[Accred-Model] Version 1.6 of the Accreditation and Access Model
Stephanie Perrin
stephanie.perrin at mail.utoronto.ca
Tue Jun 19 23:14:37 UTC 2018
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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