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

Maureen Hilyard maureen.hilyard at gmail.com
Tue Aug 7 20:51:49 UTC 2018


+1

On Tue, Aug 7, 2018 at 10:24 AM, Marita Moll <mmoll at ca.inter.net> wrote:

> This is great Greg. Thanks for filling in some of the details.
>
> Marita
>
> On 8/7/2018 10:17 PM, Greg Shatan wrote:
>
> I’ve been watching this conversation unfold for awhile. A few observations:
>
> 1. Nobody suggested that ALAC support an outcome that would violate GDPR.
> Compliance with GDPR is a given. Thankfully, that misunderstanding seems to
> have been cleared up.
>
> 2. No one is arguing in favor of putting the “private info of registrants”
> into “the hands of bad actors.” Indeed, GDPR is not primarily aimed at
> preventing access by bad actors. Rather it is aimed at regulating the use
> of personal data by any actor. I haven’t really thought about it, but GDPR
> is probably not going to be a major deterrent against real bad actors.
>
> 3. WHOIS/RDS exists in order to be accessed by third parties (i.e., folks
> other than the registrant and the registrar). There are many, many
> legitimate use cases for access. Of course, there are “mis-use cases”
> involving bad actors, and one of the obvious challenges for the EPDP is
> dealing with those. From the point of view of the end-user, that needs to
> be dealt with in a way that does not hinder timely, straight-forward
> legitimate access to Whois data.
>
> 4. I have seen no evidence that the European Data Protection people have
> thought about how WHOIS/RDS can function under GDPR. More broadly, GDPR is
> a law about access, in very large part. GDPR provides a road map for data
> controllers and processors to get and “process” (use, store, provide access
> to, transfer, delete, etc.) data. Much of GDPR is concerned with how data
> is used (I’d rather use that term than “processed” for these discussions),
> the purposes for which it is used, how it is stored, how it is transferred,
> who is responsible for any use, the circumstances when a data subject does
> (and does not) have control over how their data is used. GDPR assumes that
> data will be “processed” and creates a set of rules of the road for that
> processing.
>
> 5. It is true that end-users and registrants benefit from both privacy and
> security. End-users benefit directly and indirectly from access to
> WHOIS/RDS data, for non-security related reasons as well as
> security-related reasons. Registrants also benefit from access to
> WHOIS/RDS, both by themselves and by third parties in a variety of ways.
> Registrants benefit from data privacy, at least with regard to their own
> data (though they may lose some of the benefits that come from third party
> access to their data, such as receiving offers to purchase domain names).
> However, I struggling to see how end-users (as end-users) benefit from
> barriers to accessing registrant WHOIS/RDS data.
>
> 6. How Cambridge Analytica got Facebook data is not particularly relevant.
> But if it is going to be used as a “cautionary tale”, we need to be
> accurate, so that the right lessons can be learned. Cambridge Analytica did
> NOT get the data by making a request to Facebook “to have access to these
> data for research.” In fact, they didn’t get the data directly from
> Facebook at all. The data was gathered through a personality quiz app,
> which was (as Facebook was configured at that time and with the consent of
> the participants) able to harvest data about friends and friends-of-friends
> of the participants, as well as the participants. It may have been used for
> legitimate research purposes. However, the data was then sold to Cambridge
> Analytica, without Facebook’s knowledge and in violation of their terms of
> service.
>
> 7. The California Consumer Privacy Act is already here, though it won’t be
> enforced until 2020. While it bears a resemblance to GDPR, it has many
> differences as well, and some of its goals are quite different. Like GDPR
> it is not primarily aimed at keeping data out of the hands of bad actors. I
> have not yet considered the impact of the CCPA on WHOIS/RDS, and how it is
> similar or different to the impact of GDPR. Its primary goals seem to be to
> control data monetization, and to give consumers greater access to their
> data, with data subject rights similar to those in GDPR.
>
> 8. Overall, I agree with those who believe that appropriate and timely
> access to WHOIS/RDS data benefits end-users. Whether GDPR is good or bad
> for end-users is moot. GDPR exists, and how it is dealt with will show how
> good or bad it is for end-users. Our goal should be to have GDPR
> implemented in the WHOIS/RDS context in a way that maximizes the benefit
> and minimizes the harm to end-users.
