[council] Accuracy scoping team - proposed next steps

Fri May 7 17:10:26 UTC 2021

Dear all,

Many thanks for this and for your input, Jeff and Kurt. The perspective of the BC:

  *   We are keen for this work to be productive on a practical level (how to promote/ensure accurate data) and to start as soon as possible.
  *   We should not confuse the establishment of a scoping team with the charter for a PDP: the whole point is that a cross-community group of experts should come together to look at what we have, what (if any) other resources/studies are needed and propose the way forward. There is no need to impose rigid charter-like questions; the experts may have other experience-based views that we have not considered.
  *   We have a different understanding as to the proposed study, further to both the draft text and our Extraordinary meeting: whether we need such a study, and what it should address, should be defined by the scoping team. That team would start by considering all of the resources we already have about accuracy, both to come to agreement on what our next steps should be and to avoid duplication, and after that they can decide if there are gaps or questions that such a study could address.
  *   While we agree that RDS data accuracy's definition would be one of the most important aspects of the scoping group's work, we caution against this work being limited to definition. Once defined we also need to do something about it: "we have measured the data and x% is inaccurate" is not the end goal.
  *   We don't think that we need to have more lengthy discussions at Council level. The issue of accuracy has been bubbling for years, as the GAC rightly says way before the GDPR. It was to be addressed in Phase 1 of the EPDP but has been repeatedly pushed back and if we do not address it, legislation will do so for us, creating yet more jurisdictional fragmentation. We reiterate that the scoping team should be formed and be allowed to start its work as soon as possible - they are the experts and the whole idea is to ask experts where we are and how we move forward, and yet another Council-level discussion will, in our view, only lead to unnecessary delay.

Kind regards,
Marie

From: council <council-bounces at gnso.icann.org<mailto:council-bounces at gnso.icann.org>> On Behalf Of Kurt Pritz via council
Sent: Friday, 7 May 2021 04:45
To: philippe.fouquart <philippe.fouquart at orange.com<mailto:philippe.fouquart at orange.com>>
Cc: gnso-SECS <gnso-secs at icann.org<mailto:gnso-secs at icann.org>>; GNSO Council List <council at gnso.icann.org<mailto:council at gnso.icann.org>>
Subject: Re: [council] Accuracy scoping team - proposed next steps

Hi Philippe:

Thank you for providing the draft set of proposed next steps for dealing with the topic of registration data accuracy. We (RYSG Council representatives) have read the proposal and associated documentation and consulted with our stakeholder group members and leadership.

First, we wish you to confirm that the Proposed Path Forward is intended to be the "framework" described and recommended in the recent ICANN briefing (i.e., "develop a framework for a study on how to measure accuracy"). After reading the documents furnished, that was the conclusion to which we came.

Keeping with the ICANN briefing recommendation to "commission a study on how accuracy of registration data might be measured," we believe the Proposed Path Forward is too vague to be released as is. I.e., the proposal provides inadequate direction to the working group (which is likely to cause confusion and be perceived as disrespectful of volunteers' time). Put another way, the proposal initiates the study but does not describe the scope of the work to be done.

For example, the proposal calls for the scoping team to focus on, "identifying what problems, if any, are expected to be addressed and how," but nowhere describes to what the problems should pertain other than "accuracy," with no other detail or direction.

Instead, the objective and terms of reference should be clearly delineated. Recognizing our commitment to fact-based policy development, the proposal should make clear that we are seeking to formulate an approach to data registration accuracy measurement first - and that any policy discussion will follow (because policy should be informed by data and facts derived from competently done studies). The "problems" identified should be those specifically related to how accuracy of registration data might be measured.

In addition, we think it necessary to expressly include registration data accuracy definitions in the scoping team's remit. How can one design an approach to registration data accuracy measurement without defining that which is to be measured?

The proposal refers extensively to GDPR and NIS2. Most of these could be omitted. The proposal seeks to assess how best to measure accuracy, which we think is an objective matter, and not seek to interpret and implement statutory requirements, which is a policy discussion that should occur when the factual assessments are complete. (We do note the proposal's brief inference that the GDPR Accuracy Principle is essentially satisfied by the current actions of the contracted parties.)

Regarding timing, the call for volunteers should be published after the close of work on the EPDP for Registration Data. This scoping effort will require the expertise of EPDP participants because it is likely that one of the problems to be addressed is how or whether personal data can be processed to accomplish a registration data accuracy assessment. In addition, the topic of registration data accuracy continues to be raised in the EPDP discussions and that should be exhausted before going on to a subsequent effort on the same topic.

We also believe the composition or casting of the working group should be more carefully considered. The specification of "two from each" stakeholder group seems arbitrary and merits additional discussion.

To correct these concerns, we propose to have a substantive discussion at the Council level, and then create a small team of Council members (or form a "working-group-of-the-whole") to redraft the proposed framework, an effort we will gladly support.

Sincerely,

Maxim Alzoba
Sebastien Ducos
Kurt Pritz

On Apr 23, 2021, at 2:43 PM, philippe.fouquart--- via council <council at gnso.icann.org<mailto:council at gnso.icann.org>> wrote:

Dear Councillors,

Following our extraordinary meeting on 8 April 2021, Council leadership, with the support of the GNSO Support Staff, has worked together to develop a set of proposed next steps for dealing with the topic of accuracy. The proposed next steps aim to find a balance between the different viewpoints that have been expressed on this topic while at the same time recognizing our commitment to fact-based policy development. The Council leadership's expectation is that by focusing on identifying and confirming the problem(s) (if any), the scoping team will be in a much better position to recommend to the Council what next steps to take.

We would like to request that you review the attached document with your respective groups and indicate by Friday 7 May at the latest if you have any significant concerns or objections about the proposed next steps.

If no concerns or objections are raised, Council leadership will include formal confirmation of these next steps on the consent agenda for the Council meeting on 20 May 2021.

We would also like to request Jeffrey, as the Council liaison to the GAC, to share this message with his GAC point of contact for the GAC's information, making clear that this document is still subject to change, as the GAC has expressed interest in this topic in its recent engagements with the GNSO Council.
Regards,
Pam, Tanya & Philippe

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