[Gnso-sc-budget] Travel Reports Now Meaningless, as Useful Data has been Redacted

Tue Aug 14 16:40:56 UTC 2018

Thanks for the clarification Ayden.

From: Ayden Férdeline [mailto:icann at ferdeline.com]
Sent: Tuesday, August 14, 2018 9:24 AM
To: Austin, Donna <Donna.Austin at team.neustar>
Cc: Stephanie Perrin <stephanie.perrin at mail.utoronto.ca>; Michele Neylon - Blacknight <michele at blacknight.com>; gnso-sc-budget at icann.org
Subject: Re: [Gnso-sc-budget] Travel Reports Now Meaningless, as Useful Data has been Redacted

Hi Donna,

I agree that this is something that exceeds the (current) remit of the Standing Committee.

I was raising this issue for information purposes only, and I am not sure there is any action that we can take as the Standing Committee.

However, I do think a letter on this issue would be helpful, and off-list the NCSG is currently drafting a response that we may send on our letterhead, as this seems the more appropriate path forward for now. We would be very open to sending a joint letter, if another Stakeholder Group or Constituency would like to join us. Please write to me off-list if you are interested.

Thanks, as always, for the input.

Best wishes,

Ayden Férdeline

On 13 Aug 2018, at 22:59, Austin, Donna <Donna.Austin at team.neustar<mailto:Donna.Austin at team.neustar>> wrote:

All

I understand the concerns here, but I think they are beyond the remit of Council Budget Standing Committee. Happy to hear from others why they think this is something that the SC should pursue.

Donna
From: Gnso-sc-budget [mailto:gnso-sc-budget-bounces at icann.org] On Behalf Of Stephanie Perrin
Sent: Monday, August 13, 2018 6:08 AM
To: Michele Neylon - Blacknight <michele at blacknight.com<mailto:michele at blacknight.com>>; Ayden Férdeline <icann at ferdeline.com<mailto:icann at ferdeline.com>>
Cc: gnso-sc-budget at icann.org<mailto:gnso-sc-budget at icann.org>
Subject: Re: [Gnso-sc-budget] Travel Reports Now Meaningless, as Useful Data has been Redacted

Most data protection laws do not accept disclosure in one forum as a consent for all disclosure, nor the erasure of the character of personal data as personal once it has been published.  IF that were the case, we would all be done in re birthdates by our parents' birth announcements on our arrival....
Trust ICANN to overreact on these issues.  Plain and simple, if you want to take advantage of the fellowship program, you have to do it transparently.  IF you want to fly on ICANN's dime, you have to do it transparently.  This is perfectly legitimate and indeed necessary.....
Shall we write the Privacy Officer and complain?  Happy to do that, I am v grumpy today....(having one of those why do I volunteer at ICANN, I could be fighting for the preservation of the Eastern pink bog lily instead of wasting my time preaching about privacy here.....)
cheers Stephanie
On 2018-08-13 08:40, Michele Neylon - Blacknight wrote:
Re: bios – aren’t most people using LinkedIn already? Which would kind of render ICANN’s “protection” moot?

--
Mr Michele Neylon
Blacknight Solutions
Hosting, Colocation & Domains
https://www.blacknight.com/<https://urldefense.proofpoint.com/v2/url?u=https-3A__www.blacknight.com_&d=DwMDaQ&c=MOptNlVtIETeDALC_lULrw&r=CwipU91YB6EkpFXK9ynnT_QUef4yC5p7jpsDm8cU97g&m=116A6SZnS7tKNHjFoXCEqutuAijTUEYfGDsro_vpTp0&s=WCV4mttw-pjuqiTzixBKdnEqytST2JxeYKqgyQ8Bmq4&e=>
https://blacknight.blog/<https://urldefense.proofpoint.com/v2/url?u=https-3A__blacknight.blog_&d=DwMDaQ&c=MOptNlVtIETeDALC_lULrw&r=CwipU91YB6EkpFXK9ynnT_QUef4yC5p7jpsDm8cU97g&m=116A6SZnS7tKNHjFoXCEqutuAijTUEYfGDsro_vpTp0&s=suzkgZO8Dq01b0YJEShTATA6mGoivnNva58M20f08qQ&e=>
Intl. +353 (0) 59  9183072
Direct Dial: +353 (0)59 9183090
Personal blog: https://michele.blog/<https://urldefense.proofpoint.com/v2/url?u=https-3A__michele.blog_&d=DwMDaQ&c=MOptNlVtIETeDALC_lULrw&r=CwipU91YB6EkpFXK9ynnT_QUef4yC5p7jpsDm8cU97g&m=116A6SZnS7tKNHjFoXCEqutuAijTUEYfGDsro_vpTp0&s=s05RE5tXdrB2VrnsAEwsfyjh5TQeP_pAcLTEGaI5gYg&e=>
Some thoughts: https://ceo.hosting/<https://urldefense.proofpoint.com/v2/url?u=https-3A__ceo.hosting_&d=DwMDaQ&c=MOptNlVtIETeDALC_lULrw&r=CwipU91YB6EkpFXK9ynnT_QUef4yC5p7jpsDm8cU97g&m=116A6SZnS7tKNHjFoXCEqutuAijTUEYfGDsro_vpTp0&s=4NGvRYC8y5EjikXSuMAGs3GsRF_Xo3FeS7JKFzaoGco&e=>
-------------------------------
Blacknight Internet Solutions Ltd, Unit 12A,Barrowside Business Park,Sleaty
Road,Graiguecullen,Carlow,R93 X265,Ireland  Company No.: 370845

