[Gnso-epdp-team] Pro-forma Triage Report

Alex Deacon alex at colevalleyconsulting.com
Sun Aug 19 16:42:20 UTC 2018

Hi Kurt, All,

Just catching up on this topic. Its not clear to me how one can come to the
conclusion that there was no opposition to redacting the data elements the
Temp Spec designates.

In Part 2 of the triage, support for Section 5.1, which specifies
compliance to Appendix A (where redaction is discussed) resulted in a
66.67% "no" response. ,  In part 1 of the triage, support for Appendix A
2.1-2.3 resulted in 89.98% "no" response,.  Finally, Appendix A 2.4-2.5
received a "no" response rate of 77.78%.     Even if you put aside the
response count and look at the responses themselves you will see there is
significant disagreement--at least with respect to the IPC (and even BC and
GAC although I won't speak for them.)

As has been our position since the beginning of the these temp spec
discussions we believe the Temp Spec has over-redacted a number of data
elements. You can read the details for our rational in our response to
Question 22 of Part 1 of the triage. However, to summarize:

First, we believe that it is a misapplication of the GDPR for the Temp Spec
to make no distinction between registrants that are legal persons versus
natural persons for purposes of data element/field redactions. Second, even
for natural person registrants we believe that certain data elements that
are designated for redaction should not be redacted. We think at minimum
that the registrant's e-mail address, as supplied to and verified by the
registrar, should not be redacted. These views have been expressed
repeatedly by the IPC, (BC, the GAC and others) over the past months both
before and after the Temp Spec was issued.

Bottom line I respectfully do not agree with this particular takeaway or
Milton's suggested modification. We have significant objection to and
disagreement with the data elements/fields that the Temp Spec has
designated for redaction.

For the avoidance of doubt while we do not oppose (and even accept) that
some data will be placed "behind a gate" to ensure GDPR compliance we feel
continued discussion about which data should be redacted (and when/why) is



On Thu, Aug 16, 2018 at 5:58 AM Kurt Pritz <kurt at kjpritz.com> wrote:

> Good amendment, Thanks Milton.
> Kurt
> On Aug 16, 2018, at 5:56 AM, Mueller, Milton L <milton at gatech.edu> wrote:
> Thanks for the draft of the Triage Report, Kurt. Having read only the Exec
> Summary, I think staff did a very good job of summarizing the "takeaways."
> I would like for one small amendment to be made, however. In the second
> paragraph you write:
> "There were several areas of agreement with the underlying principles in
> several sections of the Temporary Specification (e.g., data redaction)."
> NCSG would like this to be amended to clarify:
> "There were several areas of agreement with the underlying principles in
> several sections of the Temporary Specification; in particular, there was
> no opposition to redacting the data elements the temp spec designates."
> Dr. Milton L Mueller
> Professor School of Public Policy
> Georgia Institute of Technology
> <image001.jpg> <http://internetgovernance.org/>
> *From:* Gnso-epdp-team [mailto:gnso-epdp-team-bounces at icann.org
> <gnso-epdp-team-bounces at icann.org>] *On Behalf Of *Kurt Pritz
> *Sent:* Wednesday, August 15, 2018 8:48 PM
> *To:* GNSO EPDP <gnso-epdp-team at icann.org>
> *Subject:* [Gnso-epdp-team] Pro-forma Triage Report
> Hi Everyone:
> It was requested that we prepare a “pro forma” Triage Report for review
> and discussion - a version of the Triage report that might be submitted to
> the Council when the surveys are completed.
> This represents the work from the first survey, about 30% of the Temporary
> Specification. So you can see, it will be a fairly long report.
> The report includes an executive summary, our operating methodology, the
> summary table of inputs, the issue summaries that were created for each
> section and an appendix with all written comments.
> This report hasn’t had sufficient vetting on the leadership-support side
> yet but I wanted you to see the formatting and level of content as soon as
> possible.
> I apologize for the font size in the appendix. We will reorganize the
> table of all comments in some way that is readable in time for the actual
> publication.
> We will continue building this report and amending it in accordance with
> comments and discussion as we go along. Remember that this report is
> designed to help but not limit, prejudice or restrict our future work. So
> let’s spend time to make this good, but not perfect.
> I hope you find this helpful.
> Best regards,
> Kurt
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*Alex Deacon*
Cole Valley Consulting
alex at colevalleyconsulting.com
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