[Gdd-gnso-ppsai-impl] Summary, action items from today's PP IRT call
Volker Greimann
vgreimann at key-systems.net
Mon Mar 5 15:50:07 UTC 2018
Excellent points. Full support!
Best,
Volker
Am 02.03.2018 um 21:18 schrieb Eric Rokobauer:
> Agree to the feedback raised also.
>
> Regards,
> Eric
>
>
> */Eric Rokobauer/*
> Sr. Registrar Compliance Manager | Endurance International Group
> 10 Corporate Drive, Suite 300, Burlington MA 01803
> T - 781.852.3445 <tel:%28781%29%20852-3445>
> E - eric.rokobauer at endurance.com <mailto:eric.rokobauer at endurance.com>
>
>
>
>
> On Mar 2, 2018 2:41 PM, "DiBiase, Gregory via Gdd-gnso-ppsai-impl"
> <gdd-gnso-ppsai-impl at icann.org <mailto:gdd-gnso-ppsai-impl at icann.org>>
> wrote:
>
> +1 on all of these points.
>
> -Greg
>
> *From:* Gdd-gnso-ppsai-impl
> [mailto:gdd-gnso-ppsai-impl-bounces at icann.org
> <mailto:gdd-gnso-ppsai-impl-bounces at icann.org>] *On Behalf Of
> *Michele Neylon - Blacknight
> *Sent:* Friday, March 02, 2018 11:03 AM
> *To:* gdd-gnso-ppsai-impl at icann.org
> <mailto:gdd-gnso-ppsai-impl at icann.org>
>
>
> *Subject:* Re: [Gdd-gnso-ppsai-impl] Summary, action items from
> today's PP IRT call
>
> I agree 100% with all of these points
>
> Regards
>
> Michele
>
> Mr Michele Neylon
>
> https://www.blacknight.com/
>
> https://michele.blog
>
> Intl. +353 (0)59 9183072 <tel:+353%2059%20918%203072>
>
> Sent from mobile so usual disclaimers about typos etc apply
>
>
> On 2 Mar 2018, at 13:58, Sara Bockey <sbockey at godaddy.com
> <mailto:sbockey at godaddy.com>> wrote:
>
> As requested, I’m providing feedback to the bulleted items at
> the bottom of this thread. For ease of reading I’m restating
> the question and then providing my response.
>
> *Monthly Reporting Specification*
>
> 1. Issue 1: Report frequency—IRT members seemed to support a
> requirement that these reports be submitted quarterly
> (current draft suggested monthly). Absent contrary input
> on the list this week, this change will be made in next
> draft. Reports could be submitted quarterly at maximum.
> Bi-annual or annual would be preferred.
>
> 2.Issue 2: Report submission—on-list, some IRT members said
> that using ICANN reporting interface was too complicated
> and/or unnecessary. No one commented on this topic during
> today’s meeting. Absent substantial input on this topic
> on-list this week indicating that many IRT members would
> support a contrary reporting mechanism, no changes will be
> made on this point.
>
> The reporting spec is overly burdensome. Reporting must be
> simple enough for smaller companies to use without
> necessitating technical implementation. Companies should not
> have to spend significant amounts of money creating a system
> to support this specification. Reporting can and should
> therefore be permissible by form of a pre-formatted email.
>
> For issues 1 and 2, let's start simple and basic. Allow the
> Provider to fill out a sheet and email it to a designated
> address. If after submitting the first few reports it’s clear
> that we need to re-evaluate the process, we can come back and
> do so.
>
> 3.Issue 3: Report format—on-list, some IRT members took issue
> with requiring both per-registrar and per-TLD reports. During
> the call, some IRT members indicating per-TLD could be too
> labor intensive, but other IRT members supported having
> per-TLD reports. Additional IRT input is requested on this point.
>
> Again, the requirements set forth in the current spec are too
> complicated. Simple is what is needed. The reports should
> only focus on the number of requests, and the actions taken on
> a global perspective.
