[council] Draft GNSO Council Letter to ICANN Board on EPDP Phase 1 Recommendations

[Darcy Southwell]

In follow up to my email below and today's Council discussion, please find
my proposed edits to section 2 attached.

Thanks,
Darcy

On Fri, Aug 16, 2019 at 10:13 AM Darcy Southwell <
darcy.southwell at endurance.com> wrote:

> Thanks, all, for preparing this.  I’m struggling a bit with section 2.  I
> agree we’ve characterized Council’s position accurately in section 2.  But
> the rest seems confusing.  Did we already provide the Board with the
> written explanation of what was discussed in Marrakech?  If not, we should
> consider explaining that it’s provided now and then be more specific in our
> ask to the Board.
>
>
>
> Thanks,
>
> Darcy
>
>
>
> *From: *council <council-bounces at gnso.icann.org> on behalf of Michele
> Neylon - Blacknight <michele at blacknight.com>
> *Date: *Friday, August 16, 2019 at 8:35 AM
> *To: *Keith Drazek <kdrazek at verisign.com>, "council at gnso.icann.org" <
> council at gnso.icann.org>
> *Cc: *"gnso-secs at icann.org" <gnso-secs at icann.org>
> *Subject: *Re: [council] Draft GNSO Council Letter to ICANN Board on EPDP
> Phase 1 Recommendations
>
>
>
> Keith and Co
>
>
> Thanks for your work on this. I think it captures pretty accurately where
> we are at
>
>
>
> Regards
>
>
>
> Michele
>
>
>
>
>
> --
>
> Mr Michele Neylon
>
> Blacknight Solutions
>
> Hosting, Colocation & Domains
>
> https://www.blacknight.com/
>
> https://blacknight.blog/
>
> Intl. +353 (0) 59  9183072
>
> Direct Dial: +353 (0)59 9183090
>
> Personal blog: https://michele.blog/
>
> Some thoughts: https://ceo.hosting/
>
> -------------------------------
>
> Blacknight Internet Solutions Ltd, Unit 12A,Barrowside Business Park,Sleaty
>
> Road,Graiguecullen,Carlow,R93 X265,Ireland  Company No.: 370845
>
>
>
> *From: *council <council-bounces at gnso.icann.org> on behalf of "Drazek,
> Keith via council" <council at gnso.icann.org>
> *Reply to: *Keith Drazek <kdrazek at verisign.com>
> *Date: *Thursday 15 August 2019 at 17:59
> *To: *"council at gnso.icann.org" <council at gnso.icann.org>
> *Cc: *"gnso-secs at icann.org" <gnso-secs at icann.org>
> *Subject: *Re: [council] Draft GNSO Council Letter to ICANN Board on EPDP
> Phase 1 Recommendations
>
>
>
> Hi all,
>
>
>
> In preparation for our 22 August GNSO Council meeting, and further Council
> discussion on this topic, I am attaching an updated draft letter for your
> review.
>
>
>
> We have attempted to incorporate everyone’s comments and expressed views
> in this draft.
>
>
>
> To summarize, the goal of this letter is to:
>
>
>
>    1. Ensure the Council is proceeding as expected under Annex A-1
>    Section 6 of the ICANN Bylaws.
>    2. Create a record of the Council-Board engagement in Marrakech.
>    3. Advise the Board of the Council’s current thinking around
>    Recommendation #1, Purpose 2 and Recommendation #12.
>    4. Seek further input from the Board, and ideally confirm a common
>    understanding or more clearly understand any difference of opinion.
>    5. Ensure that the Council is setting good precedent in terms of how
>    we engage in this kind of situation.
>
>
>
> In response to comments from Marie and Flip, we have added language that
> acknowledges a difference of opinion among Councilors on the subject of Rec
> #12 and the deletion of data.
>
>
>
> Please review and provide any comments to the list. We will also discuss
> next week. Let me know if I missed anything.
