[Accred-Model] Version 1.6 of the Accreditation and Access Model

[Michael Palage]

Hello Fab,

 

In Section III.I of Version 1.6 it states in relevant part:

 

 

Different terms and conditions are applied to different purposes. Violation
of terms and conditions may result in graduated penalties (such as
restricted/throttled access, or denial of further access -- see Section
V(f), Data Misuse Penalties).

 

I believe that should read Section IV(F).  

 

My primary substantive concern is that this document solely focuses on
Penalties in the context of a User's 'future" blocked or restricted access
(throttled).  There is NO mechanism to compensate the Data Subject whose
rights have been violated.  That just seems fundamentally flawed to me.

 

As someone that was involved in the drafting of the original UDPR, we looked
at the respective rights of both the Trademark Holder and the Registrant.  I
feel that failure to account for a right of action by the Data Subject when
a User has exceeded their rights is deeply troubling.

 

Best regards,

 

Michael

 

From: Accred-Model <accred-model-bounces at icann.org> On Behalf Of Vayra,
Fabricio (Perkins Coie)
Sent: Monday, June 18, 2018 9:37 AM
To: 'accred-model at icann.org' <accred-model at icann.org>
Subject: Re: [Accred-Model] Version 1.6 of the Accreditation and Access
Model

 

Please see attached version 1.6 of the Accreditation and Access Model that
includes tweaks to the second paragraph under the introduction in Annex I:
Registration Directory Service Accreditation Authority (RDSAA).

 

Thanks and we look forward to your further input.

 

Fabricio Vayra | Perkins Coie LLP

PARTNER

D. +1.202.654.6255

 

From: Vayra, Fabricio (WDC) 
Sent: Saturday, June 16, 2018 1:29 AM
To: 'accred-model at icann.org' <accred-model at icann.org
<mailto:accred-model at icann.org> >
Subject: Version 1.6 of the Accreditation and Access Model

 

Attached for discussion and additional comment is version 1.6 of the
Accreditation and Access Model.  This, following further comment and input
from many parts of the community, is a much richer and robust model.
Notably, this version 1.6 contains new:

 

*	Annex D: Accreditation Approach for Intellectual Property Owners and
Agents
*	Annex J: Lawful Bases for Access to WHOIS Data

 

Many thanks to those who made constructive contributions to further
developing this model.

  

Thank you again for your input and support.

 

Fabricio Vayra | Perkins Coie LLP

PARTNER

D. +1.202.654.6255

 

 

  _____  


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