>
> 4.Issue 4: Report fields—on-list, suggestions have been made
> for eliminating some fields, and adding others. Based on the
> discussion in today’s call (absent contrary and/or additional
> suggestions on-list) the specification will be updated to:
> eliminate “total” numbers for requests for specific contacts,
> eliminate “publication” fields for LEA and IP requests, add
> publication/disclosure-other fields to capture non-LEA/IP
> requests, add coded “reasons for denial” fields.
>
> *PP Applicant Guide*
>
> 1. Issue 1: Shift to “rolling” application period
> (eliminating application phases). IRT members supported
> this approach. Absent contrary feedback on-list we will
> proceed with this approach.
>
> No issue with this change.
>
> 2.Issue 2: Elimination of many “essay” questions in favor of
> “checkbox” questions. IRT members supported this approach.
> Absent contrary feedback on-list we will proceed with this
> approach.
>
> No issue with this change.
>
> 3.Issue 3: Fees proposal. IRT requested additional
> documentation of costs to support fees proposal (ICANN org
> will work to provide this ASAP).
>
> Current proposed fees are not acceptable, and we look forward
> to ICANN providing its justification. Fees must be justified
> and reasonable considering the business models and volumes of
> service providers that are to be accredited. The new gTLD
> application fees were also meant to be cost-neutral, based on
> cost recovery, and that resulted in a huge surplus. Also,
> significant savings can be achieved in reducing or eliminating
> the requirements for background checks.
>
> *LEA Disclosure Framework Specification*
>
> 1. Issue 1: Language re: notices to customers in Sections 6.3
> and 4.3, while not directly contradictory, sets different
> standards for the timing of notice to customers regarding
> an LEA request. Per IRT input on-list and on today’s call,
> edits will be made to make clear that Section 4.3
> controls, and language to 4.3 to make clear that provide
> will notify customer of a request in accordance with ToS
> and timeframe requested by LEA, subject to any other
> requirements under applicable law or court order. Any
> additional input on this is requested by the end of the week.
>
> 2.Issue 2: Required provider responses to high priority LEA
> requests. Per discussion on-list and during today’s call, it
> appears that
>
> 1.If “action” is clearly defined to include (1) disclosure of
> the requested information, (2) refusal to disclose the
> requested information for one of the reasons listed in section
> 4.2.2, and/or (3) in exceptional circumstances, informing LEA
> that the provider requires additional time to respond, then
>
> 2.The IRT appears to find a 24-hour response time acceptable
> for high-priority requests from LEA that qualify for this
> specification.
>
> No. That is an incorrect presumption. The 24-hour response
> time is still overly strict. I propose the following language:
>
> Where a disclosure request has been categorized as High
> Priority, LEA will make every effort to contact the Provider
> directly to discuss the matter, and should it be determined
> that Provider has useful information, Provider shall use its
> best efforts to action the request within one business day,
> noting that a court order/subpoena may still be required prior
> to release of any information. Registrar will not be required
> to take any action in contravention of applicable law.
>
> 3.*IRT feedback is specifically requested on this point.
> Please respond to the list noting whether you (1) support, (2)
> oppose, or (3) would edit (explain how) the requirement that
> providers be required to action high-priority requests from
> LEA within 24 hours of receipt of the request from LEA. If
> there is disagreement on this, this will be flagged during the
> public comment period. *
>
> I oppose the requirement that providers be required to action
> high-priority requests from LEA within 24 hours of receipt of
> the request from LEA. As previously stated, the 24-hour
> requirement is overly strict. This does not mean we will not
> try to move heaven and earth to assist LEA in a dire
> situation, but having it baked into a contract is a recipe for
> failure.
>
> What Section 4.2.2 fails to recognize are extraordinary
> circumstances that could arise outside of the 3 reasons list.
> There could be a DDOS attack that cripples the Provider’s
> systems, or there could be a flu epidemic that leaves the
> Provider short staffed and with a backlog, just to name a
> few. The point being that very valid circumstances could
> arise outside of the reasons listed in 4.2.2 and outside a
> Provider’s control.