>
>
>
> Thanks to all and I appreciate your patience on this one.
>
>
>
> Best,
>
> Keith
>
>
>
>
>
>
>
> *From:* council <council-bounces at gnso.icann.org> *On Behalf Of *Rubens
> Kuhl
> *Sent:* Tuesday, July 30, 2019 2:08 PM
> *To:* Flip Petillion <fpetillion at petillion.law>
> *Cc:* gnso-secs at icann.org; council at gnso.icann.org
> *Subject:* [EXTERNAL] Re: [council] Draft GNSO Council Letter to ICANN
> Board on EPDP Phase 1 Recommendations
>
>
>
>
>
>
>
> Em 30 de jul de 2019, à(s) 10:14:000, Flip Petillion <
> fpetillion at petillion.law> escreveu:
>
>
>
> Rubens,
>
>
>
> I share the feeling that it is uncommon to have a substantive discussion
> within the Council. However, that is exactly what the Bylaws mandate us to
> do within the atypical framework of expedited PDPs. Doesn’t the proposed
> one pager attached to the draft letter also address substance?
>
>
>
> I don't think the bylaws mandate who specifically does that. It's a
> substantive discussion, but in the same way we ask WGs to take them, we can
> ask the RegData EPDP WG to answer the substance. If we engage ourselves in
> a discussion where we first delegated authority to a WG, we would be
> disenfranchising them.
>
>
>
> BTW, Expedited PDPs only differ from Standard PDPs by not having an Issue
> Report to frame discussions. So everything we does here is a precedent for
> any future PDP, being an EPDP or not.
>
>
>
> As to your second comment, I think we owe it to the community to provide
> the Board with recommendations and reasoning that is legally sound. If
> certain aspects of privacy have been previously overlooked, now seems the
> time to correct them.
>
>
>
>
>
> IPC can send Board, PDP or anyone else any communication they see fit at
> any time. But the discussion here is not that, it's only the Board
> rationale for not approving the PDP recommendation.
>
>
>
>
>
> Rubens
>
>
>
>
>
> Best regards,
>
>
>
> Flip
>
>
>
> Flip Petillion
>
> fpetillion at petillion.law
>
> +32484652653
>
> www.petillion.law
>
>
>
> <image001.png> <http://www.petillion.law/>
>
>
>
>   Attorneys – Advocaten - Avocats
>
>
>
>
>
>
>
>
>
> *From: *Rubens Kuhl <rubensk at nic.br>
> *Date: *Tuesday, 30 July 2019 at 13:22
> *To: *Flip Petillion <fpetillion at petillion.law>
> *Cc: *Ayden Férdeline <icann at ferdeline.com>, "council at gnso.icann.org" <
> council at gnso.icann.org>
> *Subject: *Re: [council] Draft GNSO Council Letter to ICANN Board on EPDP
> Phase 1 Recommendations
>
>
>
>
>
> Flip,
>
>
>
> I find strange we are having a substantive discussion on the topic within
> the Council. I believe our approach to board denials of PDP recommendation
> should be to ask the PDP WG what clarifications or positions they have, and
> relay them to the board. IPC is represented in the PDP so the same content
> you posted here could be used there while formulating the response,
> whatever that response would look like.
>
>
>
> And still on process grounds, it's clear that the board rationale for not
> approving part of Rec. 12 is different from the IPC rationale you relayed
> to the Council. But the rationale that needs to be answered to is the Board
> one, because they've made the decision to not fully approve rec. 12. So
> while it's interesting to know the overall IPC position on the matter, the
> topic at hand is the Board decision.
>
>
>
>
>
> Rubens
>
>
>
>
>
>
>
>
> On 30 Jul 2019, at 06:54, Flip Petillion <fpetillion at petillion.law> wrote:
>
>
>
> Hi Ayden,
>
>
>
> Thank you for your questions and for the opportunity to clarify our
> position. I understand your questions address the substance of the
> recommendations and not the GNSO Council’s remit within the Board Approval
> Process.
