[Gdd-gnso-ppsai-impl] Request for IRT Feedback: LEA Framework Specification, Receipt Process's Application to High Priority Requests
Volker Greimann
vgreimann at key-systems.net
Fri Feb 9 16:30:08 UTC 2018
You are right about the RAA requirement, however we have never received
such a request or a requests that was deemed to be this urgent by LEAs.
Secondly, operating a registrar is vastly different from operating a
privacy service both in size of their operation and staff as well as
with regard to what they can actually do to assist. This must be borne
in mind when it comes to the reasonableness of such a requirement. Is it
a good thing for LEAs of appropriate jurisdiction to have such access?
Probably. Is it reasonable though? Probably not...
Volker
Am 09.02.2018 um 17:24 schrieb Roman, Peter (CRM):
>
> Hi Chris,
>
> I do not have exact numbers, we do not keep statistics on questions
> like that (that I know of), but we do make emergency requests for
> subscriber data.
>
> I also wanted to note that this is a similar provision as the one in
> the registrar accreditation agreement:
>
> 3.18.2 Registrar shall establish and maintain a dedicated abuse point
> of contact, including a dedicated email address and telephone number
> that is monitored 24 hours a day, seven days a week, to receive
> reports of Illegal Activity by law enforcement, consumer protection,
> quasi-governmental or other similar authorities designated from time
> to time by the national or territorial government of the jurisdiction
> in which the Registrar is established or maintains a physical office.
>
> Well-founded reports of Illegal Activity submitted to these contacts
> must be reviewed within 24 hours by an individual who is empowered by
> Registrar to take necessary and appropriate actions in response to the
> report. In responding to any such reports, Registrar will not be
> required to take any action in contravention of applicable law.
>
> Peter Roman
>
> Senior Counsel
>
> Computer Crime & Intellectual Property Section
>
> Criminal Division
>
> Department of Justice
>
> 1301 New York Ave., NW
> Washington, DC 20530
> (202) 305-1323
>
> peter.roman at usdoj.gov <mailto:peter.roman at usdoj.gov>
>
> *From:* Gdd-gnso-ppsai-impl
> [mailto:gdd-gnso-ppsai-impl-bounces at icann.org] *On Behalf Of *Chris
> Pelling
> *Sent:* Friday, February 9, 2018 6:54 AM
> *To:* gdd-gnso-ppsai-impl at icann.org
> *Subject:* Re: [Gdd-gnso-ppsai-impl] Request for IRT Feedback: LEA
> Framework Specification, Receipt Process's Application to High
> Priority Requests
>
> Hi Peter,
>
> I also find it unreasonable to expect an answer "within" 24 hours -
> but that aside for the moment, let me ask you, how many times have you
> seen in your experience an "imminent threat"/"imminent death/bodily
> harm" request for whois data ?
>
> In 20 years of being a registrar, I thankfully have yet to have 1
> request of this nature. (touch wood I will never have one too)
>
> Kind regards,
>
> Chris
>
> ------------------------------------------------------------------------
>
> *From: *"Roman, Peter (CRM)" <Peter.Roman at usdoj.gov
> <mailto:Peter.Roman at usdoj.gov>>
> *To: *gdd-gnso-ppsai-impl at icann.org <mailto:gdd-gnso-ppsai-impl at icann.org>
> *Sent: *Friday, 9 February, 2018 11:36:08
> *Subject: *Re: [Gdd-gnso-ppsai-impl] Request for IRT Feedback: LEA
> Framework Specification, Receipt Process's Application to High
> Priority Requests
>
> Michele,
>
> I think that’s a distinction without a difference. If it takes three
> days for a provider to provide law enforcement with the information
> needed to handle an emergency request, which by definition is one
> involving a threat of imminent death or serious bodily injury, that is
> way too long. Whether the provider said that the request contains the
> relevant information required to meet the minimum standard for
> acceptance after two days is irrelevant to the need that required an
> emergency request in the first place. A three day window for
> responding in a useful way to an emergency request is unreasonable.
