[Gdd-gnso-ppsai-impl] Materials, action items from 17 Oct Privacy/Proxy IRT call
gtheo
gtheo at xs4all.nl
Tue Nov 28 12:22:57 UTC 2017
Hi Steve,
https://www.icann.org/en/system/files/correspondence/jeffrey-to-sprey-01nov17-en.pdf
We now have this process.
https://www.icann.org/resources/pages/contractual-compliance-statement-2017-11-02-en
So I am not sure what the result is going to be of all this. But if we
end up at with a GDPR or data protection law solution at the Registry
level through an RESP, well, I am not sure where we are going to end up,
what are your thoughts?
Thanks,
Theo
Metalitz, Steven schreef op 2017-11-28 01:52 AM:
> Thanks Theo, looking forward to seeing RrSG comments.
>
> Not sure I understand your reference to the .amsterdam GDPR solution
> in this context, but if you could point me to a description of it,
> perhaps that would make your point clearer to me. Thank you.
>
> Steve
>
> STEVEN J. METALITZ | PARTNER, THROUGH HIS PROFESSIONAL CORPORATION
>
> T: 202.355.7902 | met at msk.com
>
> MITCHELL SILBERBERG & KNUPP LLP | WWW.MSK.COM [1]
>
> 1818 N Street NW, 8th Floor, Washington, DC 20036
>
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> INTENDED RECIPIENT, YOU ARE HEREBY NOTIFIED THAT ANY REVIEW, USE,
> DISSEMINATION, FORWARDING OR COPYING OF THIS MESSAGE IS STRICTLY
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> AND DELETE THE ORIGINAL MESSAGE AND ALL ATTACHMENTS FROM YOUR SYSTEM.
> THANK YOU.
>
> FROM: Theo Geurts [mailto:gtheo at xs4all.nl]
> SENT: Monday, November 27, 2017 12:30 PM
> TO: Metalitz, Steven; 'Jennifer Gore'; gdd-gnso-ppsai-impl at icann.org
> CC: Sara Bockey
> SUBJECT: Re: [Gdd-gnso-ppsai-impl] Materials, action items from 17 Oct
> Privacy/Proxy IRT call
>
> Hi Steve, et al.
>
> I will post the RrSG comments tomorrow, which will include a few
> examples.
> Though when I look at the .Amsterdam GDPR solution by the Registry, is
> a key example where our members are thinking, will such solutions
> nullify the PPSAI efforts?
>
> And perhaps this is not obvious for some folks on this IRT. But
> development time is extremely scarce and very costly nowadays. So yes,
> the RrSG folks in here are cautious as they will be the ones who will
> have a very hard time convincing the developers that this all needs to
> be coded and developed. And if it turns out to be all in vain, that is
> not acceptable.
>
> If we look at language draft and the WG recommendations.
>
> DRAFT
> 3.14 Intellectual Property Disclosure Framework Specification.
> Provider
> shall comply with the Intellectual Property Disclosure Framework
> Specification
> attached hereto. 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.
>
> WG language
> "Given the balance that this Policy attempts to strike, evidence of
> the use of high-volume, automated
> electronic processes for sending Requests or responses to Requests
> (without human review) to the
> systems of Requesters, Providers, or Customers in performing any of
> the steps in the processes outlined
> in this Policy shall create a rebuttable presumption of non-compliance
> with this Policy."
>
> It sounds to me it is conflicting. Or perhaps my interpretation is
> off.
>
> Thanks,
>
> Theo
>
> On 27-11-2017 15:52, Metalitz, Steven wrote:
>
>> Just to add to Jennifer's note, I believe it would also be useful
>> for those advocating for discussion on GDPR in this context to
>> provide a couple of examples of specific items in the current draft
>> of the accreditation agreement (or other documents) that they
>> consider problematic in the GDPR context. In other words, concrete
>> examples with respect to item 1 as well as item 2.