>
>
>
>    1. Regarding your first question:
>
>
>
> You are correct that the ‘Organisation’ field pertains to information of
> legal entities and thus should not be subject to GDPR principles (and thus
> should not be deleted or even redacted). However, this is not treated as
> such in the Final Report. To avoid that we enter into circular discussions,
> we started from the premise in the Final Report (and the draft rationale
> for rec. #12) that the GDPR could apply to the ‘Organisation’ field. Our
> point is that, in such a case, the practices of both disclosing AND
> deleting data are subject to GDPR according to article 4 (2). ,The deletion
> of previously provided data can likewise not occur without a solid purpose,
> legal basis and safeguards.
>
>
>
>    1. Regarding your second question:
>
>
>
> (i) You are correct that the GDPR requires consent to be informed,
> affirmative and freely given. However, active opt-in consent is only
> required when relying on consent as a legal basis (art. 6.1.a). The Final
> Report and the guidance of the EU Authorities and DPAs have established
> that, depending on the purpose, the performance of the registration
> contract (art. 6.1.b) and legitimate interest (art. 6.1.f) are the valid
> legal bases. For the latter, an opt-out mechanism or redaction mechanism
> can be sufficient to shift the balance in favour of the interested party
> (cfr. Article 29 WP Guidance on Legitimate Interest) and active opt-in
> consent is not required.
>
>
>
> (ii) If you were to rely on consent as a legal basis, normally (and
> ideally) consent is obtained at the time of collection of the personal data
> (i.e. the registration of the domain name). It is at this point in time
> that the data subject (registrant) is properly informed of the processing
> activities and is engaged in providing the necessary information related to
> the purpose and legal bases (i.e., performance of the registration
> agreement). Practice has shown that there are a lot of problems with
> obtaining consent after the fact (i.e., during the performance of the
> registration agreement). Quite often data subjects cannot be contacted, are
> confused about the nature of the opt-in communication, are simply not
> interested, etc. Accordingly, the requirement of an active opt-in consent
> on the basis of a ‘review request’ to existing registrants unnecessarily
> risks losing valid organisation information on a wide scale.
>
>
>
> I hope this sufficiently answers your questions and clarifies the position
> of the IPC on this matter.
>
>
>
> Best regards,
>
>
>
> Flip
>
>
>
>
>
> Flip Petillion
>
> fpetillion at petillion.law
>
> +32484652653
>
> www.petillion.law
>
>
>
> <image001.png> <http://www.petillion.law/>
>
>
>
>   Attorneys – Advocaten - Avocats
>
>
>
>
>
>
>
>
>
> *From: *Ayden Férdeline <icann at ferdeline.com>
> *Reply to: *Ayden Férdeline <icann at ferdeline.com>
> *Date: *Tuesday, 30 July 2019 at 00:41
> *To: *Flip Petillion <fpetillion at petillion.law>
> *Cc: *Maxim Alzoba <m.alzoba at gmail.com>, Darcy Southwell <
> darcy.southwell at endurance.com>, "gnso-secs at icann.org" <gnso-secs at icann.org>,
> "council at gnso.icann.org" <council at gnso.icann.org>
> *Subject: *Re: [council] Draft GNSO Council Letter to ICANN Board on EPDP
> Phase 1 Recommendations
>
>
>
> Hi Flip,
>
>
>
> Thanks for sharing this input from the IPC.
>
>
>
> Sorry if this is a stupid question, but since data that does not pertain
> to natural persons is beyond the scope of the GDPR, I do not understand how
> you can make the claim that article 4 (2) of the GDPR does not allow for
> the organisation field to be deleted. Could you please clarify? Thanks.
>
>
>
> I am also concerned that what you describe below - "Practice has shown
> that data subjects are generally reluctant to take active steps after their
> data has been collected to provide active opt-in consent (cfr. opt-in
> emails)" - sounds like a proposal for not obtaining consent that is valid
> under the GDPR, which I understand requires consent to be freely given.