>
> Peter Roman
>
> Senior Counsel
> Computer Crime & Intellectual Property Section
>
> Criminal Division
> U.S. Department of Justice
> 1301 New York Ave. <x-apple-data-detectors://7>, NW
>
> Washington, DC 20530
> (202) 305-1323
>
> peter.roman at usdoj.gov <mailto:peter.roman at usdoj.gov>
>
>
> On Feb 9, 2018, at 4:47 AM, Michele Neylon - Blacknight
> <michele at blacknight.com <mailto:michele at blacknight.com>> wrote:
>
> Peter
>
> 1 – that’s not correct. “Respond” and “take action” are two
> different things. If you ring me and I answer the phone you’re
> getting “a” response.
>
> 2 – Again that’s not correct. There is an obligation to “respond”.
> But you seem to be mixing “respond” and “take action” which is
> where the issue originally arose.
>
> 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/ <https://michele.blog/>
>
> Some thoughts: https://ceo.hosting/ <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 <gdd-gnso-ppsai-impl-bounces at icann.org
> <mailto:gdd-gnso-ppsai-impl-bounces at icann.org>> on behalf of
> "Roman, Peter (CRM)" <Peter.Roman at usdoj.gov
> <mailto:Peter.Roman at usdoj.gov>>
> *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: *Thursday 8 February 2018 at 15:52
> *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: *Re: [Gdd-gnso-ppsai-impl] Request for IRT Feedback: LEA
> Framework Specification, Receipt Process's Application to High
> Priority Requests
>
> Fair enough, and that is why I am seeking clarification of the
> solutions. My reading of the suggestions for solving these issues
> are:
>
> 1 – timing: Providers can take up to three days to respond to
> emergency requests, such as imminent death or serious bodily harm,
> and in 10% of cases even more time
>
> 2 – action: Providers get to choose whether to respond to law
> enforcement requests at all
>
> Peter Roman
>
> Senior Counsel
>
> Computer Crime & Intellectual Property Section
>
> Criminal Division
>
> Department of Justice
>
> 1301 New York Ave., NW
> Washington, DC 20530
> (202) 305-1323
>
> peter.roman at usdoj.gov <mailto:peter.roman at usdoj.gov>
>
> *From:*Gdd-gnso-ppsai-impl
> [mailto:gdd-gnso-ppsai-impl-bounces at icann.org] *On Behalf Of
> *Michele Neylon - Blacknight
> *Sent:* Thursday, February 8, 2018 10:16 AM
> *To:* gdd-gnso-ppsai-impl at icann.org
> <mailto:gdd-gnso-ppsai-impl at icann.org>
> *Subject:* Re: [Gdd-gnso-ppsai-impl] Request for IRT Feedback: LEA
> Framework Specification, Receipt Process's Application to High
> Priority Requests
>
> Peter
>
> I don’t think we are talking about the same thing.
>
> The issue we have with the current wording is two fold:
>
> 1 - timing
>
> 2 - action
>
> My reading of the current wording is that there’s an assumption
> that on receipt of a request the provider will give the LEA what
> they’re asking for.
>
> That might not always be the case, which is why the timing issue
> is key
>
> Regards
>
> Michele
>
> Mr Michele Neylon
>
> Blacknight Hosting & Domains
>
> http://www.blacknight.host/
>
> http://www.mneylon.social
>
> Sent from mobile so typos and brevity are normal
>
>
> On 8 Feb 2018, at 15:08, Roman, Peter (CRM) <Peter.Roman at usdoj.gov
> <mailto:Peter.Roman at usdoj.gov>> wrote:
>
> Just to be clear, these two proposals are:
>
> 1. Providers get to choose whether to respond to law
> enforcement requests at all
> 2. Providers can take up to three days to respond to
> emergency requests, such as imminent death or serious
> bodily harm, and in 10% of cases even more time
>
> Also, just to make sure we are all using the same terms in the
> same way:
>
> Emergency: a sudden, urgent, usually unexpected occurrence or
> occasion requiring immediate action. Dictionary.com
> <http://Dictionary.com>, /Emergency/,
> http://www.dictionary.com/browse/emergency?s=t(last visited
> February 8, 2018).
>
> Imminent: likely to occur at any moment; impending.
> Dictionary.com <http://Dictionary.com>, /Imminent/,
> http://www.dictionary.com/browse/imminent(last visited
> February 8, 2018).
