[Gdd-gnso-ppsai-impl] Materials, action items from 17 Oct Privacy/Proxy IRT call
Theo Geurts
gtheo at xs4all.nl
Mon Oct 30 07:45:45 UTC 2017
Agreed Sara and thanks,
And again, given what is going on, we need to make sure this thing is
data protection proof. And yes that is out of scope as an IRT but I feel
if we do not do this we will get shot down during the comment period.
But I am repeating myself here.
Theo
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 withdrawn at any time and not a requirement for registration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 480-366-3616*
>
> *skype: sbockey*
>
> /This email message and any attachments hereto is intended for use
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>
> *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.
>
> 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
>
>
>
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