>>
>> STEVEN J. METALITZ | PARTNER, THROUGH HIS PROFESSIONAL CORPORATION
>>
>> T: 202.355.7902 | met at msk.com
>>
>> MITCHELL SILBERBERG & KNUPP LLP | WWW.MSK.COM [1]
>>
>> 1818 N Street NW, 8th Floor, Washington, DC 20036
>>
>> THE INFORMATION CONTAINED IN THIS E-MAIL MESSAGE IS INTENDED ONLY
>> FOR THE PERSONAL AND CONFIDENTIAL USE OF THE DESIGNATED RECIPIENTS.
>> THIS MESSAGE MAY BE AN ATTORNEY-CLIENT COMMUNICATION, AND AS SUCH IS
>> PRIVILEGED AND CONFIDENTIAL. IF THE READER OF THIS MESSAGE IS NOT AN
>> INTENDED RECIPIENT, YOU ARE HEREBY NOTIFIED THAT ANY REVIEW, USE,
>> DISSEMINATION, FORWARDING OR COPYING OF THIS MESSAGE IS STRICTLY
>> PROHIBITED. PLEASE NOTIFY US IMMEDIATELY BY REPLY E-MAIL OR
>> TELEPHONE, AND DELETE THE ORIGINAL MESSAGE AND ALL ATTACHMENTS FROM
>> YOUR SYSTEM. THANK YOU.
>>
>> FROM: Jennifer Gore [mailto:jennifer.gore at icann.org]
>> SENT: Saturday, November 25, 2017 8:03 PM
>> TO: gdd-gnso-ppsai-impl at icann.org
>> CC: theo geurts; Metalitz, Steven; Sara Bockey
>> SUBJECT: Re: [Gdd-gnso-ppsai-impl] Materials, action items from 17
>> Oct Privacy/Proxy IRT call
>>
>> Thank you Darcy and all for re-raising your concerns. As I believe
>> we can jointly discuss items 1&3 constructively, it would still be
>> helpful for those IRT members whom believe item number 2 is actually
>> an issue, please provide concrete examples for reference.
>>
>> Thank you,
>>
>> Jennifer Gore
>>
>> Jennifer
>>
>> On Nov 22, 2017, at 11:28 AM, Victoria Sheckler <vsheckler at riaa.com>
>> wrote:
>>
>> I disagree - we need to move the process along as far as we can,
>> while considering GDPR, but we cannot get bogged down or delay other
>> progress that we can accomplish while assessing GDPR issues.
>>
>> FROM: Gdd-gnso-ppsai-impl
>> [mailto:gdd-gnso-ppsai-impl-bounces at icann.org] ON BEHALF OF Darcy
>> Southwell
>> SENT: Wednesday, November 22, 2017 10:19 AM
>> TO: theo geurts <gtheo at xs4all.nl>; gdd-gnso-ppsai-impl at icann.org;
>> Metalitz, Steven <met at msk.com>; Sara Bockey <sbockey at godaddy.com>
>> SUBJECT: Re: [Gdd-gnso-ppsai-impl] Materials, action items from 17
>> Oct Privacy/Proxy IRT call
>>
>> Agree with Theo.
>>
>> @Steve, My concern here is that we're moving forward with developing
>> processes that may violate the GDPR, which goes into effect in just
>> six months. It seems far more efficient to identify and discuss how
>> GDPR affects any PDP policy recommendations before finalizing
>> processes. We need to take a step back to do that first. I'm
>> certainly not a GDPR expert, but data collection and transmission
>> registrants who are EU residents appear to be problematic if we
>> continue to ignore the GDPR.
