[gnso-rds-pdp-wg] Working paper from the Berlin group

[Victoria Sheckler]

I’m concerned about the overly narrow view of the purpose of a domain name registrant database in this paper.  I note that one of ICANN’s commitments in its bylaws include:

“Preserve and enhance the administration of the DNS and the operational stability, reliability, security, global interoperability, resilience, and openness of the DNS and the Internet;”

The concept behind that ICANN commitment doesn’t seem to be captured in the purpose assumed by the analysis in the Berlin Group working paper.

In addition, I note that the ICANN bylaws contemplate that

“Subject to applicable laws, ICANN shall use commercially reasonable efforts to enforce its policies relating to registration directory services and shall work with Supporting Organizations and Advisory Committees to explore structural changes to improve accuracy and access to generic top-level domain registration data, as well as consider safeguards for protecting such data.”

I believe the above requirement contemplates more than mere technical resolution.

From: gnso-rds-pdp-wg [mailto:gnso-rds-pdp-wg-bounces at icann.org] On Behalf Of theo geurts
Sent: Friday, March 9, 2018 3:48 PM
To: Andrew Sullivan <ajs at anvilwalrusden.com>; Stephanie Perrin <stephanie.perrin at mail.utoronto.ca>; gnso-rds-pdp-wg at icann.org
Subject: Re: [gnso-rds-pdp-wg] Working paper from the Berlin group



Hi Andrew,

These recommendations go beyond WHOIS, but yet tie in directly with issues we will face as a WG.

Furthermore, this is not a few DPA's from Europe who made these recommendations; these are the recommendations from DPA's and experts all over the world, which makes it, in my opinion, a global recommendation.

And to kindly to remind everyone again, there are more than 120 countries with data protection laws. So this is not some little tea club gathering, these recommendations took a lot of time to get vetted by this group due to the many members. They started working in November last year on this, so they took their time.

We would be fools to ignore this.

Theo

On 9-3-2018 17:02, Andrew Sullivan wrote:

I think I asked this before about recommended additional materials: could you say something about what's new or useful in this paper that means we ought to read it too?  I fear that we are at that point where everything that is to be said about the RDS has been said, but not everyone has said it. More input should only be considered as important if there's something new, I think.

Best regards,

A

--
Please excuse my clumbsy thums

________________________________

On March 9, 2018 9:21:32 AM Stephanie Perrin <stephanieperrin at mail.utoronto.ca><mailto:stephanieperrin at mail.utoronto.ca> wrote:

The International WOrking Group on Data Protection in Telecommunications, a group of data commissioners and experts on DP and IT have released a new paper on ICANN and RDS.  It should be added to our repository, please.
https://www.datenschutz-berlin.de/pdf/publikationen/working-paper/2017/2017-IWGDPT_Working_Paper_WHOIS_ICANN-en.pdf

Stephanie Perrin


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