[Gnso-epdp-team] RrSG initial comment on SSAD Registrant user group

Alan Woods alan at donuts.email
Fri Jun 7 15:06:29 UTC 2019

Thank you Sarah.

Greg just for completeness, an EU data subject will of course still be
entitled to exercise their rights against the 'SSAD' also. If their data is
processed within the SSAD then whoever is the guardian of that system,
shall have to have
a) a viable and robust process for dealing with such requests directly
themselves (assuming they are a controller), and/or
 b) provide the necessary information and aid to other controllers dealing
with such requests in this data processing ecosphere (especially Art 17).

But I do agree, expecting them to have to be a "subscribed" or
"credentialed"  user in order to exercise such rights is a *very* bad idea.


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Alan Woods
Senior Compliance & Policy Manager, Donuts Inc.
The Victorians,
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Dublin 2, County Dublin

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On Fri, Jun 7, 2019 at 3:33 PM Greg Aaron <greg at illumintel.com> wrote:

> Agree.  Registrants already have the appropriate means to view their own
> sensitive data fields and update their domain data: the registrar’s
> system.  And that provides controlled, permissioned access for the
> registrants to see their data and theirs only.  And registrants will have
> public access to RDS to see non-sensitive data about their domains.
> To offer registrants access to the SSAD System on top of that would be a
> nightmare from an access management view.  (How would registrants get
> credentials into a SSAD, and how would that system know what records the
> registrant is allowed to see?)   SSAD is for third parties who need to
> access non-public data.
> All best,
> --Greg
> *From:* Gnso-epdp-team <gnso-epdp-team-bounces at icann.org> *On Behalf Of *Sarah
> Wyld
> *Sent:* Thursday, June 6, 2019 9:36 AM
> *To:* gnso-epdp-team at icann.org
> *Subject:* [Gnso-epdp-team] RrSG initial comment on SSAD Registrant user
> group
> Hello all,
> The RrSG has significant concerns with the inclusion of Registrants as a
> user group for the System for Standardized Disclosure of non-public gTLD
> registration data, and strongly recommends that this group be removed from
> the proposed list of users. We are curious as to the origin of these
> proposed user groups, and suggest that instead of working through this list
> we begin by reviewing the purposes for processing data (Recommendation 1)
> and assessing the potential user group applicable to each purpose.
> Registrants already access their domains via their service provider
> (registrar or reseller)’s system, as required under the RAA. Having
> multiple interfaces to access the same information poses a significant risk
> of inappropriate data exposure; this unnecessary and unbalanced security
> risk is not compliant with data protection law. It also creates a confusing
> user experience for the registrant. For example, if a registrant uses the
> SSAD to review their domain data for the purpose of confirming that it is
> accurate, they would still need to work with their service provider to
> confirm that the data held in that system is also up to date.
> The RrSG notes that a system used to access or disclose data is not also a
> system to modify that data. The EPDP team definitions of access and
> disclosure do not include any capability to modify the data, so this is a
> new addition to the requirements not grounded in any previously agreed-upon
> basis or definition. Modification of domains via the SSAD could easily
> result in synchronization issues and security risks, where the SSAD holds
> data that is different from what is in the registrar or reseller’s
> platform, or an unauthorized party could modify and even hijack a
> registered domain. This also represents a fundamental shift from the system
> in place for the past twenty years: EPP is one-directional, with data
> flowing from the reseller or registrar through to the registry, so any
> functionality for updating domain data would need to be created and
> implemented by thousands of service providers worldwide.
> We look forward to discussing this important concern at today’s EPDP team
> call. Beyond these concerns about the “Registrants” group, we are also
> uncertain that “end users” is a valid group; this and the other groups
> should be discussed with the plenary team.
> --
> Sarah Wyld
> Domains Product Team
> Tucows
> +1.416 535 0123 Ext. 1392
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