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

[Greg Shatan]

So, not only does it provide nothing new, it makes some fundamental
assumptions about ICANN's mission that are narrow, self-serving and
frankly, incorrect.

And not only does it provide nothing new, it doesn't even appear to be
new.  It was approved on November 27/28, almost 3 1/2 months ago.  Yet it
is dumped on our doorstep oh-so-coincidentally on the very eve of ICANN 61,
for maximum effect and minimum ability to react and respond.

I've tried to find out more about this group and I have been stymied.
Their so-called website is a couple of pages (at best) on the German DPA's
website.  There is no list of members, no record of the meeting in Paris
where this was approved, no indication who participated in the preparation
of this paper and what their roles were.  I suppose I shouldn't be
surprised to see that from a group of privacy advocates.  I do long for the
day when "transparency" and "accountability" were considered good things.

Given the above, I would give this high marks as propaganda, but I'll
withhold my judgment otherwise, until I can actually give this thing a
close read.  What I won't do is treat it as if it were tablets brought down
from the mount, before which I should prostrate myself, trembling in fear
and awe.

Greg

On Sat, Mar 10, 2018 at 9:48 AM, Victoria Sheckler <vsheckler at riaa.com>
wrote:

> 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> <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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