>
>
>
> Kind regards,
>
>
>
> Ayden
>
>
>
>
>
> ‐‐‐‐‐‐‐ Original Message ‐‐‐‐‐‐‐
>
> On Monday, 29 July 2019 18:29, Flip Petillion <fpetillion at petillion.law>
> wrote:
>
>
>
> Dear Keith,
>
> Dear All,
>
>
>
> The IPC *shares the Board’s concern* that the option to *delete* the
> Organisation fields contents as a result of a refusal or failure to respond
> by the registrant upon a ‘review request’ by the registrar, *risks
> resulting in a* *wide scale loss* of crucial information about the
> registrant's identity.
>
>
>
> While the IPC acknowledges that Recommendation #12 achieved consensus
> support in the EPDP Team’s Phase 1 Final Report, we agree with the Board
> that the “or delete the field contents” part of recommendation #12 2) b) is
> not in the best interests of the ICANN community or ICANN.
>
>
>
> We therefore do not agree that the recommendation should be resubmitted as
> is, and also not together with the presented rationale in the draft letter
> to the Board.
>
>
>
> Irrespective of the debate as to whether the organisation
> field may contain personal data or not, the issues considered in
> the current rationale and the concerns of the Board can both be met by
> redacting the organisation data in case of an opt-out (or lack of active
> opt-in) instead of deleting.
>
> · The concept of ‘privacy by default/design’ in the GDPR does not
> automatically necessitate the implementation of an opt-in mechanism
> (especially considering the legitimate interests attached to the
> transparency of organisation information online);
>
> · The deletion/erasure by a controller of previously provided
> personal data is also considered ‘processing’ (article 4 (2) GDPR), for
> which the controller must determine a purpose and proper legal basis. As a
> result, a registrar cannot simply delete important information provided by
> the registrant unless (i) the registrant has requested the erasure of the
> ‘Organisation’ field by exercising his right to erasure (this right must be
> actively exercised and cannot be inferred), (ii) the retention of the
> ‘Organisation’ field is no longer necessary for the purposes of processing
> the domain name registration data (Recommendation #15 implies that the
> retention period of the data elements would at the minimum be the ‘life of
> the registration’), or (iii) the registrar can justify the deletion on the
> basis of another valid legal basis (such as the consent of the
> registrant).
>
>
>
> Practice has shown that data subjects are generally reluctant to take
> active steps after their data has been collected to provide active opt-in
> consent (cfr. opt-in emails). Together with the expected difficulties in
> contacting the registrants and verifying their (lack of) consent on a wide
> scale, the IPC believes (in accordance with the Board Statement) that this
> would pose a serious and unnecessary risk to lose important registrant
> information.
>
>
>
> Procedurally, we fail to see the use of the checks and balances
> incorporated in the ‘Board Approval Process’ of Annex A-1 Section 6 of the
> Bylaws if it would be outside the GNSO Council’s remit to allow a
> modification to the Consensus Policy recommendation delivered by the EPDP
> Team. Section 6 of Annex A-1 of the Bylaws specifically provides:
>
> *“At the conclusion of the Council and Board discussions, the Council
> shall meet to affirm or modify its recommendation, and communicate that
> conclusion (the "Supplemental Recommendation") to the Board, including an
> explanation for the then-current recommendation.”*
>
>
>
> The IPC therefore believes it is in the GNSO Council’s remit to consult
> with the Board and modify a Consensus Policy Recommendation if such
> modification alleviates concerns raised in the Board Statement and is in
> the best interest of the ICANN community and ICANN.
>
>
>
> In accordance with the concern raised in the Board Statement, the IPC
> therefore believes that the “or delete the field contents” part (deletion
> option) of Recommendation #12 2) b) should be deleted.
