[CPWG] [GTLD-WG] [registration-issues-wg] ALAC Statement regarding EPDP

Thu Aug 2 14:37:51 UTC 2018

Jonathan / Alan

Thanks for the clarifications.

3 - I don't know how you can know what the interests of a user are. The assumption you seem to be making is that due process and privacy should take a backseat to access to data
4 - Same as 3. Plenty of ccTLDs never offered PII in their public whois and there weren't any issues with security or stability.

Skipping due process for "ease of access" is a very slippery and dangerous slope.

Regards

Michele

--
Mr Michele Neylon
Blacknight Solutions
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On 02/08/2018, 15:03, "Jonathan Zuck" <JZuck at innovatorsnetwork.org> wrote:

    Thanks Michele!
    3. Where there appears to be a conflict of interest between a registrant and non-registrant end user, we'll be endeavoring to represent the interests of the non-registrant end user.
    4. Related to 3. This is simply an affirmation of the interests of end users in a stable and secure internet and it is those interests we'll be representing. We've included law enforcement because efficiencies regarding their access may come up. Just because there's always a way for them to get to data doesn't mean it's the best way.

    Make sense?
    Jonathan

    -----Original Message-----
    From: GTLD-WG <gtld-wg-bounces at atlarge-lists.icann.org> On Behalf Of Michele Neylon - Blacknight
    Sent: Wednesday, August 1, 2018 12:34 PM
    To: Alan Greenberg <alan.greenberg at mcgill.ca>; CPWG <cpwg at icann.org>
    Subject: Re: [GTLD-WG] [CPWG] [registration-issues-wg] ALAC Statement regarding EPDP

    Alan

    1 - good
    2 - good
    3 - I don't understand what that means
    4 - Why are you combining law enforcement and private parties? Law enforcement can always get access to data when they follow due process. 

    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

    On 01/08/2018, 17:27, "registration-issues-wg on behalf of Alan Greenberg" <registration-issues-wg-bounces at atlarge-lists.icann.org on behalf of alan.greenberg at mcgill.ca> wrote:

        Yesterday, the EPDP Members were asked to present a 1-3 minute 
        summary of their groups position in regard to the EPDP. The following 
        is the statement agreed to by me, Hadia, Holly and Seun.

        1.   The ALAC believes that the EPDP MUST succeed and will be working 
        toward that end.

        2.   We have a support structure that we are organizing to ensure 
        that what we present here is understood by our community and has 
        their input and support.

        3.   The ALAC believes that individual registrants are users and we 
        have regularly worked on their behalf (as in the PDP that we 
        initiated to protect registrant rights when their domains expire), if 
        registrant needs differ from those of the 4 billion Internet users 
        who are not registrants, those latter needs take precedence. We 
        believe that GDPR and this EPDP are such a situation.

        4.   Although some Internet users consult WHOIS and will not be able 
        to do so in some cases going forward, our main concern is access for 
        those third parties who work to ensure that the Internet is a safe 
        and secure place for users and that means that law enforcement, 
        cybersecurity researchers, those combatting fraud in domain names, 
        and others who help protect users from phishing, malware, spam, 
        fraud, DDoS attacks and such can work with minimal reduction in 
        access to WHOIS data. All within the constraints of GDPR of course.

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