>
> Best regards,
>
> Greg Shatan
>
> On Tue, Aug 7, 2018 at 1:58 PM Evan Leibovitch <evanleibovitch at gmail.com>
> wrote:
>
>> I don't know about the Europeans or the California government. I do have
>> more than a decade's experience in ICANN, however, and have observed that
>> its track record in both decent privacy and decent accessibility is
>> abysmal.
>>
>> ___________________
>> Evan Leibovitch, Toronto
>> @evanleibovitch/@el56
>>
>> On Tue, Aug 7, 2018, 1:30 PM Marita Moll, <mmoll at ca.inter.net> wrote:
>>
>> > With respect Evan, saying I am missing the point is not really
>> > respectful.  No one is arguing for privacy without protections. I don't
>> > have all the information I need to support this, but I have a feeling
>> > the European Data Protection people might have thought about this. They
>> > don't want to protect bad actors either. And I have heard that a
>> > similiar law to GDPR is under consideration in California. So I don't
>> > see any need to think we are only ones concerned with keeping bad actors
>> > out of the ring.
>> >
>> > Marita
>> >
>> >
>> > On 8/7/2018 7:08 PM, Evan Leibovitch wrote:
>> > > Hi Marita,
>> > >
>> > > I think you may be missing the point when you state that "keeping the
>> > > private info of registrants out of the hands of bad actors protects
>> > > both parties". The examples that exist in abundance come from
>> > > registrants who /ARE themselves/ the bad actors, that hide behind
>> > > either privacy regulations or inaccurate contact information to avoid
>> > > being held to account for their harm.
>> > >
>> > > Just as the right to freedom of speech is not absolute -- even in
>> > > America -- neither is the right to privacy a way to hide
>> > > accountability for causing demonstrable harm. Augmenting privacy with
>> > > tiered access is fine so long as it is accessible to victims and
>> > > effective in execution; that is exactly the balance of which I speak.
>> > > This won't be easy -- being physically threatened demands a different
>> > > response to merely being insulted -- but it is vital. Without such
>> > > checks and balances, absolute privacy is a sure source of far more
>> > > harm than good. For every whistleblower protected, a dozen others will
>> > > be scammed out of their life savings, and thousands more will live in
>> > > fear for their lives because of death threats from those with
>> > > unchecked anonymity. This is not theory, it is happening.
>> > >
>> > > In summary, it is both naive and against the global public interest to
>> > > advocate for privacy without advocating just as strenuously for
>> > > appropriate protections against bad actors who seek to exploit that
>> > > privacy to cause harm. At-Large seeks both.
>> > >
>> > > - Evan
>> > >
>> > >
>> > > PS: I absolutely reject the assertion that it is fear-mongering to
>> > > simply want to prevent abuse of privacy by some registrants that is
>> > > both clearly evidenced and ongoing.
>> > >
>> > >
>> > > On Aug 7, 2018, at 11:55, Marita Moll <mmoll at ca.inter.net
>> > > <mailto:mmoll at ca.inter.net>> wrote:
>> > >
>> > >     Hello Evan and Allan. I agree with a number of those here how have
>> > >     suggested that the interests of registrants and end-users are not
>> > that
>> > >     different. Keeping the private info of registrants out of the
>> hands
>> > of
>> > >     bad actors protects both parties. If crimes are committed, having
>> > tiered
>> > >     access to the info would release that info to validated
>> authorities.
>> > As
>> > >     a registrant, I don't want my private information out there if it
>> > isn't
>> > >     necessary. And I don't see how shielding my private info on WhoIS
>> > will
>> > >     endanger my neighbour once tiered access is agreed upon. This is
>> no
>> > >     different from the way the law usually works -- we don't all have
>> to
>> > >     live in glass houses in order to be safe. We need well thought out
>> > >     procedures that protect all of us.
>> > >
>> > >     It's just my opinion. I know others have good arguments. But I
>> don't
>> > buy
>> > >     the scary scenarios being presented by some groups hoping to
>> scuttle
>> > >     this whole thing. If the Europeans don't think the world will come
>> > to an
>> > >     end once GDPR is enforced, why is the boogey man being unleashed
>> in
>> > >     North America?
