[Gdd-gnso-ppsai-impl] Reminder: IRT feedback requested on proposed LEA Spec edits by EOD Friday, 30 March

Fri Mar 30 13:20:43 UTC 2018

Amy

A lot of us are focussed on GDPR related activities at the moment, so trying to deal with this IRT and the moving target that is GDPR is proving problematic.

However I do think that people will want to weigh in on the text that has evolved.

Regards

Michele

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From: Gdd-gnso-ppsai-impl <gdd-gnso-ppsai-impl-bounces at icann.org> on behalf of Amy Bivins <amy.bivins at icann.org>
Reply-To: "gdd-gnso-ppsai-impl at icann.org" <gdd-gnso-ppsai-impl at icann.org>
Date: Thursday 29 March 2018 at 15:00
To: "gdd-gnso-ppsai-impl at icann.org" <gdd-gnso-ppsai-impl at icann.org>
Subject: Re: [Gdd-gnso-ppsai-impl] Reminder: IRT feedback requested on proposed LEA Spec edits by EOD Friday, 30 March

Hi Darcy and all,

The edits below are quick changes to the draft contract, but given that the IRT hasn’t been presented with the requested fees-related information yet and will need time to review, we’re likely looking at late April/early May at this point, between that and the remaining issues I’ll summarize below.

I hear the group’s frustration on this fees issue. I’m sorry that we don’t have information for you as soon as many of you would like. This inquiry involves virtually all of our operations, because this program won’t operate in a vacuum, so this is taking some time to complete.

ICANN is working on outreach to the data escrow agents as we are finalizing the data escrow specification, and may need to discuss some final issues with the IRT after talking with the agents. Finally, we are also doing a final review of the contract, to make sure there’s nothing else that we should discuss prior to opening the public comment window, particularly considering that the interim GDPR model is up now.

This timeline has continued to push in recent months, but we are trying to ensure we are as thorough as possible. Thus, if there is anything else the IRT would like to discuss, please let us know—we do have time.

We suggested the 30 March deadline for the issues below, as the discussions have been largely circular at this stage, but if the IRT would like to discuss further we certainly can.

Would the group like to discuss the LEA specification on Tuesday, or do you think we’ve gotten as far as we can prior to opening this up for community input? Or, if there are other issues you’d like to discuss on Tuesday, please let us know. Otherwise we will cancel the call, as I don’t have updated materials for you this week. We’ll make the call by EOD tomorrow.

Thanks!
Amy

From: Gdd-gnso-ppsai-impl [mailto:gdd-gnso-ppsai-impl-bounces at icann.org] On Behalf Of Darcy Southwell
Sent: Wednesday, March 28, 2018 6:47 PM
To: gdd-gnso-ppsai-impl at icann.org
Subject: Re: [Gdd-gnso-ppsai-impl] Reminder: IRT feedback requested on proposed LEA Spec edits by EOD Friday, 30 March

Amy,

Given the edits and details below, and the March 30 deadline for further suggestions, what is staff’s expected timing for publishing for public comment?

Thanks,
Darcy

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>>
Date: Wednesday, March 28, 2018 at 5:40 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] Reminder: IRT feedback requested on proposed LEA Spec edits by EOD Friday, 30 March

Dear Colleagues,

This is a reminder that you are requested to provide any additional input you have on the latest proposed edits to the LEA Specification no later than this Friday, 30 March. The latest message to the group on this topic is attached.

The following proposed edits appear to be non-controversial given all of the IRT discussions to date. If we receive no objections to these proposals, we will add these to the draft prior to publishing for public comment:

(1) The addition of the following sections proposed by Sara Bockey (information required to be included in an LEA request):

2.1.9 A clear statement that the domain name or URL involved is part of an official investigation.

2.1.10 A clear statement that the Law Enforcement/Gov’t Agency [propose to change to “Law Enforcement Authority” here for consistency] has attempted to contact the relevant parties and has no other means of identifying them.
2.1.11 For High Priority requests, in addition to the requirements specified in 2.1.1-2.1.10, the Requestor must provide specific information demonstrating that the request is High Priority due to an imminent threat to life, serious bodily injury, critical infrastructure or child exploitation.

We would also likely re-arrange this section slightly, to move the current section 2.1.7 (Any details otherwise required by applicable law) to the end of this section.

(2) The addition of “subject to any additional requirements under applicable law or court order” in Section 4.3.1.

(3) Moving section 6.3 up to the notification section as 4.3.3.

The edits proposed in Section 4.2 appear to be more controversial and would be flagged during the public comment period. Likewise, the disagreement among IRT members on the time period for high-priority requests would be specifically flagged for public comment.

If you would like to discuss any of these proposed edits during our call on Tuesday, please let me know.

Internally, we are continuing to work on the request for additional data surrounding the fees proposal. We are also working on removing the data escrow specification from the body of the contract into a separate specification, and corresponding edits to the contract to accommodate that. I’m not sure whether the data escrow materials will be ready for next week or not. I’ll update you before we meet. If we don’t have updated escrow materials ready and you do not wish to discuss any of the LEA-related issues, we might cancel Tuesday’s call.

The fees information will not be ready for next week, but we will get it to you as soon as possible.

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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