>
>
>
> Best regards,
>
>
>
> Flip
>
>
>
> Flip Petillion
>
> fpetillion at petillion.law
>
> +32484652653
>
> www.petillion.law
>
>
>
> <image002.png> <http://www.petillion.law/>
>
>
>
>   Attorneys – Advocaten - Avocats
>
>
>
>
>
>
>
>
>
> *From: *Flip Petillion <fpetillion at petillion.law>
> *Date: *Monday, 29 July 2019 at 21:41
> *To: *Maxim Alzoba <m.alzoba at gmail.com>, Darcy Southwell <
> darcy.southwell at endurance.com>
> *Cc: *"gnso-secs at icann.org" <gnso-secs at icann.org>, "council at gnso.icann.org"
> <council at gnso.icann.org>
> *Subject: *Re: [council] Draft GNSO Council Letter to ICANN Board on EPDP
> Phase 1 Recommendations
>
>
>
> Dear Keith,
>
> Dear All,
>
>
>
> Due to the vacation period, we will be able to send in the IPC comments
> later today or tomorrow morning my time.
>
> Sorry for the inconvenience.
>
>
>
> Best regards,
>
>
>
> Flip
>
>
>
>
>
> Flip Petillion
>
> fpetillion at petillion.law
>
> +32484652653
>
> www.petillion.law
>
>
>
> <image003.png> <http://www.petillion.law/>
>
>
>
>   Attorneys – Advocaten - Avocats
>
>
>
>
>
>
>
>
>
> *From: *council <council-bounces at gnso.icann.org> on behalf of Maxim
> Alzoba <m.alzoba at gmail.com>
> *Date: *Thursday, 25 July 2019 at 18:53
> *To: *Darcy Southwell <darcy.southwell at endurance.com>
> *Cc: *"gnso-secs at icann.org" <gnso-secs at icann.org>, "council at gnso.icann.org"
> <council at gnso.icann.org>
> *Subject: *Re: [council] Draft GNSO Council Letter to ICANN Board on EPDP
> Phase 1 Recommendations
>
>
>
>  We support the current draft of the letter and comments of Darcy.
>
>
>
> Also I'd like to underline , that the modification of the recommendations
> is for GNSO Council, not for the Board
>
>  ,and that doing micro management of PDPs is not in the GNSO Council's
> role.
>
>
>
>
>
> Maxim Alzoba
>
>
>
> On Wed, Jul 24, 2019, 22:44 Darcy Southwell <darcy.southwell at endurance.com>
> wrote:
>
> Thanks you, Keith.
>
>
>
> The Registrar Stakeholder Group (RrSG) agrees that it's outside the
> Council's remit to modify, or even suggest modification of, a consensus
> recommendation from a PDP working group and therefore objects to modifying
> Recommendation 12 to remove the deletion option.  The Council should seek
> to formalize the rationale provided to the Board in Marrakech and resubmit
> the consensus recommendation to the Board for approval.  Therefore, RrSG
> supports the Council's letter to the Board as written regarding
> Recommendation 12.
>
>
>
> Regarding Recommendation 1, Purpose 2, the EPDP Team and Board have been
> quite clear that further legal analysis is necessary to ensure Purpose 2 is
> drafted consistent with applicable laws.  In its Final Report, the EPDP
> Team recommended Purpose 2 be further evaluated during phase 2 of the
> EPDP.  In its resolution, the Board clearly instructed ICANN Org to engage
> the DPAs to accomplish the necessary legal analysis to perform the work.
> That legal analysis must be completed before the EPDP Team can even begin
> to consider how to revise Purpose 2.  Further, it is not typical for the
> Council to instruct a PDP as to when it works on such specific tasks.  It
> is up to the PDP Working Group, with its leadership and coordinating with
> ICANN staff, to prioritize its work.  So far, the EPDP Team has prioritized
> the work related to the System for Standardized Access to Non-Public
> Registration Data, consistent with its Charter, and with the concerns of
> many of the GNSO Councilors.  At this point, the RrSG sees no reason for
> the Council to intervene to reprioritize the Purpose 2 work ahead of the
> chartered work.