>> > >
>> > >     http://www.insidesources.com/fake-news-fake-pharmacies-
>> whats-next/
>> > >
>> > >     Marita
>> > >
>> > >
>> > >     On 8/7/2018 5:09 AM, Alan Greenberg wrote:
>> > >
>> > >         Marita, you cannot take one phrase out of context. If you go
>> > >         back in the thread (which was not fully copied here) I believe
>> > >         that a major concern of Holly and Bastiaan was that my
>> > >         statement sounded like it was trying to get around GDPR, but
>> > >         in fact compliance with GDPR is (to use a Startrek expression)
>> > >         "the prime directive". It is not a simple matter of security
>> > >         vs privacy. If, for instance, we were talking about USER
>> > >         security vs USER privacy, we would have a real challenge in
>> > >         deciding which was more important and I am pretty sure we
>> > >         would not even try in the general case. But that is not what
>> > >         we are taking about here. We are talking about gTLD REGISTRANT
>> > >         privacy vs USER security. And the ALAC's position has
>> > >         previously been that although we care about registrants (and
>> > >         their privacy and their domains etc) and have put very
>> > >         significant resources into supporting gTLD registrants, the
>> > >         shear number of users makes their security and ability to use
>> > >         the Internet with relative safety and trust takes precedence
>> > >         over the privacy of the relative handful of gTLD registrants.
>> > >         That is why ICANN has (and continues to) support the existing
>> > >         WHOIS system to the extent possible. That is the entire gist
>> > >         of the Temporary Spec. - /"Consistent with ICANN’s stated
>> > >         objective to comply with the GDPR, while maintaining the
>> > >         existing WHOIS system to the greatest extent possible, the
>> > >         Temporary Specification maintains....." /And I note with some
>> > >         amusement that some filter along the way has flagged this
>> > >         entire thread as SPAM. Alan At 06/08/2018 12:08 PM, Marita
>> > >         Moll wrote:
>> > >
>> > >             I am in agreement with Tijani, Holly, Bastian and Michele.
>> > >             Perhaps it is unintentional, but the language does send
>> > >             the message that we are looking more carefully at security
>> > >             than privacy. I am also not convinced that end-users would
>> > >             want us to do that. Marita On 8/3/2018 10:30 AM, Tijani
>> > >             BEN JEMAA wrote:
>> > >
>> > >                 Very interesting discussion. This issue has been
>> > >                 discussed several times and the positions didn’t
>> > >                 change. What bothers me is the presentation of the
>> > >                 registrants interest as opposite to the remaining
>> > >                 users ones. they are not since the registrants are
>> > >                 also subject to the domain abuse. You are speaking
>> > >                 about 4 billion users; these include all: contracted
>> > >                 parties, business, registrants, governments, etc. We
>> > >                 are about defending the interest of all of them as
>> > >                 individual end users, not as registry, registrar,
>> > >                 businessman, minister, etc…. You included theÂ
>> > >                 cybersecurity researchers; you know how Cambridge
>> > >                 Analytica got the American data from Facebook? They
>> > >                 requested to have access to these data for research,
>> > >                 and the result was the American election result
>> > >                 impacted. So, I agree with Bastiaan that we need to be
>> > >                 careful and care about the protection of personal data
>> > >                 as well as the prevention of any harmful use of the
>> > >                 domain names, both together.
>> > >
>> >  ------------------------------------------------------------
>> ------------
>> > >                 *Tijani BEN JEMAA* Executive Director Mediterranean
>> > >                 Federation of Internet Associations (*FMAI*) Phone:
>> > >                 +216 98 330 114 +216 52 385 114
>> > >
>> >  ------------------------------------------------------------
>> ------------
>> > >
>> > >                     Le 3 août 2018 à 07:22, Bastiaan Goslings
>> > >                     <bastiaan.goslings at ams-ix.net
>> > >                     <mailto:bastiaan.goslings at ams-ix.net
>> > >                     <mailto:bastiaan.goslings at ams-ix.net>>> a écrit
>> :
>> > >                     Thanks for clarifying, Alan. As a matter of
>> > >                     principle I agree with Holly - and Michele. While
>> > >                     I think I understand the good intent of what you
>> > >                     are saying, your earlier responses almost sound to
>> > >                     me like a false ‘security versus privacy’
>> > >                     dichotomy. Like, the number of people (users) that
>> > >                     care about security as opposed to those
>> > >                     (registrants) that want their privacy protected to
>> > >                     the max is larger. Etc. Apologies if I am
>> > >                     oversimplifying things here, I do not mean to. In
>> > >                     this particular EPDP case though I am convinced
>> > >                     that we can find a common ground on what the ALAC
>> > >                     members and alternates should bring to the table.
