[GNSO-Accuracy-ST] Level Setting

Mon Mar 7 16:33:46 UTC 2022

Hi Becky,

I do not think we should make a response or confirmation from the recipient
a requirement. It is the prerogative of the registrant to decide whether to
respond to anyone contacting them.

Best,
-- 
Volker A. Greimann
General Counsel and Policy Manager
*KEY-SYSTEMS GMBH*

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On Mon, Mar 7, 2022 at 5:25 PM Becky Burr via GNSO-Accuracy-ST <
gnso-accuracy-st at icann.org> wrote:

> I am comfortable with "data quality" and "contact." But don't we also need
> to agree on what "contactability" means?  Is it enough to be able to send
> an email?  Are users with legitimate interests entitled to know whether
> their communication has been received?
>
>
> *J. Beckwith Burr*
>
> HARRIS, WILTSHIRE & GRANNIS LLP
>
> 1919 M Street NW/8th Floor
>
> Washington DC 20036
>
> 202.730.1316 (P) 202.352.6367 (M)
>
>
> ------------------------------
> *From:* GNSO-Accuracy-ST <gnso-accuracy-st-bounces at icann.org> on behalf
> of Stephanie E Perrin <stephanie.perrin at mail.utoronto.ca>
> *Sent:* Monday, March 7, 2022 11:18:11 AM
> *To:* gnso-accuracy-st at icann.org
> *Subject:* Re: [GNSO-Accuracy-ST] Level Setting
>
>
> I think Steve's comments are very helpful here.  Let me be clear....I do
> not disagree with Volker, who objects to my characterization of the word
> "accuracy" as binary.  I prefer to use the expression "data quality"
> because it more exactly describes the decisions we need to make regarding
> the work threshold imposed on contracted parties, and the intrusion on the
> RNH with respect to fulfilling the data demands that are imposed on
> him/her/it as a condition of registration.
>
> The key question here is not the needs/wants/desires of third parties to
> determine precisely who the RNH is.  It is what demands for data precision,
> revision, timeliness are imposed on the RNH in the context of getting
> access to the limited resource that ICANN is tasked to manage.  The key
> criterion has always been contactability.  Obviously the CPs have a keen
> interest that the financial data provided actually works, so they need to
> leave no margin of error in such matters as credit card information, expiry
> dates etc.  However, that is "below the waterline" as I like to put it, it
> is none of ICANN's business. If the CPs can contact the registrant, all
> other processes can flow.  If the RNH chooses not to be available for a
> private sector dispute, is the remedy for this situation not already
> provided for in the contract with the RNH?
>
> Use of the term "accuracy" in my view perpetuates this infinite desire for
> updating, verifying and amplifying the information collected from the RNH.
> We in the NCSG have resisted this on many grounds, not just the intrusion
> into personal information, the failure to comply with the data limitation
> principle that is one of the key foundations of privacy law.  It is also a
> response burden on the individual or company, something governments are
> acutely aware of in their own public policy initiatives.  It is a cost
> burden on the CPS, and we wish to maintain the low cost web that we all
> have known and loved for the past couple of decades.
>
> The key question here is, when is the data "good enough".  The answer is
> "when you can contact them".  I think the proposed language from the Rys is
> confusing to someone not immersed up to his/her/their neck in this debate,
> and I hope we can come up with something better.
>
> kind regards,
>
> Stephanie Perrin
> On 2022-03-07 8:54 a.m., Steve Crocker wrote:
>
> Michael,
>
> Thanks for your thoughtful email.  IMO, the touchstone question is whether
> the data elements serve the *needs* of the parties who receive the data.
> This statement includes some important implications.
>
>    1. The focus of attention is on the parties who get the data.  Not the
>    registrant, not the registrar, not the registry and not ICANN.  The
>    registrant, registrar, registry and ICANN also have interests in this
>    process, but if the needs of the parties receiving the data aren't met, the
>    rest are irrelevant.
>
>    2. My phrase "parties who receive the data" includes recognition there
>    may be conditions controlling whether a party does or does not receive the
>    data.  The question of whether a party requesting the data is allowed to
>    receive the data, i.e., the access question, is separate.
>
>    3. My choice of the word "needs" is related to what the receiving
>    party does with the data.  This is related to but distinct from "purposes"
>    which has become a reserved word in our setting.  The list of purposes in
>    the EPDP reports is a rough attempt to capture the same notion but
>    forecloses any future discussions regarding whether the overall system is
>    actually serving the needs of the community.
>
> I have always understood the work of an "accuracy scoping team" is to lay
> the foundation for future policy development work.  Accordingly, the
> definition of accuracy must include one or more dimensions of variability,
> with future policies setting the required levels of accuracy in each
> dimension for the various circumstances.  Two of the obvious dimensions are
> (1) the degree of certainty that the data is correct when it is supplied
> and (2) how recently it has been checked.  The certainty dimension is
>
> 0 = accept whatever the registrant supplies
>
> 1 = check that the registrant's input fits syntactically for the data
