[Gnso-epdp-team] [Ext] Memo to ICANN re: Purpose O

[Trang Nguyen]

Hi Kurt,

Thank you for your note. As you know, ICANN org has provided a couple of responses to the EPDP Team on this topic in which we clarified that " ICANN OCTO does not require personal data in domain name registration data for its work."

https://mm.icann.org/pipermail/gnso-epdp-team/2018-October/000610.html 

https://mm.icann.org/pipermail/gnso-epdp-team/2018-October/000495.html 

Dan and I have consulted with OCTO and David Conrad and John Crain would be happy to join an EPDP Team meeting the week of January 7th to further answer any questions that the EPDP Team might have. Please let us know which meeting (the meeting on January 8th or the meeting on January 10th) you'd like David and John to join and we'll inform them.

Regarding your request for a status of the WHOIS ARS, it should be noted that there are two parts to it, the reporting part that GDD manages and the Compliance part. As communicated at the EPDP Team's Los Angeles face-to-face, the Compliance part is hold. The reporting part continues to operate. The team is working on modifications to processes in light of the GDPR before moving forward. We plan to start the next reporting cycle mid-year 2019 once modifications to the ARS process are completed. The ARS analyzes only the publically available gTLD registration data and will continue to do so when we move forward with the next reporting cycle. More information about both parts of the ARS will be published early next year.

Best,

Dan and Trang
ICANN Org Liaisons

On 12/10/18, 3:50 PM, "Kurt Pritz" <kurt at kjpritz.com> wrote:

    Hi Dan & Trang:
    
    After our last call, Benedict and I briefly spoke some more about the proposed “Purpose O” for ICANN research related to stability and security issues. In that discussion, we reiterated the position of many on the EPDP call that it seemed awkward that Benedict was the key (even sole) proponent of this purpose and that it seemed logical that ICANN should be championing this. 
    
    For me, it seems reasonable that a full understanding of this purpose for processing registration data should be available -  to give the EPDP team the opportunity to hear, in some detail, the benefits, costs and risks of this “purpose” so that they have full information and can decide if it should be included. 
    
    If ICANN agrees that they should have access to data for SSR research, what is the best way to bring this information to the EPDP team? I would suggest David Conrad or John Crain present to our group to inform our discussion and flesh out the material in the “purpose O” as currently written.
    
    ICANN staff could describe the effect of GDPR on research efforts, i.e., what could be done prior to 25 May that can no longer be done? What is necessary to overcome any GDPR barriers placed in the way of ICANN SSR research? 
    
    I think reticence on the part of ICANN to participate in this part of the EPDP deliberation would be interpreted as lack of ICANN support for these types of projects and an indication that their value does not rise to the level of importance indicated by Benedict and others. That would be fine with me but I wanted you to understand the implication as I see them. As you heard, Benedict was in a tough position defending the access to data by ICANN.
    
    On a different but related topic, can ICANN report on the status of the Whois Accuracy Reporting System Project? During the recent call I believe Alan Greenberg stated that he thought it was “stopped” but the Trang said it was not closed off and might be starting again. I ask this because this project will be discussed at an upcoming meeting and, to me, it might fall under “Purpose O” as it is a study of finite duration, approved by the community and currently stopped. I understand it does not fall under the aegis of the Office of Technology but It could be described by the ICANN group championing it. I understand that this falls under GDD. In any event, a status, including the effects of GDPR on this project would benefit the discussion. 
    
    Let me know your thinking and if I can provide any additional communication. 
    
    Best regards,
    
    Kurt