[Accred-Model] Annotated - WHOIS Accreditation and Access Model v1.4

[Rubens Kuhl]

Personal comments for Access Model v1.4:

- Granting access for all records is not granular enough to fit GDPR. I refer to my message from April 13, stored at https://mm.icann.org/pipermail/accred-model/2018-April/000022.html <https://mm.icann.org/pipermail/accred-model/2018-April/000022.html> , and further discussions on the thread indicating it would be likely viable to do an RDAP implementation with that access workflow.
- I welcome the reference(footnote 12) to an anonymised form of data access that could serve correlation purposes that are useful to both security practitioners and IP abuse pattern detection, but the idea of it being a "future update" goes against what DPAs already said(https://iapp.org/news/a/dpas-to-pros-theres-no-grace-period-folks/ <https://iapp.org/news/a/dpas-to-pros-theres-no-grace-period-folks/>) that there is no interim period of forbearance.
- I also support the "Philly Special"(https://mm.icann.org/pipermail/accred-model/2018-April/000054.html <https://mm.icann.org/pipermail/accred-model/2018-April/000054.html>) add-on of creating a financial mechanism of compliance. I would only add the possibility of data controllers that end up being fined by DPAs due to misuse by an authorised requestor also be covered.

I'll do my best to attend today's call, but it's very likely I can only be there for a few minutes, and probably not the ones where the more operational aspects will be discussed.


Rubens





> On 20 Apr 2018, at 19:47, Vayra, Fabricio (Perkins Coie) <FVayra at perkinscoie.com> wrote:
> 
> Attached for discussion and further comment please find an annotated Accreditation and Access Model v1.4 document.
> 
> Thanks for your continued community participation in the creation of this accreditation and access model.
> 
> We appreciate your support and commitment and look forward to further discussion next week.
> 
> Thanks,
> 
> Fabricio Vayra | Perkins Coie LLP
> PARTNER
> D. +1.202.654.6255
> 
> 
> 
> NOTICE: This communication may contain privileged or other confidential information. If you have received it in error, please advise the sender by reply email and immediately delete the message and any attachments without copying or disclosing the contents. Thank you.
> <Annotated - WHOIS Accreditation and Access Model v1.4.pdf>_______________________________________________
> Accred-Model mailing list
> Accred-Model at icann.org <mailto:Accred-Model at icann.org>
> https://mm.icann.org/mailman/listinfo/accred-model <https://mm.icann.org/mailman/listinfo/accred-model>
-------------- next part --------------
An HTML attachment was scrubbed...
URL: <http://mm.icann.org/pipermail/accred-model/attachments/20180424/17c70149/attachment.html>
-------------- next part --------------
A non-text attachment was scrubbed...
Name: signature.asc
Type: application/pgp-signature
Size: 529 bytes
Desc: Message signed with OpenPGP
URL: <http://mm.icann.org/pipermail/accred-model/attachments/20180424/17c70149/signature.asc>