> element
>
> 2 = check that the registrant's input works operationally
>
> 3 = check that the registrant's input is indeed correctly associated with
> the registrant
>
> These degrees of certainty apply to *each* of the data elements provided
> by the registrant.  For example, it is entirely plausible for a policy to
> require level 2 or 3 for the email address provided by the registrant but
> perhaps to permit level 0 for the registrant's name or organization.
>
> With respect to recency, possible values are
>
>
>    - checked when the domain was registered
>    - checked annually
>    - etc.
>
> Much of what I've said here does not fit cleanly into the binary choice
> you've presented, but I'm clearly much closer to the "degree of
> correctness" than the other choice.  The other choice will lead to burying
> all of the distinctions and shortchange any discussion of the needs of the
> receiving parties.
>
> Thanks,
>
> Steve
>
> On Sun, Mar 6, 2022 at 2:32 PM Michael Palage <michael at palage.com> wrote:
>
>> Hello All,
>>
>>
>>
>> I am looking forward to a productive ICANN73 public session tomorrow.
>>
>>
>>
>> I spent the past several days trying to digest all of the exchanges that
>> took place last Thursday. While I think we are close to wrapping up our
>> work on Assignments 1 & 2, I think it would be constructive to quickly
>> level set and make sure we are all on the same page to minimize potential
>> future confusion.
>>
>>
>>
>> Part of my level setting involved going back to the original GNSO
>> Council’s charge to the Scoping Team which asked is there “an agreed
>> definition of registration data accuracy and, if not, consider what working
>> definitions should be used in the context of the Scoping Team's
>> deliberations.” See
>> https://community.icann.org/display/AST/2.+Council+Instructions+to+Scoping+Team
>>
>>
>>
>> This task at first blush seems simple enough, but as we have learned
>> there have been several concerns raised in connection with the use of the
>> term “definition” and the meaning of “accuracy.” Therefore, instead of
>> using the term “definition” as proposed by the GNSO Council I propose that
>> we use the phrase “current contractual requirements and enforcement
>> construct.” I believe this should meet the concerns of the RrSG that have
>> repeatedly raised concerns about “providing a definition” and the concerns
>> of the GAC and others about how a definition might bias future discussions.
>>
>>
>>
>> Is there any objection to us using the phrase “current contractual
>> requirements and enforcement construct?”  If so please explain your
>> objection and proposed alternative suggestion.
>>
>>
>>
>> Next we need to tackle what I have deemed the accuracy conundrum. The
>> intervention by Stephanie this past week reminded me of some previous
>> research that I was doing which I decided to revisit. I think Stephanie hit
>> the nail on the head when she talked about how “accuracy” to most people
>> conveys a binary choice, e.g. the data is accurate or is the data
>> inaccurate.  It is a black or white answer with no room for grey. In fact
>> this seemed to align closely with the RrSG proposed “current contractual
>> requirements and enforcement construct.” If the data collected meets
>> syntactical validation and either the email or phone number was
>> operationally verified, then the data provided by the Registrant was
>> “accurate” per their interpretation of the 2013 RAA.
>>
>>
>>
>> So I decided to spend a couple of hours researching the definition and
>> origins of the word “accuracy” online and with an old school trip to the
>> local library. I believe this definition of the word “accuracy” best
>> describes the conundrum that we as a group find ourselves.
>>
>>
>>
>> noun, plural
>>
>> 1.           the condition or quality of being true, correct, or exact;
>> freedom from error or defect; precision or exactness; correctness.
>>
>> 2.           Chemistry, Physics. the extent to which a given measurement
>> agrees with the standard value for that measurement. Compare precision
>> (def. 6).
>>
>> 3.           Mathematics. the degree of correctness of a quantity,
>> expression, etc. Compare precision (def. 5).
>>
>>
>>
>> Source Dictionary.com
>>
>>
>>
>> Now the first definition “being true, correct, or exact; freedom from
>> error or defect” is a rather high bar, particularly if you are applying
>> this bar to all registration data elements processed like some working
>> group members have advocated. However, that bar is substantially lower if
>> free from defect simply means that the data collected by the Registrar was
>> syntactically correct and a Registrar at a point in time got an affirmative
>> response from either telephone number or an email.
>>
>>
>>
>> Alternatively, the third definition of a “degree of correctness” suggests
>> something other than a binary accurate or inaccurate response.  Therefore
>> to help steer our future discussions I would like everyone to answer the
>> following question:
>>
>>
>>
>> Question #1
>>
>>
>>
>> For purposes of our Working Group the term accuracy should be defined as:
>>
>>
>>
>> [  ] true, correct and free from error; or
>>
>>
>>
>> [  ] degree of correctness;
>>
>>
>>
>> (PICK ONE)
>>
>>
>>
>> I think once we get clarity and/or agreement on these points, we should
>> have a more clearly defined path forward for our post ICANN73 call.
>>
>>
>>
>> Best regards,
>>
>>
>>
>> Michael
>>
>>
>>
>>
>>
>>
>>
>>
>>
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