>
> Peter Roman
>
> Senior Counsel
>
> Computer Crime & Intellectual Property Section
>
> Criminal Division
>
> Department of Justice
>
> 1301 New York Ave., NW
> Washington, DC 20530
> (202) 305-1323
>
> peter.roman at usdoj.gov <mailto:peter.roman at usdoj.gov>
>
> *From:*Gdd-gnso-ppsai-impl
> [mailto:gdd-gnso-ppsai-impl-bounces at icann.org] *On Behalf Of
> *Amy Bivins
> *Sent:* Thursday, February 8, 2018 9:25 AM
> *To:* gdd-gnso-ppsai-impl at icann.org
> <mailto:gdd-gnso-ppsai-impl at icann.org>
> *Subject:* Re: [Gdd-gnso-ppsai-impl] Request for IRT Feedback:
> LEA Framework Specification, Receipt Process's Application to
> High Priority Requests
>
> Thank you, Sara, for this very specific proposed change. What
> do others think of this language?
>
> *From:*Gdd-gnso-ppsai-impl
> [mailto:gdd-gnso-ppsai-impl-bounces at icann.org] *On Behalf Of
> *Sara Bockey
> *Sent:* Thursday, February 8, 2018 9:22 AM
> *To:* gdd-gnso-ppsai-impl at icann.org
> <mailto:gdd-gnso-ppsai-impl at icann.org>
> *Subject:* Re: [Gdd-gnso-ppsai-impl] Request for IRT Feedback:
> LEA Framework Specification, Receipt Process's Application to
> High Priority Requests
>
> Dear Amy,
>
> I will reiterate my concern that the LEA framework, as
> currently written, creates a presumption of disclosure if LEAs
> check all the right boxes. Because this decision ultimately
> resides with the provider, based on due process, this must be
> reflected in the framework. Therefore, the following is
> problematic:
>
> You wrote:
>
> “the Provider must review the request and confirm to the LEA
> requester that it has been received and contains the relevant
> information required to meet the minimum standard for
> acceptance (See 3.2.1 of Specification 4). (2) The Provider
> must then action the request in accordance with the priority
> level (within 24 hours for “high priority” requests (4.1.2);
> or within the timeline requested by LEA, if possible, for
> other requests (See 4.1.3).”
>
> At the very minimum, I believe we need to add “without
> limitations” back to section 4.2.2. (Forgive me, I can’t
> recall where we landed on this and fear if I wait to see the
> revised document it will be deemed “too late” to discuss.)
> What’s listed under 4.2.2 should be non-limiting examples for
> when disclosure can be reasonably refused.
>
> Regarding high priority requests, Volker has proposed:
>
> "Where a disclosure request has been categorized as High
> Priority, Provider shall use its best efforts towards
> actioning the request within 24 hours on business days or as
> close as possible to this."
>
> Another option could be something like “actioning the request
> within 24 hours for up to 90% (or some other level determined
> acceptable by Providers) of incidences.”
>
> Your proposed language, namely, *“Where a disclosure request
> has been categorized as High Priority, this must be actioned
> within 24 hours of completion of the receipt process outlined
> in Section 3.2.” The LEA Requestor will detail the threat type
> and justification for a request with a Priority Level of High
> Priority*”, remains overly strict, uses language that creates
> a presumption of disclosure, and is not acceptable.
>
> Thanks,
>
> Sara
>
> *sara bockey*
>
> *sr. policy manager | **Go**Daddy^™ *
>
> *sbockey at godaddy.com* <mailto: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
> <gdd-gnso-ppsai-impl-bounces at icann.org
> <mailto:gdd-gnso-ppsai-impl-bounces at icann.org>> on behalf of
> Amy Bivins <amy.bivins at icann.org <mailto:amy.bivins 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: *Monday, February 5, 2018 at 11:58 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: *Re: [Gdd-gnso-ppsai-impl] Request for IRT Feedback:
> LEA Framework Specification, Receipt Process's Application to
> High Priority Requests
>
> Hi, All,
>
> *Thanks so much for your contribution to this discussion thus
> far, and I encourage the IRT to continue this discussion
> between now and our next meeting on the 13^th .*
>
> As a reminder of how we arrived at this point, the Final
> Report contained a few guidelines for any future LEA
> disclosure framework (see p. 16), /“In the event that a
> Disclosure Framework is eventually developed for LEA requests,
> the WG recommends that the Framework expressly include
> requirements under which at a minimum: (a) the Requester
> agrees to comply with all applicable data protection laws and
> to use any information disclosed to it solely for the purpose
> to determine whether further action on the issue is warranted,
> to contact the customer, or in a legal proceeding concerning
> the issue for which the request was made; and (b) exempts
> Disclosure where the customer has provided, or the P/P service
> provider has found, specific information, facts, and/or
> circumstances showing that Disclosure will endanger the safety
> of the customer.”/
>
> //
>
> * Jan 2016 Final Report: Guidelines re: any future LEA framework
> * June 2016 GAC Helsinki Communique: advising ICANN Board to
> ensure that GAC concerns are effectively addressed in the
> implementation phase of the Privacy/Proxy Service Provider
> Accreditation Program to the greatest extent possible. The
> GAC advised that its input and feedback should be sought
> out as necessary in developing a proposed implementation
> plan, including through participation of the GAC Public
> Safety Working Group (PSWG) on the Implementation Review
> Team (IRT).