>
> Again, I would like following language considered:
>
> Where a disclosure request has been categorized as High
> Priority, LEA will make every effort to contact the Provider
> directly to discuss the matter, and should it be determined
> that Provider has useful information, Provider shall use its
> best efforts to action the request within one business day,
> noting that a court order/subpoena may still be required prior
> to release of any information. Registrar will not be required
> to take any action in contravention of applicable law.
>
> *sara bockey*
>
> *sr. policy manager | **Go**Daddy^™ *
>
> *sbockey at godaddy.com <mailto:sbockey at godaddy.com> 480-366-3616
> <tel:%28480%29%20366-3616>*
>
> *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: *Amy Bivins <amy.bivins at icann.org
> <mailto:amy.bivins at icann.org>>
> *Date: *Thursday, February 22, 2018 at 2:24 PM
> *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>>
> *Cc: *Sara Bockey <sbockey at godaddy.com
> <mailto:sbockey at godaddy.com>>
> *Subject: *Re: [Gdd-gnso-ppsai-impl] Summary, action items
> from today's PP IRT call
>
> Hi All,
>
> We can provide an additional week for IRT input on the items
> below. Please send any feedback on these topics to the list by
> the end of next week, 2 March.
>
> As this will impact our ability to finalize the PPAA draft,
> next week’s IRT meeting will be canceled.
>
> Best,
>
> Amy
>
>
> On Feb 22, 2018, at 4:04 PM, theo geurts <gtheo at xs4all.nl
> <mailto:gtheo at xs4all.nl>> wrote:
>
> Agreed, the time we have to invest due to GDPR is weighing
> heavy on contracted parties and I am pretty sure no one
> expected we had to deep dive so hard into all these models
> and many many calls. Did the T&T even reach quorum
> yesterday? The last meeting it was me and Roger Carney as
> the only attendees. IRT's and WG's are suffering due to
> the GDPR, I think we are asking too much of the volunteer
> workforce here.
>
> The meeting in PR, 18:30 till 20:00 for the PPSAI, I
> cannot believe that. My first meeting starts at 8 am that
> day. Is it normal ICANN staff works from 8 am to 8 pm? I
> do not find it normal as we do not get paid. This is
> getting close to slave labor here.
>
> Theo
>
> On 22-2-2018 21:51, Sara Bockey wrote:
>
> Amy,
>
> As you know, several registrars were not able to
> attend Tuesday’s call and I think it’s safe to say
> many members a facing bandwidth issues.
>
> As you also know, GDPR is fast approaching and several
> sessions were held this week on the topic. GDPR is
> mission critical and requires a lot of registrar time
> investment. That said, it is likely that IRT members
> have not had a chance to listen to the recording or
> catch up on the mailing list. Therefore, I think it
> would be appropriate to allow an additional week to
> respond to our punch list below. There is no reason
> why we cannot allow this additional time. We are not
> facing a hard deadline as with GDPR, and it is very
> important for this IRT to produce quality work, not
> quick work.
>
> Thanks,
>
> Sara
>
> *sara bockey*
>
> *sr. policy manager | **Go**Daddy^™ *
>
> *sbockey at godaddy.com <mailto:sbockey at godaddy.com>
> 480-366-3616 <tel:%28480%29%20366-3616>*
>
> *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: *Thursday, February 22, 2018 at 3:55 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] Summary, action
> items from today's PP IRT call
>
> Dear Colleagues,
>
> This is a reminder to please submit your input on the
> points below no later than your EOD Friday.
>
> We will make any final edits to the PPAA draft based
> on this feedback and intend to send you the updated
> draft on Monday as soon as the final edits are
> complete and reviewed internally. You aren’t expected
> to review the draft prior to Tuesday’s meeting-I
> realize this is a tight turnaround-I will explain
> edits that were made so that you can more easily
> review the updated draft after our call next week.
>
> Best,
>
> Amy
>
> Sent from my iPhone
>
>
> On Feb 20, 2018, at 12:27 PM, Amy Bivins
> <amy.bivins at icann.org <mailto:amy.bivins at icann.org>>
> wrote:
>
> Dear Colleagues,
>
> Thank you for your active participation on today’s
> Privacy/Proxy IRT call. We covered a lot of
> ground. If you could not attend, I encourage you
> to listen to the recording, available on the wiki,
> https://participate.icann.org/p39onhjd1g1/
> <https://participate.icann.org/p39onhjd1g1/>.
