[Comments-atrt3-draft-report-16dec19] Regarding sections 10.5

[Heather Flanagan]

Hello review team members,

The reviews I’ve read through or observed to date appear to come down to two basic characteristics and requirements:

1 - They need to hold ICANN accountable to the world that ICANN is doing what it says it’s going to do in its policies and procedures.

2 - They need to be handled in a timely enough fashion that ICANN has time to respond to the review and change their processes and procedures as necessary.

The current review team model is indeed dysfunctional, with too many reviews running at the same time, and too many recommendations for ICANN to be able to respond to effectively, and it does not appear that the current review process is meeting either of those basic requirements.

Rather than require a review team to try and do all its work in a 5 day workshop, which seems unreasonable and almost designed to result in a very shallow review, I personally would recommend that ICANN treat this as a more typical audit process and hire a firm that does audits for a living to evaluate if ICANN is following its own processes and procedures, and to make recommendations where those processes/procedures are insufficient or otherwise not being met. The final report from the audit company can be made available for public comment, thus keeping that public accountability open. 

It may be that an audit isn’t a correct model in all cases, but it certainly will fill some (e.g., SSR and WHOIS/RDS) but the idea has the potential to cut down on the number of review teams running concurrently, and given the contractual arrangement with an audit firm, you can set a more reasonable time limit (e.g., 6 months per review).

I hope this suggestion is useful, and I wish you the best with wrapping up the ATRT3 process.

Heather Flanagan