> * December 2016: ICANN Board directs ICANN Org to continue
> to encourage dialogue between the IRT and the PSWG to
> address GAC concerns during implementation, to the extent
> that so doing is consistent with Policy Recommendations.
> * Jan 2017: IRT invites PSWG to share strawman proposal,
> http://mm.icann.org/pipermail/gdd_pp_irt_lea/2017-January/000003.html.
>
> * June 2017: PSWG shares strawman proposal with IRT
> * Jun-Sept 2017: IRT discussions re: LEA framework (among
> other topics)
> * Jan/Feb 2018: Continued IRT discussions re: lingering open
> items in LEA FW
>
> Following over six months of discussions on this draft
> framework, the only remaining item appears to be how to handle
> “high priority” requests in terms of timing. In the last
> request to the IRT on this topic, sent to the IRT on 23 Jan,
> http://mm.icann.org/pipermail/gdd-gnso-ppsai-impl/2018-January/000525.html,
> we requested any final feedback on this topic with a deadline
> of 28 Jan. No responses were sent to the list.
>
> This proposed language was distributed today for discussion as
> a proposed solution to resolve potential ambiguity in the
> Final Draft prior to going to public comment. This proposal is
> an attempt to reflect all IRT member input received on the
> topic to date.
>
> Please share any comments on the list with the goal of
> reaching a resolution to this issue prior to our next meeting.
>
> Best,
>
> Amy
>
> *From:*Gdd-gnso-ppsai-impl
> [mailto:gdd-gnso-ppsai-impl-bounces at icann.org] *On Behalf Of
> *theo geurts
> *Sent:* Monday, February 5, 2018 12:32 PM
> *To:* gdd-gnso-ppsai-impl at icann.org
> <mailto:gdd-gnso-ppsai-impl at icann.org>; Sara Bockey
> <sbockey at godaddy.com <mailto:sbockey at godaddy.com>>
> *Subject:* Re: [Gdd-gnso-ppsai-impl] Request for IRT Feedback:
> LEA Framework Specification, Receipt Process's Application to
> High Priority Requests
>
> Agreed Sara,
>
> It seems, or at least, we create a suggestion that if process
> X is followed, disclosure will happen, that is not the case,
> and never has been the case, providers must follow due
> process, always.
>
> If we create a set of LEA procedures, they need to realistic
> and clear and never put a provider in a position where
> contractual agreements put pressure on a provider to comply
> with applicable law. But the first step in this process is to
> figure out if we are not out of scope as an IRT to create such
> procedures.
>
> Theo
>
> On 5-2-2018 18:05, Sara Bockey wrote:
>
> A few items.
>
> Again, I’m concerned that we are /_creating_/ policy, not
> implementing it. Granted, the framework outlined in the
> Final Report is not as robust as what is detailed for IPC,
> but then again LEA did not participate in the PDP
> process. The IRT is _not_ the place to be creating policy
> for LEAs.
>
> That said, the problem with a strict 24-hour period is
> that it doesn’t acknowledge certain situations/matters may
> require additional time, falling outside a 24-hour period
> *_despite a Provider’s best efforts_*. Language such as
> “Where a disclosure request has been categorized as High
> Priority, this must be actioned within 24 hours” are
> overly strict and sets the Provider up for failure/being
> out of compliance due to circumstances beyond its control.