>> > >                     In terms of perceived registrants’ and general
>> > >                     Internet end-users’ interests. As you rightly
>> > >                     state, it is about being GDPR compliant. So we do
>> > >                     not have to be philosophical about a rather broad
>> > >                     term like ‘privacy’ and argue about whether it
>> > >                     is in conflict with e.g. the interest of LEAs.
>> > >                     Indeed, ‘Privacy is not absolute’. However,
>> > >                     ‘due process’ is a(nother) no brainer, not
>> > >                     just because it might be a legal requirement. From
>> > >                     what I understand the work being done on defining
>> > >                     Access and Accreditation criteria is keeping that
>> > >                     principle in mind, and within in the MS context of
>> > >                     the EPDP we can together see to it that it does
>> > >                     end up properly enshrined in policy and contracts.
>> > >                     -Bastiaan
>> > >
>> > >                         On 3 Aug 2018, at 01:10, Alan Greenberg
>> > >                         <alan.greenberg at mcgill.ca
>> > >                         <mailto:alan.greenberg at mcgill.ca
>> > >                         <mailto:alan.greenberg at mcgill.ca>>> wrote:
>> > >                         Holly, the original statement ends with "All
>> > >                         within the constraints of GDPR of course." I
>> > >                         don't know how to make that clearer. We would
>> > >                         be absolutely FOOLISH to argue for anything
>> > >                         else, since it will not be implementable. That
>> > >                         being said, if through the EPDP or otherwise
>> > >                         we can help make the legal argument for why
>> > >                         good access for the folks we list at the end
>> > >                         is within GDPR, more power to us. GDPR (and
>> > >                         eventually similar legislation/regulation
>> > >                         elsewhere) is the overall constraint. It is
>> > >                         equivalent to the laws of physics which for
>> > >                         the moment we need to consider inviolate. So
>> > >                         my statement that "other issues trump privacy"
>> > >                         is within that context. But just as
>> > >                         proportionality governs what GDPR will decree
>> > >                         as private in any given case, so it will
>> > >                         govern what is not private. It all depends on
>> > >                         making the legal argument and ultimately in
>> > >                         needed convincing the courts. They are the
>> > >                         arbiters, not me or anyone else in ICANN. In
>> > >                         the US, there is the constitutional right to
>> > >                         freedom of speech, but it is not unconstrained
>> > >                         and there are limits to what you are allowed
>> > >                         and not allowed to say. And from time to time,
>> > >                         the courts and legislatures weigh in and
>> > >                         decide where the line is. Alan At 02/08/2018
>> > >                         06:42 PM, Holly Raiche wrote:
>> > >
>> > >                             Hi Alan I have concerns with your
>> > >                             statement - and since your reply below,
>> > >                             with our statement of principles for the
>> > >                             EPDP. As I suggested in my email of 1
>> > >                             August, we need to be VERY clear that we
>> > >                             are NOT arguing against implementation a
>> > >                             policy that is compliant with the GDPR. Â
>> > >                             We are arguing for other issues that
>> > >                             impact on users - WITHIN the umbrella of
>> > >                             the GDPR. Â And if we do not make that
>> > >                             very clear, then we look as if we are not
>> > >                             prepared to operate within the bounds of
>> > >                             the EPDP - which is all about developing a
>> > >                             new policy to replace the RDS requirements
>> > >                             that will allow registries/registrars to
>> > >                             comply with their ICANN contracts and
>> > >                             operate within the GDPR framework. So your
>> > >                             statement below that ‘yes, other issues
>> > >                             trump privacyÂ’ - misstates that. Â What
>> > >                             we are (or should be) arguing for is a
>> > >                             balance of rights of access that - to the
>> > >                             greatest extend possible - recognises the
>> > >                             value of RDS to some constituencies with
>> > >                             legitimate purposes - WITHIN the GDPR
>> > >                             framework. That implicitly accepts that
>> > >                             people/organisations that once had free
>> > >                             and unrestricted access to the data will
>> > >                             no longer have that open access. And for
>> > >                             ALAC generally, I will repeat what I said
>> > >                             in my 1 August email - our statement of
>> > >                             principles must be VERY clear that we are
>> > >                             NOT arguing for a new RDS policy that goes
>> > >                             outside of the GDPR. Holly On 3 Aug 2018,
>> > >                             at 1:29 am, Alan Greenberg
>> > >                             <alan.greenberg at mcgill.ca
>> > >                             <mailto:alan.greenberg at mcgill.ca
>> > >                             <mailto:alan.greenberg at mcgill.ca>> >
>> wrote:
>> > >
>> > >                                 At 02/08/2018 10:37 AM, Michele Neylon
>> > >                                 - Blacknight wrote:
>> > >
>> > >                                     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
>> > >
>> > >                                 Privacy is not absolute but based on
>> > >                                 various other issues. So yes, we are
>> > >                                 saying that in some cases, the other
>> > >                                 issues trump privacy. Perhaps we
>> > >                                 differ on where the dividing line is.
