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

[Stephanie Perrin]

Enforcement of individual rights is indeed hard.  But worth it.  We 
don't have much of a democracy when people decide that fundamental 
rights are just too hard to bother with...

Stephanie Perrin

On 2018-06-19 14:26, Cyntia King wrote:
>
> This would be an enforcement nightmare.
>
> Multiple enforcement mechanisms for ICANN Whois accreditation policy 
> including govt agencies - potentially many govts around the world.
>
>   * Could we implement standardized penalties?  Or would it vary
>     govt-to-govt?
>   * Would there also be private, for-profit enforcement entities?
>   * Would each entity be able to charge whatever they want?
>   * What would happen if a govt wasn’t following the rules themselves
>     - would they have provider contracts w/ ICANN?
>
> Unfortunately, this proposition sounds like an unmanageable, expensive 
> & fragmented mess to me.
>
> *Cyntia King*
>
> O:  +1 816.633.7647
>
> C:  +1 818.209.6088
>
> Email Logo5
>
> *From:* Rubens Kuhl <rubensk at nic.br>
> *Sent:* Tuesday, June 19, 2018 1:03 PM
> *To:* Cyntia King <cking at modernip.com>
> *Cc:* John R. Levine <johnl at iecc.com>; accred-model at icann.org
> *Subject:* Re: [Accred-Model] Version 1.6 of the Accreditation and 
> Access Model
>
> Cyntia,
>
> Just to be clear, the initial suggestion by Michael Palage 
> incorporated in itself a mechanism, instead of relying on Privacy 
> Shield. Perhaps Privacy Shield certification could be use to achieve 
> some of its requirements in order to save for organizations already 
> subscribed for it, instead of being the only option.
>
> Rubens
>
>
>
>     Em 19 de jun de 2018, à(s) 14:58:000, Cyntia King
>     <cking at modernip.com <mailto:cking at modernip.com>> escreveu:
>
>     Easy for whom?
>     I'm a small business owner & this is daunting, to say the least.
>     And there are multiple fees involved.
>
>     Are we suggesting that this should be ICANN’s enforcement
>     mechanism for accessing Whois data? This would be on top of the
>     accreditation & fees we’re already discussing, right?
>
>     What about ‘foreign’ companies - are we asking non-US companies to
>     self-certify w/ the Us govt?
>
>     I don’t see how this solves much of anything, but it would
>     certainly make accreditation more difficult & expensive.
>
>     *Cyntia King*
>
>     O:  +1 816.633.7647
>
>     C:  +1 818.209.6088
>
>     <image001.jpg>
>
>     -----Original Message-----
>     From: Accred-Model <accred-model-bounces at icann.org
>     <mailto:accred-model-bounces at icann.org>> On Behalf Of Rubens Kuhl
>     Sent: Tuesday, June 19, 2018 12:48 PM
>     To: John R. Levine <johnl at iecc.com <mailto:johnl at iecc.com>>
>     Cc: accred-model at icann.org <mailto:accred-model at icann.org>
>     Subject: Re: [Accred-Model] Version 1.6 of the Accreditation and
>     Access Model
>
>     > Em 19 de jun de 2018, à(s) 14:32:000, John R. Levine <johnl at iecc.com
>     <mailto:johnl at iecc.com>> escreveu:
>
>     >
>
>     >> It's great when there is actually an easy solution.  At least for
>     the many US companies, law firms, cybersecurity firms, and others
>     (and this a huge part of the group seeking access), they should
>     "self-certify" to the EU-US Privacy Shield, via procedures set up
>     by the US Department of Commerce and Federal Trade Commission.
>
>     >
>
>     > Well, at least until the EU courts kill privacy shield like they
>     did Safe Harbor.
>
>     >
>
>     > Banks and non-profits such as CAUCE are not eligible for Privacy
>     Shield (they're not regulated by the FTC or DOT.)  For small
>     organizations the PS rules are extremely conplex and there's a
>     mandatory annual payment to cover potential arbitration costs.
>
>     >
>
>     > Can we back up and explain what problem this overcomplex "solution"
>     is supposed to be solving here?
>
>     Having redress mechanisms for data subjects that have their data
>     privacy rights violated. With great power, there must also come
>     great responsibility.
>
>     Rubens
>
>
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