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

Fri Mar 30 20:05:15 UTC 2018

Agreed with Michele and I guess most EU registrars.

I think the most of the EU registrars are neck deep in making sure the 
business stays afloat and GDPR compliant.

On top of this, we need to process many data processing agreements from 
our vendors and clients which need to be reviewed. And I think all EU 
registrars can verify and acknowledge this is super time consuming and a 
lot things are at stake.

We also enter a stage where we need to have our own data processing 
agreements ready to be compliant. Pimp up our security policies and 
privacy statements to be compliant. We all waited a long time for ICANN. 
But the reality is we EU ICANN registrars got 55 days left.

EU ccTLD registries who were not GDPR ready are moving fast; we need to 
process all the legal stuff and the changes in the registry systems on 
the fly.

Sure we can argue this is all out of scope as it is not ICANN related. 
But it is also not very multi-stakeholder model wise when a lot of 
stakeholders are forced to deal with issues to be compliant with the law 
and cannot spend time on this IRT.

I have not participated much the last few months as I was up to my ears 
in solving all of the above, and I am not even close to wrapping things 
up, and I will not participate for the next few weeks, maybe end of June 
if I am lucky? We still got significant legal hurdles to solve.
And I am aware that within the ICANN silo the GDPR sounds very urgent 
and necessary, the reality is, ICANN is way at the bottom priority wise. 
Sure gTLDS are essential, but it is not at the top of the list, not even 
close.

I would ask this IRT to put pause things, till things are cooled down.

Thanks,
Theo Geurts

On 30-3-2018 15:20, Michele Neylon - Blacknight wrote:
>
> 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
>
> --
>
> 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/
>
> Some thoughts: 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> 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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