[Gnso-epdp-team] For your review - latest version of EPDP Team Final Report

farzaneh badii farzaneh.badii at gmail.com
Sun Feb 3 08:27:05 UTC 2019

Thank you very much for this work. I guess you mean to mark the concerns by
4th Feb and not March.

Here are some of my comments:

Line 1542, Rec 12: Reasonable access should be called "parameters for
responding to lawful disclosure requests". Why does line 1542 recommends a
modified version?

Line 1558, Rec 12: It is worrisome that so much leeway and emphasis has
been given for the implementation phase to clarify the criteria further.

Line 1580, Rec 12: When did we agree that a separate guideline/timeline
might be considered for disclosure of personal data in urgent
circumstances? I did record my objection to that.
Line 1589: EPDP recommends that working on these (disclosure) criteria
start as soon as possible. What does that mean? Are we recommending that
implementation of disclosure criteria start sooner than anything else?

Rec 12 in general: all the "access" language has to be replaced with
disclosure requests.

Line 1936, Rec 13: Joint Controller Agreement language is removed,
providing no rationale.  Other than Chris Disspain's point of view and the
US government reasoning, as I say I don't see objections to JCA. If you
have considered the public comments to make this change, please let us
know. If you have considered other factors I would like to know what they

Line 2066, Rec 18:  If we are getting rid of data processing agreement
replacing with data protection arrangements (which I don't personally agree
with) then please be consistent throughout the document. Or are we only
getting rid of DPA and JCA only regarding registries and registrars?

Line 2129, Rec21: Data processing agreement/ JCA mentioned for Escrows etc.
Are we keeping this language?

I will send more comments soon.


On Fri, Feb 1, 2019 at 6:10 PM Marika Konings <marika.konings at icann.org>

> Dear EPDP Team,
> Please find attached for your review the latest version of the Final
> Report. In relation to section 5, EPDP Team Responses to Charter Questions
> & Recommendations, please note that those sections highlighted in green are
> considered finalized for inclusion in the Final Report, sections in blue
> are still under review / consideration (but these do include the latest
> language, unless indicated differently).
> For substantive issues or concerns, please flag these on the mailing list
> by *Monday 4 March COB* so that these can be included in the meeting
> agendas for next week. If you want to reference specific parts of the
> report, please use the line numbering of the attached pdf version. For any
> minor edits / updates, please use the google doc:
> https://docs.google.com/document/d/1sVZ9odV0qK1Bk8a4bDwWe5RW_PBzOnYBhHW_GnLL8jw/edit?ts=5c4f07ef.
> On the wiki (see https://community.icann.org/x/VZwWBg), we have also
> posted a Word and clean version for those of you that prefer that format.
> As you review the Final Report, we want to remind you of Kurt’s message
> that also seem to apply here: “study the balancing that went into this and
> be ready to accept wording in cases where it does not match your own
> choice”.
> As a reminder, revisions to the data elements workbooks to ensure
> alignment with EPDP recommendations are being undertaken by a small team
> which is expected to share the results of its work shortly.
> Best regards,
> Caitlin, Berry and Marika
> *Marika Konings*
> *Vice President, Policy Development Support – GNSO, Internet Corporation
> for Assigned Names and Numbers (ICANN) *
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