[Gnso-epdp-team] Revised Recommendations for (Final) Review - Research Purpose

Kavouss Arasteh kavouss.arasteh at gmail.com
Sun Feb 3 08:36:14 UTC 2019

Dear All,
We are up to the teeth on work before finalizing the Final Report
Not wirthstanding the need or otherwise " Purpose O"my question is do we
really need to conclude on that ?
Does it have a priority within the framework of GPDR ,Phase 1 ( Current
EPDP work )
If not stop discussion and prostpone itz to later stage ,perhaps Phase 2 or

On Sun, Feb 3, 2019 at 6:25 AM farzaneh badii <farzaneh.badii at gmail.com>

> Thank you Kurt.
> I have a couple of points to make about the research purpose, in the
> report you mention that:
> "The team continued to discuss the so-called purpose O. The Team agreed
> that, to include such a
> purpose, we would require:
>  some expression from ICANN (and OCTO in particular), that personal data
> was necessary to
> carry out OCTO’s mission, and"
> *FB: *OCTO has said it does not need personal data for its research for
> now. While OCTO clearly said it does not need personal information to carry
> out its mission, how did we come to the conclusion that we need some
> expression from ICANN (and OCTO) in particular that personal data is
> necessary? Are we going to ask OCTO again? I have copy pasted their
> response at the end of this email.
> [...]
> The discussion led to the preliminary conclusions that, *it was unclear*:
>  whether OCTO required the use of personal data in its work
> *FB:* There is nothing unclear for now. OCTO has clearly said (as I cited
> them in various shape and form) that at the present they do not need
> personal information. In fact, as Benedict has been saying they will never
> need personal information for research. What they might need (in the future
> but *not now*)  is hashed personal data. To process that, some argue
> that, research should be an ICANN purpose. But there were objections to the
> speculative nature of this purpose. As some said during the meeting we
> cannot speculate what might be needed in the future for research. This
> observation needs to be recorded.
> *Solution? *I think what should be discussed if the team wants to discuss
> in phase 2 is: is it legal to have purposes for processing data for *future
> "research"* that might need disclosure of *hashed* data
> (pseudonymized data)? can  the group reach  consensus over having a purpose
> of speculative nature?
> ***
> Link: https://community.icann.org/display/EOTSFGRD/Input+from+ICANN+Org
> OCTO's response:
> Also, in discussions that the EPDP Team has had regarding purposes, ICANN
> Office of the CTO (OCTO) has been mentioned. To inform the EPDP Team’s
> continued discussion on this topic, ICANN Org would like to *clarify that
> ICANN OCTO does not require personal data in domain name registration data
> for its work.* For example, OCTO’s Domain Abuse Activity Reporting (DAAR)
> project <https://www.icann.org/octo-ssr/daar> uses only the registrar and
> nameserver information.
> Farzaneh
> On Fri, Feb 1, 2019 at 5:32 PM Kurt Pritz <kurt at kjpritz.com> wrote:
>> Hi again everyone:
>> In a followup to yesterday’s email that proposed conclusions to four
>> Recommendations, I am writing to provide one more. This Recommendation
>> incorporates the Team’s latest verbally developed conclusions on the
>> “Research Purpose.
>> As with the memoranda furnished yesterday, this one provides a brief
>> summary of the latest discussion and then follows with proposed Final
>> Report language: (1) a narrative describing the group discussion, and (2)
>> an amended Recommendation - i.e., amended from the Initial Report version
>> of the Recommendation.
>> As mentioned in the earlier emails, please review this revised wording
>> with your groups and return to us by Monday 4 Feb if you believe a region
>> or additional discussion is require -  so that we can put any this topic on
>> the Tues/Wed/Thur agendas. Let me know if you have any questions,
>> procedural or substantive.
>> I have one more paper to deliver to you - Recommendation 11 Data
>> Retention.
>> Thanks again and best regards,
>> Kurt
>> Begin forwarded message:
>> *From: *Kurt Pritz <kurt at kjpritz.com>
>> *Subject: **Revised Recommendations for (Final) Review - with
>> attachments*
>> *Date: *January 31, 2019 at 8:31:45 PM PST
>> *To: *EPDP <gnso-epdp-team at icann.org>
>> Hello Everyone:
>> Thanks again for your perseverance. And - thank you in advance for your
>> spirit of cooperation and compromise in considering the attached. We have
>> spent the last few days reviewing the transcripts and other records of our
>> recent discussions and then amending the Final Report Recommendations -
>> taking into account the Initial Report Recommendations, the small team
>> work, the conclusions in Toronto and these last several meetings.
>> The Recommendations included here are:
>> Recommendation 5 - Data elements to be transferred from Registrars to
>> Registries
>> Recommendation 10 - Email communication
>> Recommendation 12 - Reasonable Access
>> Recommendation 14 - Responsible Parties
>> [Not included are Rec. 13 (sent earlier) and Rec. 11 and the Research
>> Purpose (to be sent tomorrow.]
>> Each of these documents has a brief forward containing a description of
>> the pertinent discussion and an explanation for choosing the wording in the
>> Recommendations. They each then contain the Recommendation as originally
>> written and a redline of the proposed recommendation based on the most
>> recent discussions.  Please read the entire documents (they are not long),
>> and not just the recommendation itself.
>> I am certainly not asking for you to stand silently by if you disagree
>> with these Recommendations because they would negatively impact GDPR
>> compliance. I am asking that you study the balancing that went into this
>> and be ready to accept wording in cases where it does not match your own
>> choice.
>> Please review with your groups and return to us by Monday so that we can
>> put any of these on the Tues/Wed/Thur agendas.
>> Sincerely,
>> Kurt
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