susankpolicy at gmail.com
Thu May 24 00:26:09 UTC 2018
I have given the potential ePDP much thought over the last two days.
To effectively do this work at the speed that it will require we need to
focus the ePDP. As you all know this is a tremendous amount of work.
We need to address the following:
Including at the very least the GAC and SSAC in this ePDP will be critical.
The members of the team should be limited to 5-6 members of each SG/AC.
Each member must agree to accept the fast paced extensive work load,
participating on calls, subgroups and drafting when necessary.
Understand that their work is representational of the community they are
affiliated with and will receive endorsement to express views.
Create a leadership team with extensive knowledge and time to focus on this
Select a Chair that will have the time and skills to effectively manage the
Include a Board member for oversight and check ins on the team.
This ePDP should focus on the critical needs identified in the Annex of the
Temporary Spec. first as these issues are of critical importance. (copied
below for ease of reference)
Annex: Important Issues for Further Community Action
The purpose of this Annex is to set forth implementation issues raised
during the course of development of this Temporary Specification for which
the ICANN Board encourages the community to continue discussing so that
they may be resolved as quickly as possible after the effective date of the
Temporary Specification. This Annex does not create new or modified
requirements for Registrar or Registry Operator, nor is it intended to
direct the scope of the Policy Development Process, which will be initiated
as a result of the Board’s adoption of thisTemporary Specification.
Pursuant to Section 4.4, continuing community work to develop an
accreditation and access model that complies with GDPR, while recognizing
the need to obtain additional guidance from Article 29 Working
Party/European Data Protection Board.
Addressing the feasibility of requiring unique contacts to have a
uniform anonymized email address across domain name registrations at a
given Registrar, while ensuring security/stability and meeting the
requirements of Section 2.5.1 of Appendix A.
Developing methods to provide potential URS and UDRP complainants with
sufficient access to Registration Data to support good-faith filings of
Consistent process for continued access to Registration Data, including
non- public data, for users with a legitimate purpose, until the time when
a final accreditation and access mechanism is fully operational, on a
mandatory basis for all contracted parties.
Distinguishing between legal and natural persons to allow for public
access to the Registration Data of legal persons, which are not in the
remit of the GDPR.
Limitations in terms of query volume envisaged under an accreditation
program balanced against realistic investigatory cross-referencing needs.
Confidentiality of queries for Registration Data by law enforcement
Looking forward to discussing further tonight.
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