From: Ayden Férdeline <icann at ferdeline.com><mailto:icann at ferdeline.com>
Reply-To: Ayden Férdeline <icann at ferdeline.com><mailto:icann at ferdeline.com>
Date: Monday 13 August 2018 at 09:55
To: Stephanie Perrin <stephanie.perrin at mail.utoronto.ca><mailto:stephanie.perrin at mail.utoronto.ca>
Cc: Michele Neylon <michele at blacknight.com><mailto:michele at blacknight.com>, "gnso-sc-budget at icann.org"<mailto:gnso-sc-budget at icann.org> <gnso-sc-budget at icann.org><mailto:gnso-sc-budget at icann.org>
Subject: Re: [Gnso-sc-budget] Travel Reports Now Meaningless, as Useful Data has been Redacted

I would certainly like to see the Privacy Impact Assessment that was undertaken to better understand ICANN’s concerns here.

I note that the Independent Parliamentary Standards Authority in the UK, which compiles and publishes the expense reports for elected members of Parliament, is continuing to publish expense reports. It updated its publication policy<https://urldefense.proofpoint.com/v2/url?u=http-3A__www.theipsa.org.uk_media_184882_ccs0718117668-2D001-5Fipsa-2Dpublication-2Dscheme-5Fweb-2Daccessible-2D3.pdf&d=DwMDaQ&c=MOptNlVtIETeDALC_lULrw&r=CwipU91YB6EkpFXK9ynnT_QUef4yC5p7jpsDm8cU97g&m=116A6SZnS7tKNHjFoXCEqutuAijTUEYfGDsro_vpTp0&s=j0NTWgEEL1KA0D9Vsc94N2LKuzDFCsPVOIw8VHHE2YY&e=> in July 2018, and in this document it outlines what it will and will not publish. It will not publish “specific details of any disability assistance”, for instance, but it will publish the total claimed by the MP annually from the disability assistance budget.

So I do think ICANN could find a way to publish more complete travel reports.

I also note that, in the response to the recent consultation on the future of the fellowship program, ICANN wrote<https://urldefense.proofpoint.com/v2/url?u=https-3A__www.icann.org_en_system_files_files_report-2Dcomments-2Dfellowship-2Dproposal-2D10aug18-2Den.pdf&d=DwMDaQ&c=MOptNlVtIETeDALC_lULrw&r=CwipU91YB6EkpFXK9ynnT_QUef4yC5p7jpsDm8cU97g&m=116A6SZnS7tKNHjFoXCEqutuAijTUEYfGDsro_vpTp0&s=argSp9Yzby867GYWyt9NwpdALecJ9ANp3tsM5QQ_oFI&e=>  "For reasons relating to privacy and data protection, suggestions relating to publishing biographies of selected fellows … [are not] feasible.”

I think this was an over-reaction; surely a bio (written by the fellow themselves, containing the information they would like others to know about them) can be published.

I raise this because I am concerned that the GDPR is being over-applied by ICANN (and not being applied where it should be…) to the detriment of ICANN’s bylaw-mandated principles of accountability and transparency.

—Ayden

On 9 Aug 2018, at 13:01, Stephanie Perrin <stephanie.perrin at mail.utoronto.ca<mailto:stephanie.perrin at mail.utoronto.ca>> wrote:

I think the basic answer to that question is the inference potential.  If I spent over 4000 on a flight to Brussels, (which I did) either:  I needed a visa and was really late getting it (raises questions re citizenship) or I am flying business class (raises questions about health issues, since that is one of the few criteria which ICANN accepts as rationale to fly anything other than economy.  So one could potentiallyidentify the individual from this data in some cases.
They most probably are being protective of any of the folks flying business for medical reasons, because of the categorization of health data as sensitive in the EU.  Just a guess.
cheers SP

On 2018-08-08 14:05, Ayden Férdeline wrote:
I’m struggling to understand what even is personal data here.

