>>>
>>> I do not believe it is this WG's responsibility to protect anyone's
>>> commercial services if those things are basically in response to
>>> deficiencies in the existing Whois protocol. In this case, however,
>>> that's not the problem. Linking data in multiple databases to a given
>>> real-world human being is hard even in systems without competition and
>>> multiple points of access. It's always going to require researchers
>>> for the domain name system.
>>>
>>> Best regards.
>>>
>>>
>>> A
>>>
>>> --
>>> Andrew Sullivan
>>> ajs at anvilwalrusden.com
>>> ______________________________ _________________
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>>>
>>>
>>>
>>>
>>>
>>> --
>>>
>>> ______________________________ ___
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>>>
>>>
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>>>
>>>
>>> --
>>> Bei weiteren Fragen stehen wir Ihnen gerne zur Verfügung.
>>>
>>> Mit freundlichen Grüßen,
>>>
>>> Volker A. Greimann
>>> - Rechtsabteilung -
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> Note to self: Pillage BEFORE burning.
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