>
> Finally, I fear the LEA framework as currently written
> creates unrealistic expectations/SLAs. There seems to be a
> presumption of disclosure – if LEAs check all the right
> boxes, the information will be disclosed. However, this
> decision should reside with the provider, who does not
> have to bypass due process just to please LEAs.
>
> *sara bockey*
>
> *sr. policy manager | **Go**Daddy^™ *
>
> *sbockey at godaddy.com*
> <mailto: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
> <gdd-gnso-ppsai-impl-bounces at icann.org>
> <mailto:gdd-gnso-ppsai-impl-bounces at icann.org>on behalf of
> Amy Bivins <amy.bivins at icann.org>
> <mailto:amy.bivins 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: *Monday, February 5, 2018 at 7:51 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] Request for IRT Feedback:
> LEA Framework Specification, Receipt Process's Application
> to High Priority Requests
>
> Dear Colleagues,
>
> As mentioned on the list a couple of weeks ago, the
> current draft PPAA is still a bit ambiguous regarding how
> the review process outlined in Section 3.2.1 applies to
> high priority requests. We need ensure that the draft is
> clear about this requirement when we go out for public
> comment (and if there is opposition to the proposed
> requirement by any members of the IRT, this will be
> flagged in the call for comments).
>
> **
>
> *Upon reviewing the IRT’s input to date, I am proposing an
> edit that I believe reflects the IRT discussion on this
> point. Please review and provide your comments on this
> proposed language no later than this Friday, 9 February. *
>
> To summarize, the current draft contains a two-step
> process for Providers upon receipt of a request from LEA.
> (1) Within two business days, the Provider must review the
> request and confirm to the LEA requester that it has been
> received and contains the relevant information required to
> meet the minimum standard for acceptance (See 3.2.1 of
> Specification 4). (2) The Provider must then action the
> request in accordance with the priority level (within 24
> hours for “high priority” requests (4.1.2); or within the
> timeline requested by LEA, if possible, for other requests
> (See 4.1.3).
>
> *The current language may be a bit ambiguous as to whether
> the two business day “review period” applies before the
> 24-hour period for responding to high priority requests
> (as explained in more detail in the attached message).*The
> view of registrar IRT members appears to be that requiring
> action within 24 hours of receipt of an LEA request, even
> if it is a high priority request, is unacceptable. PSWG
> members of the IRT disagree. Other IRT members appear to
> have mixed views on this (some referenced the RAA
> requirement that “Well-founded reports of Illegal Activity
> submitted to these [dedicated LEA] contacts must be
> reviewed within 24 hours by an individual who is empowered
> by Registrar to take necessary and appropriate actions in
> response to the report.” Registrar members of the IRT said
> that the RAA-required review is less intensive than the
> PPAA review due to the specific requirements in the PPAA
> draft).
>
> Based on the views expressed within the IRT, it appears
> that one potential solution to this ambiguity would be to
> update Section 4.1.2 to state that (proposed edit in red),
> *“**Where a disclosure request has been categorized as
> High Priority, this must be actioned within 24 hours of
> completion of the receipt process outlined in Section
> 3.2.” The LEA Requestor will detail the threat type and
> justification for a request with a Priority Level of High
> Priority.”*
>
> The practical impact of this proposed change would be that
> the provider must action a high priority request within 24
> hours of determining that the request meets the minimum
> standard for acceptance. If the provider completes the
> receipt process sooner than 2 business days after receipt
> of the request, this would start the 24-hour clock for
> actioning the request. Thus, this could shorten the
> response window a bit, partially addressing the PSWG
> concerns of a “two business days plus 24 hours”
> requirement, while also addressing registrar concerns by
> not starting the clock until the provider has time to
> review the request, if the full time of the receipt
> process is required to conduct that review.
>
> *Please provide your feedback on this proposed change no
> later than this Friday, 9 Feb. And if you have further
> comments on this, please share those as well.*
>
> **
>
> Best,
>
> Amy
>
> *Amy E. Bivins*
>
> Registrar Services and Engagement Senior Manager
>
> Registrar Services and Industry Relations
>
> Internet Corporation for Assigned Names and Numbers (ICANN)
>
> Direct: +1 (202) 249-7551
>
> Fax: +1 (202) 789-0104
>
> Email: amy.bivins at icann.org <mailto:amy.bivins at icann.org>
>
> www.icann.org <http://www.icann.org>
>
>
>
>
>
>
> _______________________________________________
>
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