[Accred-Model] WHOIS Tiered Access and Accreditation Program: Comments from M3AAWG

[Rubens Kuhl]

I would like to set some real expectations on this so people don't claim "Surprise!" later on.

- No policies, temporary or consensus policies,  can trump applicable law. Parties to a contract, or 3rd parties in this case, are not allowed to interpret the law as they see fit, and ICANN contracts in particular recognize that reality.
- Even credentialed tiered WHOIS might not fit GDPR, as the recent Article 29 WP letter made clear; IP-based whitelist would clearly not cut it.

The global public interest would likely be better served by approaching EU lawmakers to bake use cases such as anti-abuse into law; until then, EU DPAs will have no option besides compelling ICANN and contracted parties into changing WHOIS to a mostly privacy-oriented information service.


Rubens

> Em 13 de abr de 2018, à(s) 14:37:000, Jerry Upton <jerry.upton at gmail.com> escreveu:
> 
> 
> Dear Mr. Göran Marby CEO, ICANN
> 
> We agree with the Anti-Phishing Working Group’s (APWG) comments dated April 5, 2018 that the anti-abuse community needs the ICANN Board to pass a Temporary Policy to make an accreditation plan a reality, directing the participation of the registry operators and registrars.
> 
> We agree that an expert group from the Anti-Abuse community including APWG, FIRST and M3AAWG should be created to facilitate the certification of qualified applicants from the security field.
> 
> We support a short-term plan discussed on the April 6th conference call offering tiered WHOIS access to authorized IP addresses until a more sophisticated mechanism can be a further developed with details for accredited access.
> 
> Sincerely,
> Jerry Upton
> Executive Director
> Messaging, Malware and Mobile Anti-Abuse Working Group
> https://w <http://www.m3aawg.org/>ww.m3aawg.org <http://www.m3aawg.org/>
> <M3AAWG-ICANN-WHOIS Tiered Access and Accreditation Program- Comments.pdf>_______________________________________________
> Accred-Model mailing list
> Accred-Model at icann.org
> https://mm.icann.org/mailman/listinfo/accred-model

-------------- next part --------------
An HTML attachment was scrubbed...
URL: <http://mm.icann.org/pipermail/accred-model/attachments/20180413/62f62cb0/attachment.html>
-------------- next part --------------
A non-text attachment was scrubbed...
Name: signature.asc
Type: application/pgp-signature
Size: 528 bytes
Desc: Message signed with OpenPGP
URL: <http://mm.icann.org/pipermail/accred-model/attachments/20180413/62f62cb0/signature.asc>