>>
>> Darcy
>>
>> FROM: theo geurts <gtheo at xs4all.nl>
>> DATE: Tuesday, November 21, 2017 at 12:50 PM
>> TO: <gdd-gnso-ppsai-impl at icann.org>, "Metalitz, Steven"
>> <met at msk.com>, 'Darcy Southwell' <darcy.southwell at endurance.com>,
>> Sara Bockey <sbockey at godaddy.com>
>> SUBJECT: Re: [Gdd-gnso-ppsai-impl] Materials, action items from 17
>> Oct Privacy/Proxy IRT call
>>
>> Hi all,
>>
>> Some comments.
>> @Darcy I agree on all points, very fundamental, and I think worth
>> discussing at the Dec 5th meeting.
>>
>> 1 I agree Vlad's suggestion is good, the only question I have, and
>> we discussed this earlier, do we wait for the second Hamilton piece
>> or do we already have enough? I am not sure where at right now,
>> perhaps staff can weigh in some to get a sense here.
>> 3 PSWG liaison to the IRT, what is the status? Can we indeed
>> confirm his availability?
>>
>> @Steve, your question to Darcy about the GDPR and the impact, and
>> obviously I am not Darcy ;) but we contracted parties spent a ton of
>> time on this GDPR thing, and we get frustrated how this GDPR keeps
>> creeping up on us from angles we never imagined.
>>
>> Thick WHOIS IRT, I don't have to remind you there, you and I spent a
>> lot of time there wrapping it up. Since Johannesburg, that thing
>> has been a moving target.
>>
>> The WG recommendations for the PPSAI were made under different
>> circumstances, and I hope you and fellow IRT members can understand
>> we registrars we do not want a repeat here.
>> Going through an exempt process with compliance is just
>> time-consuming, costing money and all that. We need to be in scope
>> here, and if we are not, we go back to the GNSO.
>>
>> Does this make any sense?
>>
>> Best
>>
>> Theo Geurts
>>
>> On 21-11-2017 20:39, Metalitz, Steven wrote:
>>
>> Re item 3 in Darcy's list, I understand contact has been
>> established with the new PSWG liaison to the IRT. Can we confirm
>> his availability to participate in a call on December 5?
>>
>> Re item 1 I would note Vlad's earlier comment to the list, which I
>> support: "Maybe we can focus on critical issues that are not
>> related to GDPR, and once ICANN comes back to us with some clarity
>> on GDPR then we can tackle those issues."
>>
>> Finally, Darcy perhaps you could clarify how you think these issues
>> could be discussed constructively "before moving forward with
>> reviewing the draft documents." Items 2 and 3 seem to refer to
>> specific points in one or more of the draft documents. Re item 1,
>> can you identify any specific points in the draft documents you
>> would like to discuss with regard to the impact of GDPR?
>>
>> <IMAGE001.GIF>
>>
>> STEVEN J. METALITZ | PARTNER, THROUGH HIS PROFESSIONAL CORPORATION
>>
>> T: 202.355.7902 | met at msk.com
>>
>> MITCHELL SILBERBERG & KNUPP LLP | WWW.MSK.COM [1]
>>
>> 1818 N Street NW, 8th Floor, Washington, DC 20036
>>
>> THE INFORMATION CONTAINED IN THIS E-MAIL MESSAGE IS INTENDED ONLY
>> FOR THE PERSONAL AND CONFIDENTIAL USE OF THE DESIGNATED RECIPIENTS.
>> THIS MESSAGE MAY BE AN ATTORNEY-CLIENT COMMUNICATION, AND AS SUCH IS
>> PRIVILEGED AND CONFIDENTIAL. IF THE READER OF THIS MESSAGE IS NOT AN
>> INTENDED RECIPIENT, YOU ARE HEREBY NOTIFIED THAT ANY REVIEW, USE,
>> DISSEMINATION, FORWARDING OR COPYING OF THIS MESSAGE IS STRICTLY
>> PROHIBITED. PLEASE NOTIFY US IMMEDIATELY BY REPLY E-MAIL OR
>> TELEPHONE, AND DELETE THE ORIGINAL MESSAGE AND ALL ATTACHMENTS FROM
>> YOUR SYSTEM. THANK YOU.