We are not disclosing the supported traveler’s passport number or even their city of departure, just the cost of their flight…

Ayden

On 8 Aug 2018, at 20:02, Michele Neylon - Blacknight <michele at blacknight.com<mailto:michele at blacknight.com>> wrote:

Stephanie

I don’t think it’s unreasonable to make disclosure a condition of receiving funding. Every funded traveller gets an email from ICANN when they’re approved for a meeting so including something there that gets them to sign off on the consent might work?

I’ve no idea what the case law etc., is around this in the EU, but it shouldn’t be hard to find out.

Regards

Michele

--
Mr Michele Neylon
Blacknight Solutions
Hosting, Colocation & Domains
https://www.blacknight.com<https://urldefense.proofpoint.com/v2/url?u=https-3A__www.blacknight.com_&d=DwMDaQ&c=MOptNlVtIETeDALC_lULrw&r=CwipU91YB6EkpFXK9ynnT_QUef4yC5p7jpsDm8cU97g&m=116A6SZnS7tKNHjFoXCEqutuAijTUEYfGDsro_vpTp0&s=WCV4mttw-pjuqiTzixBKdnEqytST2JxeYKqgyQ8Bmq4&e=>
https://blacknight.blog<https://urldefense.proofpoint.com/v2/url?u=https-3A__blacknight.blog_&d=DwMDaQ&c=MOptNlVtIETeDALC_lULrw&r=CwipU91YB6EkpFXK9ynnT_QUef4yC5p7jpsDm8cU97g&m=116A6SZnS7tKNHjFoXCEqutuAijTUEYfGDsro_vpTp0&s=suzkgZO8Dq01b0YJEShTATA6mGoivnNva58M20f08qQ&e=> /
http://ceo.hosting/<https://urldefense.proofpoint.com/v2/url?u=http-3A__ceo.hosting_&d=DwMDaQ&c=MOptNlVtIETeDALC_lULrw&r=CwipU91YB6EkpFXK9ynnT_QUef4yC5p7jpsDm8cU97g&m=116A6SZnS7tKNHjFoXCEqutuAijTUEYfGDsro_vpTp0&s=J3JdvrKX7xwXHwikD86yPZX-1gAmEzPId7HwxkALsPM&e=>
Intl. +353 (0) 59  9183072
Direct Dial: +353 (0)59 9183090
-------------------------------
Blacknight Internet Solutions Ltd, Unit 12A,Barrowside Business Park,Sleaty
Road,Graiguecullen,Carlow, R93 X265
,Ireland  Company No.: 370845

From: Gnso-sc-budget <gnso-sc-budget-bounces at icann.org<mailto:gnso-sc-budget-bounces at icann.org>> on behalf of Stephanie Perrin <stephanie.perrin at mail.utoronto.ca<mailto:stephanie.perrin at mail.utoronto.ca>>
Date: Wednesday 8 August 2018 at 17:51
To: "gnso-sc-budget at icann.org<mailto:gnso-sc-budget at icann.org>" <gnso-sc-budget at icann.org<mailto:gnso-sc-budget at icann.org>>
Subject: Re: [Gnso-sc-budget] Travel Reports Now Meaningless, as Useful Data has been Redacted

I am inclined to think they are over-complying here, but that opinion is based on our own law which has a specific exemption for personal info when you are receiving a grant or benefit from the government....private sector is different.  I think they could make funding conditional on disclosure (so based on consent)....but there may be precedents in Europe to stop that kind of tied consent.  I think it is worth a try though.....
cheers SP
On 2018-08-08 12:43, Ayden Férdeline wrote:
Yes, that’s correct Michele. We also no longer know the class of travel that each supported traveler travelled in.

Ayden

On Wed, Aug 8, 2018 at 18:19, Michele Neylon - Blacknight <michele at blacknight.com<mailto:michele at blacknight.com>> wrote:
So the names are listed but not the spend per person?
Just the spend per "bucket"?