>> > >
>> > >                                     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.
>> > >
>> > >                                 Both here and in reply to #3, the term
>> > >                                 "due process" tends to be used in
>> > >                                 reference to legal constraints
>> > >                                 associated with law enforcement
>> > >                                 actions as sanctioned by laws and
>> > >                                 courts. That is one path to unlocking
>> > >                                 otherwise private information. A major
>> > >                                 aspect of the GDPR implementation will
>> > >                                 be identifying other less cumbersome
>> > >                                 and restricted processes for accessing
>> > >                                 WHOIS data by a variety of partners.
>> > >                                 It will not be unconstrained nor will
>> > >                                 it be as cumbersome as going to court
>> > >                                 (hopefully). Alan
>> > >
>> > >                                     Regards Michele -- Mr Michele
>> > >                                     Neylon Blacknight Solutions
>> > >                                     Hosting, Colocation & Domains
>> > >                                     https://www.blacknight.com/
>> > >                                     <https://www.blacknight.com/>
>> > >                                     https://blacknight.blog/
>> > >                                     <https://blacknight.blog/> Intl.
>> > >                                     +353 (0) 59 Â 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 02/08/2018, 15:03,
>> > >                                     "Jonathan Zuck"
>> > >                                     <JZuck at innovatorsnetwork.org>
>> > >                                     wrote: Â Â Thanks Michele! Â Â 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. Â Â 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. Â Â Make sense? Â Â
>> > >                                     Jonathan   -----Original
>> > >                                     Message----- Â Â 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 Â Â To:
>> > >                                     Alan Greenberg
>> > >                                     <alan.greenberg at mcgill.ca>; CPWG
>> > >                                     <cpwg at icann.org> Â Â Subject: Re:
>> > >                                     [GTLD-WG] [CPWG]
>> > >                                     [registration-issues-wg] ALAC
>> > >                                     Statement regarding EPDP Â Â Alan
>> > >                                       1 - good   2 - good   3 -
>> > >                                     I don't understand what that means
>> > >                                     Â Â 4 - Why are you combining law
>> > >                                     enforcement and private parties?