>
>
>
> Best,
>
> Darcy
>
>
>
> On Fri, Jul 19, 2019 at 12:30 AM Drazek, Keith via council <
> council at gnso.icann.org> wrote:
>
> Hi Marie,
>
>
>
> Thanks for your initial feedback here, and for the discussion during
> yesterday’s Council call.
>
>
>
> On your second point below, related to the Board’s treatment of
> Recommendation 12, I believe it is outside the Council’s remit to suggest,
> or even allow, a modification to the Consensus Policy recommendation
> delivered to us by the EPDP Team, and subsequently delivered by Council to
> the Board. In my view, it is the role of Council to now hold the Board
> accountable for its decision to not accept Rec 12 in full, and to call for
> the Board to accept it following the clarification they requested.
>
>
>
> I welcome further discussion on these items following discussion with our
> respective SGs and Cs, but that’s my current view.
>
>
>
> Best,
>
> Keith
>
>
>
> *From:* Marie Pattullo <marie.pattullo at aim.be>
>
> *Sent:* Thursday, July 18, 2019 10:53 PM
>
> *To:* Drazek, Keith <kdrazek at verisign.com>
>
> *Cc:* gnso-secs at icann.org; council at gnso.icann.org
>
> *Subject:* [EXTERNAL] RE: Draft GNSO Council Letter to ICANN Board on
> EPDP Phase 1 Recommendations
>
>
>
> Hi Keith,
>
>
>
> Thanks for sharing the draft. I’m afraid I haven’t been able to discuss
> this much with our members yet (sorry) but on an initial reading, the BC
> does have some concerns.
>
>
>
> On your first point, on rec 1, while the first sentence is great, we have
> problems with the second. As you know from the comments we attached to
> Janis’ letter, we really need to give the EPDP Team a clear instruction to
> reword this and replace the placeholder language; I understand that it’s
> not on the Team’s roadmap right now. We really think that at a minimum,
> Council needs to tell the Team to do that and get it back ASAP for Board
> action. We all agree that the EPDP should deal with this, so we really do
> need a purpose 2 (for 3rd party access) for the Board to adopt.
>
>
>
> As for your 2nd para, on rec 12, we don’t agree that it should just be
> resubmitted as is. As you know, the BC really does think that as far as the
> ORG field goes, Rec 12 should be amended to remove the deletion option.
> There could always be an option of to allow the contracted parties to
> update any inaccuracies in the ORG field, as appropriate, if they need that.
>
>
>
> Looking forward to the discussion!
>
>
>
> Thanks
>
>
>
> Marie
>
>
>
>
>
> *From:* council <council-bounces at gnso.icann.org> *On Behalf Of *Drazek,
> Keith via council
>
> *Sent:* Wednesday, July 17, 2019 11:49 AM
>
> *To:* council at gnso.icann.org
>
> *Cc:* gnso-secs at icann.org
>
> *Subject:* [council] Draft GNSO Council Letter to ICANN Board on EPDP
> Phase 1 Recommendations
>
>
>
> Hi all,
>
>
>
> In preparation for our Council meeting this week, please review the
> attached draft letter to the ICANN Board concerning next steps on the two
> EPDP Phase 1 recommendations not accepted in full by the Board.
>
>
>
> As you will recall, we had a good conversation with the ICANN Board during
> our working session lunch, and we committed to following up on the issue.
> The draft letter is self-explanatory, and our goal is to ensure a common
> understanding between Council and Board before we take our formal action to
> request Board reconsideration on Recommendation 12. We want to avoid an
> ongoing back-and-forth on the issue, so our hope is this letter will pave
> the way to a clear resolution.
>
>
>
> Please review before our Council meeting.
>
>
>
> Thanks to Rafik and Pam for leading this work while I was on PTO.
>
>
>
> Best,
>
> Keith
>
> _______________________________________________
>
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>
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