[registration-issues-wg] [CPWG] [ALAC] URGENT: DRAFT ALAC Statement on the EPDP Phase 1 Final Report

Bartlett Morgan bartlett.morgan at gmail.com
Fri Feb 15 22:40:07 UTC 2019


+1

On Fri, Feb 15, 2019, 13:59 Kan Kaili <kankaili at gmail.com wrote:

> My support as well.
>
> Kaili
>
>
>
> ----- Original Message -----
> From: "Alan Greenberg" <alan.greenberg at mcgill.ca>
> To: "Bastiaan Goslings" <bastiaan.goslings at ams-ix.net>; "Holly Raiche" <
> h.raiche at internode.on.net>
> Cc: "CPWG" <cpwg at icann.org>; "ALAC" <alac at atlarge-lists.icann.org>
> Sent: Friday, February 15, 2019 10:42 PM
> Subject: Re: [CPWG] [ALAC] URGENT: DRAFT ALAC Statement on the EPDP Phase
> 1 Final Report
>
>
> At 15/02/2019 02:45 AM, Bastiaan Goslings wrote:
> >Thanks - I cannot join this evening’s (CET)
> >CPWG call and therefore want to express my
> >support for the statement. If it comes to a vote
> >during the call then please include my explicit endorsement.
>
> Thanks!  If other ALAC Members are in the same
> position, a message of support prior to the
> meeting will allow us to know if there is sufficient support.
>
>
>
> >Just a comment, and if not relevant then ignore,
> >but I took the final report from 11 February
> >that was sent to the GNSO council on the 12th as
> >a reference to see what our concerns apply to. I am somewhat confused:
> >
> >
> >- Rec#16 states ‘that Registrars and Registry
> >Operators are permitted to differentiate between
> >registrants on a geographic basis, but are not obligated to do so.’
> >
> >Our response says ‘The report recommends that
> >contracted parties will not need to perform any
> >level of geographic differentiation due to the
> >difficulty of determining the location of the registrant.’
> >
> >I cannot find that argument (‘due to’) in
> >the draft final report. However rec#5 requires
> >registrars to a.o. collect address- incl country
> >data from registrants.  So on the one hand hand
> >the data are collected and (should be) accurate,
> >and on the other it is ‘difficult’ to
> >‘determine the location of the registrant’?
>
> The contracted parties have said there is too
> much risk of incorrectly identifying whether GDPR
> is applicable to the registrant. We both have the
> same difficulty in reconciling these two facts.
>
> The other factor is that a registrar outside of
> the EU who has resellers "might" have a reseller
> in the EU (ie a "processor") without their
> knowledge be cause resellers can have resellers
> can have resellers... and the original registrar
> has no idea who they are. That should be fixed by requiring that they know!
>
>
>
> >- Rec#5 lists the ‘data elements to be
> >collected where some data elements are
> >automatically generated and, as indicated below,
> >in some cases it is optional for the registered
> >name holder to provide those data elements.
> >
> >The ‘tech fields’ (name, phone and email) in
> >the ‘data elements’ table are not
> >‘indicated’ as being ‘optional’. Like
> >for instance the ‘organization’ and
> >‘fax’ fields of the ‘registrant’ (=
> >‘opt.’) . Then there is a note ‘For the
> >purpose of the Technical contact, which is
> >optional for the Registered Name Holder to
> >complete (and if the Registrar provides this
> >option)’.  Etc. Why are the technical contact
> >data elements not labeled in the table as being ‘(opt.)’?
>
> I have pointed out that apparent discrepancy and presume it will be fixed.
>
> Alan
>
>
>
> >thanks again, with regards
> >Bastiaan
> >
> >
> >
> >
> >***  Please note that this communication is
> >confidential, legally privileged, and subject to
> >a disclaimer: https://www.ams-ix.net/ams/email-disclaimer  ***
> >
> >
> >
> >
> > > On 15 Feb 2019, at 04:17, Holly Raiche <h.raiche at internode.on.net>
> wrote:
> > >
> > > Thank you Alan
> > >
> > > I think you have captured the outcomes of the
> > CPWG discussions very well.  I am happy with
> > this statement and have no further comments
> > >
> > > Holly
> > >
> > >> On Feb 15, 2019, at 11:28 AM, Alan Greenberg
> > <alan.greenberg at mcgill.ca> wrote:
> > >>
> > >> As discussed on the CPWG call yesterday,
> > attached please find the draft statement to be attached to the report.
> > >>
> > >> I believe that it addresses all of the
> > issues we discussed and for which there was
> > general concern. As decided, we will support
> > the overall report, but note that some of the
> > particular recommendations do not have our
> > support. Others we will support but nevertheless have concerns.
> > >>
> > >> The lack of focus on public interest issues
> > puts into question whether Phase 2 will
> > suitably address access and other issues.
> > >>
> > >> THIS STATEMENT MUST BE SUBMITTED BY THE END
> > OF FRIDAY. Please make any comments with utmost urgency.
> > >>
> > >> Maureen tells me that she will issue a VERY
> > SHORT Consensus Call tomorrow, to complete prior to the submission
> deadline.
> > >>
> > >> WORD and PDF formats are attached.
> > >>
> > >> Alan
> > >>
> >
> <ALAC-Statement-v01.docx><ALAC-Statement-v01.pdf>_______________________________________________
> > >> ALAC mailing list
> > >> ALAC at atlarge-lists.icann.org
> > >> https://atlarge-lists.icann.org/mailman/listinfo/alac
> > >>
> > >> At-Large Online: http://www.atlarge.icann.org
> > >> ALAC Working Wiki:
> >
> https://community.icann.org/display/atlarge/At-Large+Advisory+Committee+(ALAC)
> > >
> > > _______________________________________________
> > > ALAC mailing list
> > > ALAC at atlarge-lists.icann.org
> > > https://atlarge-lists.icann.org/mailman/listinfo/alac
> > >
> > > At-Large Online: http://www.atlarge.icann.org
> > > ALAC Working Wiki:
> >
> https://community.icann.org/display/atlarge/At-Large+Advisory+Committee+(ALAC)
> >
> >
>
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