>> > >                                     Law enforcement can always get
>> > >                                     access to data when they follow
>> > >                                     due process.   Regards  Â
>> > >                                     Michele   --   Mr Michele
>> > >                                     Neylon   Blacknight Solutions Â
>> > >                                     Â Hosting, Colocation & Domains Â
>> > >                                     Â https://www.blacknight.com/
>> > >                                     <https://www.blacknight.com/> Â Â
>> > >                                     https://blacknight.blog/
>> > >                                     <https://blacknight.blog/> Â Â
>> > >                                     Intl. +353 (0) 59 Â 9183072 Â Â
>> > >                                     Direct Dial: +353 (0)59 9183090 Â
>> > >                                     Â Personal blog:
>> > >                                     https://michele.blog/ Â Â Some
>> > >                                     thoughts: https://ceo.hosting/ Â
>> Â
>> > >
>> >  ------------------------------------------------------------
>> ------------
>> > >                                     Â Â Blacknight Internet Solutions
>> > >                                     Ltd, Unit 12A,Barrowside Business
>> > >                                     Park,Sleaty  Â
>> > >                                     Road,Graiguecullen,Carlow,R93
>> > >                                     X265,Ireland  Company No.: 370845
>> > >                                     Â Â 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:
>> Â
>> > >                                     Â Â Â Â Â Yesterday, the EPDP
>> > >                                     Members were asked to present a
>> > >                                     1-3 minute       summary of
>> > >                                     their groups position in regard to
>> > >                                     the EPDP. The following     Â
>> > >                                     Â is the statement agreed to by
>> > >                                     me, Hadia, Holly and Seun. Â Â Â Â
>> > >                                     Â Â 1. Â Â The ALAC believes that
>> > >                                     the EPDP MUST succeed and will be
>> > >                                     working       toward that
>> > >                                     end. Â Â Â Â Â Â 2. Â Â We have a
>> > >                                     support structure that we are
>> > >                                     organizing to ensure      Â
>> > >                                     that what we present here is
>> > >                                     understood by our community and
>> > >                                     has       their input and
>> > >                                     support. Â Â Â Â Â Â 3. Â Â The
>> > >                                     ALAC believes that individual
>> > >                                     registrants are users and we   Â
>> > >                                     Â Â Â have regularly worked on
>> > >                                     their behalf (as in the PDP that
>> > >                                     we       initiated to
>> > >                                     protect registrant rights when
>> > >                                     their domains expire), if    Â
>> > >                                     Â Â registrant needs differ from
>> > >                                     those of the 4 billion Internet
>> > >                                     users       who are not
>> > >                                     registrants, those latter needs
>> > >                                     take precedence. We      Â
>> > >                                     believe that GDPR and this EPDP
>> > >                                     are such a situation. Â Â Â Â Â Â
>> > >                                     4. Â Â 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      Â
>> > >                                     those third parties who work to
>> > >                                     ensure that the Internet is a safe
>> > >                                     Â Â Â Â Â Â and secure place for
>> > >                                     users and that means that law
>> > >                                     enforcement, Â Â Â Â Â Â
>> > >                                     cybersecurity researchers, those
>> > >                                     combatting fraud in domain names,
>> > >                                     Â Â Â Â Â Â and others who help
>> > >                                     protect users from phishing,
>> > >                                     malware, spam, Â Â Â Â Â Â fraud,
>> > >                                     DDoS attacks and such can work
>> > >                                     with minimal reduction in    Â
>> > >                                     Â Â access to WHOIS data. All
>> > >                                     within the constraints of GDPR of
>> > >                                     course. Â Â Â Â Â Â
>> > >
>> >  ------------------------------------------------------------
>> ------------
>> > >                                           CPWG mailing list  Â
>> > >                                         CPWG at icann.org     Â
>> Â
>> > >
>> > https://mm.icann.org/mailman/listinfo/cpwg
>> > >                                     <
>> > https://mm.icann.org/mailman/listinfo/cpwg>
>> > >                                     Â Â Â Â Â Â
>> > >