>>
>> FROM: Darcy Southwell [mailto:darcy.southwell at endurance.com]
>> SENT: Tuesday, November 21, 2017 2:00 PM
>> TO: gdd-gnso-ppsai-impl at icann.org; Metalitz, Steven; Sara Bockey
>> SUBJECT: Re: [Gdd-gnso-ppsai-impl] Materials, action items from 17
>> Oct Privacy/Proxy IRT call
>>
>> @ICANN Staff,
>>
>> I wanted to re-raise the issues mentioned below in advance our next
>> meeting on 5 December. I think many IRT members would like to see
>> us tackle these issues first before moving forward with reviewing
>> the draft documents. Specifically:
>>
>> 1. Impact of GDPR on policy/implementation (i.e., aspects of
>> the recommendations from the Final Report that will be impacted by
>> the GDPR).
>>
>> 2. Contradictions between draft implementation language and
>> the Final Report (e.g., how/why this is happening).
>>
>> 3. Concerns with proposed framework Public Safety Working
>> Group.
>>
>> I suggest that our 5 Dec. agenda should focus on these discussion
>> items.
>>
>> Thanks,
>>
>> Darcy
>>
>> FROM: Darcy Southwell <darcy.southwell at endurance.com>
>> DATE: Tuesday, November 7, 2017 at 7:47 AM
>> TO: <gdd-gnso-ppsai-impl at icann.org>, "Metalitz, Steven"
>> <met at msk.com>, Sara Bockey <sbockey at godaddy.com>
>> SUBJECT: Re: [Gdd-gnso-ppsai-impl] Materials, action items from 17
>> Oct Privacy/Proxy IRT call
>>
>> I agree with Theo. The scope has changed and implementation is
>> impacted by GDPR. While I appreciate that Steve wants to move
>> forward expeditiously, I don't believe we can do so without
>> jeopardizing the creation of an effective program. Further, in just
>> the last week or so, issues have been raised about implementation
>> language contradicting the policy. The role of an IRT is to
>> implement the consensus policy produced in the PDP and we need to
>> spend sufficient time reviewing and discussing the implementation to
>> ensure we're not changing policy. Similarly, I think there were
>> questions raised about the proposed framework Public Safety Working
>> Group. In addition to policy creep, I believe concerns were
>> expressed that staff failed to modify the proposed framework based
>> on the feedback from IRT participants. Rather than picking through
>> the documents line by line, it seems like we should step back and
>> have a discussion about the concepts to ensure we're making progress
>> toward an effective implementation that reflects the policy. There
>> have also been repeated questions raised about the over-engineering
>> of this implementation. Because many of the meetings have focused
>> on reviewing language from a specific section (rather than reviewing
>> issues as whole items), it seems like we haven't gotten past this
>> issue, and should probably take a fresh look at that to ensure we're
>> not making this implementation more complicated than it needs to be.
>> We all know that doesn't lead us to a better implementation. Right
>> now, we have four draft documents for review/input: (1)
>> accreditation agreement, (2) de-accreditation process, (3) applicant
>> guide, and (4) data escrow specification. For many members, these
>> require operational and legal review (at a minimum). Many
>> registrars have commented that 1 December is the earliest they can
>> provide full feedback given the complexity of these documents
>> (although not all have committed to that date).
>>
>> Given these issues, as well as the fact that the privacy/proxy
>> challenge stemming from IRTP-C needs to be added to this IRT for a
>> solution, we need to take a step back and address these critical
>> issues first. This isn't about derailing the IRT; it's about
>> ensuring we don't create an implementation that's an operational
>> nightmare for providers as well as registrants and end users - and
>> that means addressing these critical issues first.