>
> *Please review the items discussed today
> (summarized below) and provide any additional
> input to the list no later than your EOD Friday,
> 23 Feb.*
>
> *Monthly Reporting Specification*
>
> (1)Issue 1: Report frequency—IRT members seemed to
> support a requirement that these reports be
> submitted quarterly (current draft suggested
> monthly). Absent contrary input on the list this
> week, this change will be made in next draft.
>
> (2)Issue 2: Report submission—on-list, some IRT
> members said that using ICANN reporting interface
> was too complicated and/or unnecessary. No one
> commented on this topic during today’s meeting.
> Absent substantial input on this topic on-list
> this week indicating that many IRT members would
> support a contrary reporting mechanism, no changes
> will be made on this point.
>
> (3)Issue 3: Report format—on-list, some IRT
> members took issue with requiring both
> per-registrar and per-TLD reports. During the
> call, some IRT members indicating per-TLD could be
> too labor intensive, but other IRT members
> supported having per-TLD reports. Additional IRT
> input is requested on this point.
>
> (4)Issue 4: Report fields—on-list, suggestions
> have been made for eliminating some fields, and
> adding others. Based on the discussion in today’s
> call (absent contrary and/or additional
> suggestions on-list) the specification will be
> updated to: eliminate “total” numbers for requests
> for specific contacts, eliminate “publication”
> fields for LEA and IP requests, add
> publication/disclosure-other fields to capture
> non-LEA/IP requests, add coded “reasons for
> denial” fields.
>
> *PP Applicant Guide*
>
> (1)Issue 1: Shift to “rolling” application period
> (eliminating application phases). IRT members
> supported this approach. Absent contrary feedback
> on-list we will proceed with this approach.
>
> (2)Issue 2: Elimination of many “essay” questions
> in favor of “checkbox” questions. IRT members
> supported this approach. Absent contrary feedback
> on-list we will proceed with this approach.
>
> (3)Issue 3: Fees proposal. IRT requested
> additional documentation of costs to support fees
> proposal (ICANN org will work to provide this ASAP).
>
> *LEA Disclosure Framework Specification*
>
> (1)Issue 1: Language re: notices to customers in
> Sections 6.3 and 4.3, while not directly
> contradictory, sets different standards for the
> timing of notice to customers regarding an LEA
> request. Per IRT input on-list and on today’s
> call, edits will be made to make clear that
> Section 4.3 controls, and language to 4.3 to make
> clear that provide will notify customer of a
> request in accordance with ToS and timeframe
> requested by LEA, subject to any other
> requirements under applicable law or court order.
> Any additional input on this is requested by the
> end of the week.
>
> (2)Issue 2: Required provider responses to high
> priority LEA requests. Per discussion on-list and
> during today’s call, it appears that
>
> a.If “action” is clearly defined to include (1)
> disclosure of the requested information, (2)
> refusal to disclose the requested information for
> one of the reasons listed in section 4.2.2, and/or
> (3) in exceptional circumstances, informing LEA
> that the provider requires additional time to
> respond, then
>
> b.The IRT appears to find a 24-hour response time
> acceptable for high-priority requests from LEA
> that qualify for this specification.
>
> c.*IRT feedback is specifically requested on this
> point. Please respond to the list noting whether
> you (1) support, (2) oppose, or (3) would edit
> (explain how) the requirement that providers be
> required to action high-priority requests from LEA
> within 24 hours of receipt of the request from
> LEA. If there is disagreement on this, this will
> be flagged during the public comment period.*
>
> 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 <tel:%28202%29%20249-7551>
>
> Fax: +1 (202) 789-0104 <tel:%28202%29%20789-0104>
>
> Email: amy.bivins at icann.org
> <mailto:amy.bivins at icann.org>
>
> www.icann.org <http://www.icann.org>
>
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--
Bei weiteren Fragen stehen wir Ihnen gerne zur Verfügung.
Mit freundlichen Grüßen,
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- Rechtsabteilung -
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