>> >  ------------------------------------------------------------
>> ------------
>> > >                                     Â Â Â Â Â Â registration-issues-wg
>> > >                                     mailing list      Â
>> > >
>> > registration-issues-wg at atlarge-lists.icann.org
>> > >                                     Â Â Â Â Â Â
>> > >
>> > https://mm.icann.org/mailman/listinfo/registration-issues-wg
>> > >                                     Â Â
>> > >
>> >  ------------------------------------------------------------
>> ------------
>> > >                                       CPWG mailing list  Â
>> > >                                     CPWG at icann.org  Â
>> > >
>> > https://mm.icann.org/mailman/listinfo/cpwg
>> > >                                     <
>> > https://mm.icann.org/mailman/listinfo/cpwg>
>> > >                                     Â Â
>> > >
>> >  ------------------------------------------------------------
>> ------------
>> > >                                       GTLD-WG mailing list  Â
>> > >                                     GTLD-WG at atlarge-lists.icann.org Â
>> > >                                     Â
>> > >
>> > https://atlarge-lists.icann.org/mailman/listinfo/gtld-wg
>> > >                                     Â Â Working Group direct URL:
>> > >
>> > https://community.icann.org/display/atlarge/New+GTLDs
>> > >
>> > >
>> > >
>> >  ------------------------------------------------------------
>> ------------
>> > >                                 CPWG mailing list CPWG at icann.org
>> > >                                 <mailto:CPWG at icann.org
>> > >                                 <mailto:CPWG at icann.org>>
>> > >
>> > https://mm.icann.org/mailman/listinfo/cpwg
>> > >                                 <
>> > https://mm.icann.org/mailman/listinfo/cpwg>
>> > >
>> > >
>> >  ------------------------------------------------------------
>> ------------
>> > >                                 registration-issues-wg mailing list
>> > >
>> > registration-issues-wg at atlarge-lists.icann.org
>> > >
>> > https://mm.icann.org/mailman/listinfo/registration-issues-wg
>> > >
>> > >
>> > >
>> >  ------------------------------------------------------------
>> ------------
>> > >                         CPWG mailing list CPWG at icann.org
>> > >                         <mailto:CPWG at icann.org
>> > >                         <mailto:CPWG at icann.org>>
>> > >                         https://mm.icann.org/mailman/listinfo/cpwg
>> > >                         <https://mm.icann.org/mailman/listinfo/cpwg>
>> > >
>> > >
>> >  ------------------------------------------------------------
>> ------------
>> > >                     CPWG mailing list CPWG at icann.org
>> > >                     <mailto:CPWG at icann.org <mailto:CPWG at icann.org>>
>> > >                     https://mm.icann.org/mailman/listinfo/cpwg
>> > >                     <https://mm.icann.org/mailman/listinfo/cpwg>
>> > >
>> > >
>> >  ------------------------------------------------------------
>> ------------
>> > >                 CPWG mailing list CPWG at icann.org
>> > >                 https://mm.icann.org/mailman/listinfo/cpwg
>> > >                 <https://mm.icann.org/mailman/listinfo/cpwg>
>> > >
>> > >
>> >  ------------------------------------------------------------
>> ------------
>> > >             CPWG mailing list CPWG at icann.org
>> > >             https://mm.icann.org/mailman/listinfo/cpwg
>> > >             <https://mm.icann.org/mailman/listinfo/cpwg>
>> > >
>> >  ------------------------------------------------------------
>> ------------
>> > >             GTLD-WG mailing list GTLD-WG at atlarge-lists.icann.org
>> > >             https://atlarge-lists.icann.org/mailman/listinfo/gtld-wg
>> > >             <https://atlarge-lists.icann.org/mailman/listinfo/gtld-wg
>> >
>> > >             Working Group direct URL:
>> > >             https://community.icann.org/display/atlarge/New+GTLDs
>> > >             <https://community.icann.org/display/atlarge/New+GTLDs>
>> > >
>> > >
>> > >
>> >  ------------------------------------------------------------
>> ------------
>> > >
>> > >     CPWG mailing list
>> > >     CPWG at icann.org
>> > >     https://mm.icann.org/mailman/listinfo/cpwg
>> > >
>> > >
>> >  ------------------------------------------------------------
>> ------------
>> > >
>> > >     GTLD-WG mailing list
>> > >     GTLD-WG at atlarge-lists.icann.org
>> > >     https://atlarge-lists.icann.org/mailman/listinfo/gtld-wg
>> > >
>> > >     Working Group direct URL:
>> > https://community.icann.org/display/atlarge/New+GTLDs
>> > >
>> >
>> > _______________________________________________
>> > CPWG mailing list
>> > CPWG at icann.org
>> > https://mm.icann.org/mailman/listinfo/cpwg
>> > _______________________________________________
>> > GTLD-WG mailing list
>> > GTLD-WG at atlarge-lists.icann.org
>> > https://atlarge-lists.icann.org/mailman/listinfo/gtld-wg
>> >
>> > Working Group direct URL:
>> > https://community.icann.org/display/atlarge/New+GTLDs
>> _______________________________________________
>> CPWG mailing list
>> CPWG at icann.org
>> https://mm.icann.org/mailman/listinfo/cpwg
>> _______________________________________________
>> GTLD-WG mailing list
>> GTLD-WG at atlarge-lists.icann.org
>> https://atlarge-lists.icann.org/mailman/listinfo/gtld-wg
>>
>> Working Group direct URL: https://community.icann.org/
>> display/atlarge/New+GTLDs
>
>
>
> _______________________________________________
> CPWG mailing list
> CPWG at icann.org
> https://mm.icann.org/mailman/listinfo/cpwg
>
>
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