>>
>> Thanks,
>>
>> Darcy
>>
>> FROM: <gdd-gnso-ppsai-impl-bounces at icann.org> on behalf of theo
>> geurts <gtheo at xs4all.nl>
>> REPLY-TO: <gdd-gnso-ppsai-impl at icann.org>
>> DATE: Monday, November 6, 2017 at 12:27 PM
>> TO: <gdd-gnso-ppsai-impl at icann.org>, "Metalitz, Steven"
>> <met at msk.com>, Sara Bockey <sbockey at godaddy.com>
>> SUBJECT: Re: [Gdd-gnso-ppsai-impl] Materials, action items from 17
>> Oct Privacy/Proxy IRT call
>>
>> 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
>>
>> <IMAGE002.GIF>
>>
>> STEVEN J. METALITZ | PARTNER, THROUGH HIS PROFESSIONAL CORPORATION
>>
>> T: 202.355.7902 | met at msk.com
>>
>> MITCHELL SILBERBERG & KNUPP LLP | WWW.MSK.COM [1]
>>
>> 1818 N Street NW, 8th Floor, Washington, DC 20036
>>
>> THE INFORMATION CONTAINED IN THIS E-MAIL MESSAGE IS INTENDED ONLY
>> FOR THE PERSONAL AND CONFIDENTIAL USE OF THE DESIGNATED RECIPIENTS.
>> THIS MESSAGE MAY BE AN ATTORNEY-CLIENT COMMUNICATION, AND AS SUCH IS
>> PRIVILEGED AND CONFIDENTIAL. IF THE READER OF THIS MESSAGE IS NOT AN
>> INTENDED RECIPIENT, YOU ARE HEREBY NOTIFIED THAT ANY REVIEW, USE,
>> DISSEMINATION, FORWARDING OR COPYING OF THIS MESSAGE IS STRICTLY
>> PROHIBITED. PLEASE NOTIFY US IMMEDIATELY BY REPLY E-MAIL OR
>> TELEPHONE, AND DELETE THE ORIGINAL MESSAGE AND ALL ATTACHMENTS FROM
>> YOUR SYSTEM. THANK YOU.
>>
>> 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…
>>
>> * Edit the definitions of Proxy Service and Privacy Service to
>> match the definitions provided in the Final Report/2013 RAA
>>
>> * The definitions of Privacy Service and Proxy Service reflect
>> those in the 2013 RAA.
>> * 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.
>> * 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.
>>
>> * Edit Sections 3.5.3.3. thru 3.5.3.6 to take into consideration
>> GDPR requirements regarding consent.
>>
>> * 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.
>>
>> * 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.
>>
>> * The section should start with "Well founded…"
>>
>> Additionally, the following sections need revision or at a minimum
>> further discuss by the IRT
>>
>> * Edit Section 3.14 to remove the language re no automation. This
>> is not feasible. This language must be removed:
>>
>> * 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.
>>
>> * Edit Section 3.15 - Labeling - to remove excessive language.
>>
>> * 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 | GODADDY™
>>
>> SBOCKEY at GODADDY.COM 480-366-3616
>>
>> SKYPE: SBOCKEY
>>
>> _This email message and any attachments hereto is intended for use
>> only by the addressee(s) named herein and may contain confidential
>> information. If you have received this email in error, please
>> immediately notify the sender and permanently delete the original
>> and any copy of this message and its attachments._
>>
>> FROM: <gdd-gnso-ppsai-impl-bounces at icann.org> on behalf of Caitlin
>> Tubergen <caitlin.tubergen at icann.org>
>> REPLY-TO: "gdd-gnso-ppsai-impl at icann.org"
>> <gdd-gnso-ppsai-impl at icann.org>
>> DATE: Wednesday, October 25, 2017 at 4:44 AM
>> TO: "gdd-gnso-ppsai-impl at icann.org" <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 [2].
>>
>> 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:
>>
>> * 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.
>>
>> * Add back in the previously-deleted CODE OF CONDUCT language in
>> SECTION 3.5.1.
>>
>> * 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
>>
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