[Gdd-gnso-ppsai-impl] Materials, action items from 17 Oct Privacy/Proxy IRT call
theo geurts
gtheo at xs4all.nl
Mon Nov 6 20:27:31 UTC 2017
Hi Steve, Vicky,
Now your argument is logical and makes sense.
Yes, as I mentioned before, CPH's will implement privacy services on
many different levels to comply with the GDPR, we agree here.
My biggest problem with the PPSAI IRT is the changing dynamics.
The WG contemplated and discussed and made recommendations based on a
very fixed situation.
In my opinion, privacy services should not be used as bandaid for data
protection problems.
Complying with data protection laws was not the driving force during the
WG days, and now it is.
I think the scope of the IRT has changed and we should deal with this
before we move on. We need to think a little smarter and deeper here
before we unleash this to many contracted parties who have zero
experience with these services and will be required to implement this to
comply with data protection laws.
So how do we do that? I think a fixed set of procedures and contractual
agreements are essential, yet I do not want us to enter into a situation
that causes more issues and forces providers into a situation that we
need to ask compliance to defer.
https://www.icann.org/resources/pages/contractual-compliance-statement-2017-11-02-en
I think that scenario is unwanted for everyone on the IRT is it not?
Thanks,
Theo Geurts
On 6-11-2017 19:40, Metalitz, Steven wrote:
>
> I strongly second Vicky’s comments. The ongoing ICANN work re GDPR is
> of course very important, but let’s not let it derail progress on the
> path we have moved so far along toward a P/P service accreditation
> framework to present to the community.
>
> In that regard, I have some sympathy (empathy?) for those requesting a
> relaxation of the comment deadline in light of so much other activity
> demanding our attention. May I suggest that we try to get as many
> proposed edits onto the list before our November 14 call (with much
> thanks to those who have already done so), with the goal of dealing
> with them then if possible, but leaving the door open for further
> edits over the next couple of weeks if necessary.
>
> Finally, some ICANN groups are adjusting the scheduling of their calls
> to reflect the return to standard time in North America and Europe.
> Is this group doing so as well? If our calls stay at 1400 UTC that is
> now 9 am EST and 6 am for those on Pacific time. Moving to 1500 UTC
> would retain the pre-existing local start times, I believe.
>
> Steve Metalitz
>
> *image001*
>
> *Steven J. Metalitz *|***Partner, through his professional corporation*
>
> T: 202.355.7902 |met at msk.com <mailto:met at msk.com>**
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> *From:*gdd-gnso-ppsai-impl-bounces at icann.org
> [mailto:gdd-gnso-ppsai-impl-bounces at icann.org] *On Behalf Of *Victoria
> Sheckler
> *Sent:* Tuesday, October 31, 2017 5:55 PM
> *To:* gdd-gnso-ppsai-impl at icann.org; Sara Bockey
> *Subject:* Re: [Gdd-gnso-ppsai-impl] Materials, action items from 17
> Oct Privacy/Proxy IRT call
>
> Please note that ICANN’s work on GDPR’s on a separate track and that
> one thing we know almost for sure is that the adoption of rational,
> predictable rules for privacy/proxy will be more important post-GDPR
> than it ever was. So please let’s get those rules in place as
> expeditiously as possible.
>
> On 30-10-2017 11:32, Sara Bockey wrote:
>
> Caitlin,
>
> Thanks for the revised docs. A few items at first glance that
> need to be revised, as I believe they have been discussion/raised
> before. I will take a closer look and follow up with additional
> edits, but in the meantime…
>
> 1. Edit the definitions of Proxy Service and Privacy Service to
> match the definitions provided in the Final Report/2013 RAA
>
> 1. The definitions of Privacy Service and Proxy Service
> reflect those in the 2013 RAA.
> 2. In this context, the 2013 RAA also defines “Registered
> Name” as a domain name within the domain of a gTLD, about
> which a gTLD Registry Operator (or an Affiliate or
> subcontractor thereof engaged in providing Registry
> Services) maintains data in a Registry Database, arranges
> for such maintenance, or derives revenue from such
> maintenance, and “Registered Name Holder” is defined as
> the holder of a Registered Name.
> 3. It’s noted that ICANN staff has replace “Registered Name
> Holder” with “Customer” in many instances, but I question
> the logic in that since it is inconsistent with the RAA.
>
> 2. Edit Sections 3.5.3.3. thru 3.5.3.6 to take into consideration
> GDPR requirements regarding consent.
>
> 1. Consent must be explicitly given for each purpose and can
> be withdrawn at any time and not a requirement for
> registration or use of the service. Therefore, 3.5.3.3. –
> 3.5.3.6 (at a minimum) are not compatible and must be revise.
