Input to Expert Working Group on gTLD Directory Services Data Elements Will Require a Separate Review by the ICANN Community

Kathy Kleiman kathy at
Thu Aug 22 12:21:15 UTC 2013

*//*We submit the following comments (below and attached) to the EWG on 
the issue of Data Elements and Need for Second Interim Report for 
Community Review.

*/ */Kathy Kleiman
Tamir Israel
Milton Mueller
Roy Balleste
Robin Gross
Avri Doria
Marie-Laure Lemineur
Peter Green
Edward Morris
All members of the NCSG

Data Elements Will Require a Separate Review by the ICANN Community; a 
Second Interim Report & Public Notice */

Throughout the Durban meeting process, the same question was asked again 
and again: /*what data elements is the EWG proposing for the Centralized 
Database (or any Whois database)? */We received no clear answer.

The reason for the question is clear: in light of the abuses of Whois 
data, the laws that protect personal data, both for data protection and 
freedom of expression reasons, the dangers of centralized data, and the 
very personal and controversial nature of some of the data elements 
proposed for inclusion in the new database or databases, /*the specific 
data elements are very, very important to the public policy discussion 
that the EWG has asked to take place. */

We in the NCSG strongly recommend a future Whois/gTLD Directory 
database(s) fully streamlined with clear, minimal information (e.g., 
operating at the minimal "contactability" standard recommended by the 
Whois Review Team with only technical data and a validated telephone 
number OR email address). Such a database raises few of the privacy, 
speech and scope concerns that caused passionate comments and criticisms 
at the microphone in the EWG Durban meeting.

But the EWG Report, read closely/*, includes the collection of numerous 
new data elements including those not even currently collected by 
Registrars today. Frankly, it was shocking for us to see such the EWG 
Report and its list of data elements. Such a collection of all possible 
information and data for all possible purposes without regard to 
legality, scope of ICANN, impossibility or dangers it presents is not 
appropriate and threatens the narrow scope, limit and fabric of ICANN. */

_Accordingly, we reject for inclusion in any future Whois/Directory 
Database records which include:_
Registrant Postal Address

Registrant Telephone Number AND Email Address (as only one is needed and 
validated per the Registrar Accreditation Agreement)
Registrant IP Address
Registrant Type
Registrant Purpose
And many other fields presented without clear explanation as to 
definition, scope or purpose.

In fact, we find morally offensive the new move to categorize speech and 
speakers through the new Directory Services in a way that moves ICANN 
squarely and fully into the role of speech monitor and communications 
overseer -- so far outside ICANN's limited technical scope and mission 
that these fields must be dropped immediately and subject to no further 

*Conclusion: *

While we have been told again and again that the EWG is still "deciding 
on the data elements, /*we must respectfully reject any final report 
that has not previously published the exact data elements proposed to be 
included in a future Whois/Directory Database prior to the final report 
-- in a preliminary way that allows for initial evaluation, feedback and 
comment by the Community.*/

But on initial review, the drafts before us are shocking in their scope, 
excessive in their inclusion, and reflecting a wish list of one 
Stakeholder Group which happens to be over-represented on the EWG.

*/The NCSG calls on the EWG to minimize and streamline information Data 
Elements proposed for any new Whois or Directory Service plan -- and to 
publish it early and quickly for additional review by the ICANN and 
Internet Community /**/_prior to any final proposal._/**//*

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