[Gdd-gnso-ppsai-impl] Fwd: PSWG proposal

Tue Jun 6 15:59:46 UTC 2017

I want to concur with Michele’s comments below and similar comments he and others made during today’s meeting.  In addition:

¶4.3.1 - I’m not certain that the Requestor (LEA) always has authority to set this timeframe. 

¶6.1 – this language is simply not necessary. What a provider may or may not do goes far beyond the single consideration of “where such action does not conflict with national or international law(s).”  It may be based on legal advice from the Provider’s counsel relating to a variety of issues.

Thanks,

Darcy

From: <gdd-gnso-ppsai-impl-bounces at icann.org> on behalf of Michele Neylon - Blacknight <michele at blacknight.com>
Reply-To: <gdd-gnso-ppsai-impl at icann.org>
Date: Tuesday, June 6, 2017 at 5:55 AM
To: "gdd-gnso-ppsai-impl at icann.org" <gdd-gnso-ppsai-impl at icann.org>
Subject: Re: [Gdd-gnso-ppsai-impl] Fwd: PSWG proposal

Amy / Nick

I’ll try to make the call today, but I am having issues juggling meetings / calls etc.,

In relation to the document shared by Nick:

1.5 – is there a list of priority levels? 

One of my concerns with this is that the lazy method would be to always set the level as “fastest” or “top priority”. I see there are two rather vague ones mentioned elsewhere in the document.

3.2 the 24 hour timeframe is not workable. 

I assume the timing has been copied from 3.18 in the 2013 RAA.

Unfortunately there is a significant difference. The disclosure framework outlined by Nick is very “legalistic” so it would require the provider to get legal advice before being able to respond. I don’t think I’d be able to even reach our main legal counsel on a Saturday night, let alone get a response from him that could be used. And if I did the cost would be untenable.

I’d be happy to acknowledge the request within 24 hours, but I don’t think that the current wording is workable.

The language around “secure mechanism” does concern me – it needs to be fleshed out a bit

4.2.3 – “This must be completed prior to any Customer Notification irrespective of the reason for refusal” – I don’t see how or why we would agree to this. Unless you have a court order or similar gagging us. Also it’s inconsistent with the grounds for refusal. 

4.3.3 – sorry, but again I don’t see why we’d agree to this. 

6.3 – this seems to contradict the other references to customer notification

Regards

Michele

--

Mr Michele Neylon

Blacknight Solutions

Hosting, Colocation & Domains

https://www.blacknight.com/

http://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: <gdd-gnso-ppsai-impl-bounces at icann.org> on behalf of Amy Bivins <amy.bivins at icann.org>
Reply-To: "gdd-gnso-ppsai-impl at icann.org" <gdd-gnso-ppsai-impl at icann.org>
Date: Sunday 4 June 2017 at 12:10
To: "gdd-gnso-ppsai-impl at icann.org" <gdd-gnso-ppsai-impl at icann.org>
Subject: [Gdd-gnso-ppsai-impl] Fwd: PSWG proposal

Dear Colleagues,

Please see the PSWG proposal attached, which Nick Shorey will present to the IRT on Tuesday.

Best,

Amy

Sent from my iPhone

Begin forwarded message:

From: Nick Shorey <lists at nickshorey.com>
Date: June 4, 2017 at 6:42:52 AM EDT
To: Amy Bivins <amy.bivins at icann.org>
Cc: Fabien Betremieux <fabien.betremieux at icann.org>
Subject: [Ext] Re: Checking in on PSWG proposal

Hi Amy, 

Please see attached the Disclosure Framework Principles document, which has now been approved by the GAC.

Do send me the details for Tuesday's session, and I look forward to running the rest of the IRT through the document.

FYI I did a Webinar for the GAC last week which took around 30 mins - though I anticipate there could be more questions from the IRT so it could run longer.

Kind regards,

Nick

Nick Shorey 

Phone: +44 (0) 7552 455 988

Email: lists at nickshorey.com

Skype: nick.shorey

Twitter: @nickshorey

LinkedIn: www.linkedin.com/in/nicklinkedin[linkedin.com]

Web: www.nickshorey.com[nickshorey.com]

On Sat, Jun 3, 2017 at 4:12 PM, Amy Bivins <amy.bivins at icann.org> wrote:

Hi Nick,

Just checking in-how are things looking for the PSWG proposal for PP?

Thanks and have a great weekend!
Amy

Sent from my iPhone

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