>
> 3. Edit section 3.12.2, as it still contains new language that
> has been added since the IRT agreement on language in August.
> The first sentence in its entirety should be removed.
>
> 1. The section should start with “Well founded…”
>
> Additionally, the following sections need revision or at a minimum
> further discuss by the IRT
>
> 4. Edit Section 3.14 to remove the language re no automation.
> This is not feasible. This language must be removed:
>
> 1. Provider shall not use high-volume, automated electronic
> processes (for example, processes that do not utilize
> human review) for sending Requests or responses to
> Requests to Requesters or Customers in performing any of
> the steps in the processes outlined in the Intellectual
> Property Disclosure Framework Specification.
>
> 5. Edit Section 3.15 – Labeling – to remove excessive language.
>
> 1. Provider shall ensure that each Registered Name for which
> Provider is providing the Services is clearly labeled as
> such in the Registration Data Directory Service, as
> specified in the Labeling Specification attached hereto,
> and shall otherwise comply with the requirements of the
> Labeling Specification attached hereto. This language is
> duplicative and not necessary. Let’s not add unnecessary
> words to this already long document. If there are doing to
> be extra works, perhaps mention complying with applicable
> local laws in light of GDPR.
>
> *sara bockey*
>
> *sr. policy manager | **Go**Daddy^™ *
>
> *sbockey at godaddy.com <mailto:sbockey at godaddy.com> 480-366-3616*
>
> *skype: sbockey*
>
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> *From: *<gdd-gnso-ppsai-impl-bounces at icann.org>
> <mailto:gdd-gnso-ppsai-impl-bounces at icann.org> on behalf of
> Caitlin Tubergen <caitlin.tubergen at icann.org>
> <mailto:caitlin.tubergen at icann.org>
> *Reply-To: *"gdd-gnso-ppsai-impl at icann.org"
> <mailto:gdd-gnso-ppsai-impl at icann.org>
> <gdd-gnso-ppsai-impl at icann.org> <mailto:gdd-gnso-ppsai-impl at icann.org>
> *Date: *Wednesday, October 25, 2017 at 4:44 AM
> *To: *"gdd-gnso-ppsai-impl at icann.org"
> <mailto:gdd-gnso-ppsai-impl at icann.org>
> <gdd-gnso-ppsai-impl at icann.org> <mailto:gdd-gnso-ppsai-impl at icann.org>
> *Subject: *[Gdd-gnso-ppsai-impl] Materials, action items from 17
> Oct Privacy/Proxy IRT call
>
> Dear Colleagues,
>
> Thanks so much for your participation on today’s Privacy/Proxy IRT
> call. For those who could not attend, I encourage you to review
> the recording and materials on the wiki,
> https://community.icann.org/display/IRT/24+October+2017.
>
> During the call, we discussed an overview of the changes to the
> draft PPAA.
>
> Please note that ICANN proposed a deadline of *Tuesday,* *14
> November* for all comments, concerns, and edits to the draft PPAA.
> The changes from the last iteration, provided to the IRT in July,
> have been highlighted in the attached issues list. Please respond
> to the list if you would like to request a longer review period.
>
> During ICANN60, we will be presenting an overview of the P/P
> program’s status to the community. Attached, please find the
> slide deck for the presentation.
>
> To highlight a few notes from the IRT’s discussion this morning,
> we received feedback to:
>
> 1. Edit the definition of *Working Group in Section 1.43*, to
> specify that the Provider Stakeholder Group, if formed, shall
> only appoint the /provider/ representatives of the Working
> Group, and the GNSO may appoint other members of the community.
>
> **
>
> 2. Add back in the previously-deleted *Code of Conduct *language
> in *Section 3.5.1*.
>
> **
>
> **
>
> 3. Add back in the previously-deleted *review provision *in
> *Section 7 of the Customer Data Accuracy Program Specification*.
>
> **
>
> If you believe the above items do not reflect the intent of the
> Working Group’s recommendations, please reply to the list by *14
> November 2017*.
>
> Thank you, and safe travels to those of you attending ICANN 60!
>
> Kind regards,
>
> *Caitlin Tubergen*
>
> Registrar Services and Engagement Senior Manager
>
> ICANN
>
> 12025 Waterfront Drive, Suite 300
>
> Los Angeles, CA 90094
>
> Office: +1 310 578 8666
>
> Mobile: +1 310 699 5326
>
> Email: caitlin.tubergen at icann.org <mailto:caitlin.tubergen at icann.org>
>
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