--
Mr Michele Neylon
Blacknight Solutions
Hosting, Colocation & Domains
https://www.blacknight.com/<https://urldefense.proofpoint.com/v2/url?u=https-3A__www.blacknight.com_&d=DwMDaQ&c=MOptNlVtIETeDALC_lULrw&r=CwipU91YB6EkpFXK9ynnT_QUef4yC5p7jpsDm8cU97g&m=116A6SZnS7tKNHjFoXCEqutuAijTUEYfGDsro_vpTp0&s=WCV4mttw-pjuqiTzixBKdnEqytST2JxeYKqgyQ8Bmq4&e=>
http://blacknight.blog/<https://urldefense.proofpoint.com/v2/url?u=http-3A__blacknight.blog_&d=DwMDaQ&c=MOptNlVtIETeDALC_lULrw&r=CwipU91YB6EkpFXK9ynnT_QUef4yC5p7jpsDm8cU97g&m=116A6SZnS7tKNHjFoXCEqutuAijTUEYfGDsro_vpTp0&s=HLPB4ahW-Y5VYJzxK2MdhBVYjC8mZGUe0HWpmd9MGrw&e=>
Intl. +353 (0) 59  9183072
Direct Dial: +353 (0)59 9183090
Personal blog: https://michele.blog/<https://urldefense.proofpoint.com/v2/url?u=https-3A__michele.blog_&d=DwMDaQ&c=MOptNlVtIETeDALC_lULrw&r=CwipU91YB6EkpFXK9ynnT_QUef4yC5p7jpsDm8cU97g&m=116A6SZnS7tKNHjFoXCEqutuAijTUEYfGDsro_vpTp0&s=s05RE5tXdrB2VrnsAEwsfyjh5TQeP_pAcLTEGaI5gYg&e=>
Some thoughts: https://ceo.hosting/<https://urldefense.proofpoint.com/v2/url?u=https-3A__ceo.hosting_&d=DwMDaQ&c=MOptNlVtIETeDALC_lULrw&r=CwipU91YB6EkpFXK9ynnT_QUef4yC5p7jpsDm8cU97g&m=116A6SZnS7tKNHjFoXCEqutuAijTUEYfGDsro_vpTp0&s=4NGvRYC8y5EjikXSuMAGs3GsRF_Xo3FeS7JKFzaoGco&e=>
-------------------------------
Blacknight Internet Solutions Ltd, Unit 12A,Barrowside Business Park,Sleaty
Road,Graiguecullen,Carlow,R93 X265,Ireland  Company No.: 370845

From: Gnso-sc-budget <gnso-sc-budget-bounces at icann.org><mailto:gnso-sc-budget-bounces at icann.org> on behalf of Ayden Férdeline <icann at ferdeline.com><mailto:icann at ferdeline.com>
Reply-To: Ayden Férdeline <icann at ferdeline.com><mailto:icann at ferdeline.com>
Date: Wednesday 8 August 2018 at 15:56
To: "gnso-sc-budget at icann.org"<mailto:gnso-sc-budget at icann.org> <gnso-sc-budget at icann.org><mailto:gnso-sc-budget at icann.org>
Subject: [Gnso-sc-budget] Travel Reports Now Meaningless, as Useful Data has been Redacted

Sharing this for information purposes, and because it may be of interest to subscribers of this list—

The travel reports that ICANN org publishes are now meaningless, because all the relevant information has been redacted.

The explanation that was provided for this change is as follows:
In light of recent changes in privacy regulations, ICANN Travel Support is making enhancements to the Travel Reports that are published for every meeting for our funded travelers. Moving forward, ICANN will publish the overall cost per group and will be redacting the individual cost per traveler. This change will be reflected on ICANN62 Travel Report and subsequent reports moving forward.

Source:https://community.icann.org/display/trvlconstit/Travel+Report<https://urldefense.proofpoint.com/v2/url?u=https-3A__community.icann.org_display_trvlconstit_Travel-2BReport&d=DwMDaQ&c=MOptNlVtIETeDALC_lULrw&r=CwipU91YB6EkpFXK9ynnT_QUef4yC5p7jpsDm8cU97g&m=116A6SZnS7tKNHjFoXCEqutuAijTUEYfGDsro_vpTp0&s=5n4jcZKAN91mXlJgeayTDAzu3VSYs4v5evpd7TqJ4sc&e=>

Presumably the ‘privacy regulations’ this refers to is the GDPR, which does not actually require that this data be redacted.

Per page 19, it cost USD 24,804.03 to bring five NextGen Ambassadors to Panama, which at an average of $4,960 a traveler, was substantially more than the average cost per GNSO traveler (which was $2,518/traveler). Without additional data it is difficult to understand why the average cost was so much higher. Was it one traveler whose airfare was disproportionately expensive, or is it something more systematic?

I would like to see the travel reports continue to be published in a way that is meaningful, while all of course compliant with the GDPR. If anyone has some suggestions as to how this issue could be taken forward, I would appreciate hearing from you.

Many thanks,

Ayden

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